Actually there is a difference. The reason wong is important is because it repeats what was in Minor v. Happersett, decided in 1875 in the Decision:
“‘At common law, with the nomenclature of which the framers of the constitution were familiar, it was never doubted that all children born in a country, of parents who were its citizens, became themselves, upon their birth, citizens also. These were natives or natural-born citizens, as distinguished from aliens or foreigners.
Some authorities go further, and include as citizens children born within the jurisdiction, without reference to the citizenship of their parents. As to this class there have been doubts, but never as to the first. For the purposes of this case, it is not necessary to solve these doubts. It is sufficient, for everything we have now to consider, that all children, born of citizen parents within the jurisdiction, are themselves citizens.’”
What makes this phrase so important is that it acknowledges that there IS a difference, and that in this case, the difference does not need to be defined, and that is why SCOTUS didn't list it out. That was a mistake as far as I am concerned. But it is what it is. There IS a difference and the court was aware of it, and THAT is why Wong and Happerset are important and relevant.
From:
http://www.theobamafile.com/_eligibility/IssueFourCases.htm#McCain" The ObamaFile one of the best resources on the net:
Statutory Vs Natural Born
A statutory citizen (bestowed by man's pen) can never be a "natural born" citizen (bestowed by God/nature).
Statutory citizenship means that a person's citizenship requires a law or laws to define it. A citizen via statute is constitutionally ineligible to serve as Commander-in-Chief.
A person who is natural born requires no laws to define their citizenship. Only a "natural born" citizen is constitutionally eligible to serve as Commander-in-Chief.
"Natural born" citizens are in a class separate from all others. They are, in fact, in a classification or category unto themselves because they alone are eligible to serve as Commander-in-Chief -- a fact that unsettles many.
Circumstances Of Birth And Citizenship
1. Birthplace important AND parentage important -- a "natural born" citizen is any person born in the US mainland (includes Alaska and Hawaii) AND born of US citizen parents (that's two) -- think Ronald Reagan.
2. Birthplace important AND parentage not important -- a "native born" citizen (also considered a 14th Amendment citizen) is any person born in the US mainland (includes Alaska and Hawaii) -- one or both of the parents may be foreign nationals -- think Barack Obama.
3. Birthplace not important AND parentage important -- a citizen "by statute" is any person born of a US citizen parent(s) outside the US mainland -- think John McCain.
4. Birthplace not important AND parentage not important -- a "naturalized" citizen is a citizen as the result of a process (i.e. by federal statute as bestowed to Congress under Art. I, Sec. 8, Cl. 4) -- think Arnold Schwarzenegger.
The Reagan Case
Ronald Reagan was born in Tampico, Illinois, USA. His father, John "Jack" Reagan, was born in Fulton, IL, as was his mother, Nelle Wilson Reagan.
By blood and by place of birth, Ronald Reagan was a "natural born" citizen. No law bestowed his citizenship upon him. His father was an American. His mother was an American. He was born in America. He was a "natural born" American citizen.
This case meets the test of jus soli -- born in the USA This case meets the test of jus sanguinis -- parents are US citizens
This person is a "natural born" citizen and is eligible to serve as Commander-in-Chief.
The Obama Case
It's 97% certain that Barack Obama was born in Hawaii. There's a 40% chance he was born at the Kapi'olani Medical Center, a 40% chance he was born at the Queens Hospital, and a 17% chance he was born at home. No Honolulu hospital has a record of Obama or mother ever being there. There's also a 2% chance that Obama was born in Kenya, and a 1% chance he was born in Vancouver, BC. Wherever he was born, he had one American citizen parent and one Kenyan citizen parent. An Indonesian adoption could further complicate Obama's status.
At birth, Barack Obama gets his citizenship via the 14th Amendment (assuming Hawaii):
"All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside."
Obama also has his citizenship defined via the Immigration and Nationality Act -- "by statute."
Sec. 305. [8 U.S.C. 1405] Persons born in Hawaii:
A person born in Hawaii on or after August 12, 1898, and before April 30, 1900, is declared to be a citizen of the United States as of April 30, 1900. A person born in Hawaii on or after April 30, 1900, is a citizen of the United States at birth. A person who was a citizen of the Republic of Hawaii on August 12, 1898, is declared to be a citizen of the United States as of April 30, 1900.
At birth, Barack Obama was also a Kenyan citizen and a subject of Great Britain:
"When Barack Obama Jr. was born on Aug. 4,1961, in Honolulu, Kenya was a British colony, still part of the United Kingdom’s dwindling empire. As a Kenyan native, Barack Obama Sr. was a British subject whose citizenship status was governed by The British Nationality Act of 1948. That same act governed the status of Obama Sr.‘s children.
The implications of a Soetoro adoption:
Under Indonesian law, when a male acknowledges a child as his son, it deems the son, in this case Soetoro/Obama, an Indonesian State citizen. See Constitution of Republic of Indonesia, Law No. 62 of 1958 concerning Immigration Affairs and Indonesian Civil Code (Kitab Undang-undang Hukum Perdata) (KUHPer) (Burgerlijk Wetboek voor Indonesie).
The implications of Kenyan or British Columbian birth:
Sec. 301. [8 U.S.C. 1405] Nationals and Citizens of the United States at Birth:
(d) a person born outside of the United States and its outlying possessions of parents one of whom is a citizen of the United States who has been physically present in the United States or one of its outlying possessions for a continuous period of one year prior to the birth of such person, and the other of whom is a national, but not a citizen of the United States;
(e) a person born in an outlying possession of the United States of parents one of whom is a citizen of the United States who has been physically present in the United States or one of its outlying possessions for a continuous period of one year at any time prior to the birth of such person;
Click here for detailed scenarios of Obama’s citizenship status.
This case meets the test of jus soli -- born in the USA (97%) This case fails the test of jus sanguinis -- one or both parents are NOT US citizens
This person is NOT a "natural born" citizen and is NOT eligible to serve as Commander-in-Chief.
The McCain Case
John Sidney McCain III was born at the Colon Hospital, located at Avenida Melendez and 2nd Street, Manzanillo Island, City of Colon, Republic of Panama. The time of birth on the birth certificate issued by Panama Railroad Company (that owned the Colon Hospital) was 5:25 PM and the day and date of birth was Saturday, August 29, 1936.
John McCain's father, John S. McCain Jr., was a US Naval officer serving in the Panama Canal Zone. His mother is Roberta Wright. Both were American citizens.
McCain gets his citizenship via the Immigration and Nationality Act -- "by statute."
Sec. 301. [8 U.S.C. 1401] The following shall be nationals and citizens of the United States at birth:
(c) a person born outside of the United States and its outlying possessions of parents both of whom are citizens of the United States and one of whom has had a residence in the United States or one of its outlying possessions, prior to the birth of such person;
Sec. 303. [8 U.S.C. 1403] Persons born in the Canal Zone on or after February 26, 1904
(b) Any person born in the Republic of Panama on or after February 26, 1904, and whether before or after the effective date of this Act, whose father or mother or both at the time of the birth of such person was or is a citizen of the United States employed by the Government of the United States or by the Panama Railroad Company, or its successor in title, is declared to be a citizen of the United States.
This case fails the test of jus soli -- NOT born in the USA This case meets the test of jus sanguinis -- parents are US citizens
This person is NOT a "natural born" citizen and is NOT eligible to serve as Commander-in-Chief.
The Schwarzenegger Case
Arnold Schwarzenegger was born in Thal, Austria, a small village bordering the Styrian capital Graz, on July 30, 1947. His parents were the local police chief, Gustav and his wife, Aurelia Jadrny.
Schwarzenegger moved to the United States in September 1968 at the age of 21. He is a dual Austria/United States citizen. He holds Austrian citizenship by birth, and has held U.S. citizenship since becoming naturalized in 1983.
This case fails the test of jus soli -- NOT born in the USA This case fails the test of jus sanguinis -- parents are NOT US citizens
This person is NOT a "natural born" citizen and is NOT eligible to serve as Commander-in-Chief -- this is the only one everybody agrees on.
14th Amendment And The U. S. Code
The 14th Amendment defines citizenship this way: "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside." But even this does not get specific enough. As usual, the Constitution provides the framework for the law, but it is the law that fills in the gaps.
Title 8 of the U.S. Code fills in those gaps. Section 1401 defines the following as people who are "citizens of the United States at birth:"
Jus soli only OR No jus soli but one or two parents US citizens OR Indians (plus some found orphans).
There is no mention of race, religion or ethnicity, nor any mention of "natural born citizen," because this is not part of the law's defining a statutory US citizen.
There is no provision in USC 1401 Section 8, which is guided by the 14th amendment, that both parents be US Citizens AND that a child must be born on US soil. None. This is the only omitted permutation, every other one is covered by the US Code 1401 Section 8.
Natural Born Citizen is not IN the Constitution (14th amendment), nor in its subsequent laws. The only humanly possible permutation omitted from the 14th Amendment and USC 1401 is for Natural Born Citizen (jus soli AND jus sanguinis).
Race has nothing to do with the topic of being a natural born citizen. Lt. Col. Allen West is a natural born citizen, and a far better human being than the usurper could ever hope to be in a thousand life spans.
Summary
Many citizens of this country fail to meet the "natural born citizen" classification and yet have no divided loyalties. At no fault of their own, they are disqualified from pursuing the position of President of the United States of America. Loyalty lies within men's hearts and minds and not their birth circumstances. One's birth circumstances could have the possibility of, but not a guarantee of, promoting divided loyalties and that is the reason for the "natural born citizen" clause/language within our constitution.
There are many that will argue the logic, because to them it will seem unfair. Maybe it is unfair, but that is what the constitutional amendment process is for. Personally, I don't think it's unfair, because the "natural born citizen" language was wisely and intentionally installed in the U. S. Constitution as a national security measure or safeguard. It was put there to protect our country from a Commander in Chief with divided loyalties. This is the exact situation that we find ourselves in now as Barack Obama has, on more than one occasion, proclaimed that he is a "citizen of the world." That is how he sees himself.
Points To Ponder
• natural born citizens have NO other nation-ties at birth
• natural born citizens are the consummate "pure Americans"
• natural born citizens have no more rights AS CITIZENS than do statutory citizens, but being president is not a "right", it is a privilege entailing highly discriminatory criterion for eligibility including age, duration of residency, as well as parentage and place of birth (but not race or ethnicity or religion)
• natural born citizenship is that state AT BIRTH, and cannot be granted at any point beyond
• natural born citizenship is the highest national security eligibility criterion