There were a number of 20th Century SCOTUS decisions on revokation/ renunciation of citizenship, including Afroyim v. Rusk and several others.
Yes, that's why I said the 20th century courts had forgotten about the part of Ark that I quoted. The idea of not being able to renounce a child's citizenship is relatively a new invention. Ark had no problem understanding that it could happen at the end of the 19th century.