What about rummy Chick's contention that the lower court used the term "natural born citizen" and the Supreme Court in it's holding ruled "upheld without exception" ?
Would that not change the understood meaning of Wong Kim Ark to be a decision that he IS a "natural born citizen"?
The WKA court explicitly said they were ONLY ruling on whether WKA was a 14A citizen. Even the Ankeny court admitted this in a footnote. This is the whole point of Leo Donofrio’s excoriation of the Ankeny court for waiving a wand and deciding that considering WKA and the 14A “in tandem” made Obama an NBC.
I disagree with RummyChick and would rather agree to disagree with her than to rehash her argument. I prefer the conclusions of law of Donofrio and Hatfield as applied to the different facts in Minor, ARK, and Ankeny.