I'd have to say that Rogers v. Bellei is what finally convinced me that it is more likely than not that statutory citizens at birth are natural-born citizens.
The Court cited Justice Gray's stipulation in Wong Kim Ark:
"But it [the first sentence of the Fourteenth Amendment] has not touched the acquisition of citizenship by being born abroad of American parents; and has left that subject to be regulated, as it had always been, by Congress, in the exercise of the power conferred by the Constitution to establish an uniform rule of naturalization."In doing so the Court said:
Thus, at long last, there emerged an express constitutional definition of citizenship. But it was one restricted to the combination of three factors, each and all significant: birth in the United States, naturalization in the United States, and subjection to the jurisdiction of the United States. The definition obviously did not apply to any acquisition of citizenship by being born abroad of an American parent. That type, and any other not covered by the Fourteenth Amendment, was necessarily left to proper congressional action.In establishing a uniform rule of naturalization, Congress defines who requires naturalization and who does not. Granted, Congress can and has changed its collective mind over the years, but the Constitution implicitly gives Congress the right to do so.The Court has recognized the existence of this power. It has observed, "No alien has the slightest right to naturalization unless all statutory requirements are complied with . . . ." (snip) And the Court has specifically recognized the power of Congress not to grant a United States citizen the right to transmit citizenship by descent.
I am at a loss as to how to respond to this message. Your quotes and examples would see to me to make the exact opposite point which you are arguing. You even quote a part which implicitly says that children born abroad to citizens are "naturalized" by congressional action.
The definition obviously did not apply to any acquisition of citizenship by being born abroad of an American parent. That type, and any other not covered by the Fourteenth Amendment, was necessarily left to proper congressional action.
To make the context even more clear, I'll show you where it says the same thing in Wong Kim Ark.
Every person born in the United States, and subject to the jurisdiction thereof, becomes at once a citizen of the United States, and needs no naturalization. A person born out of the jurisdiction of the United States can only become a citizen by being naturalized, either by treaty, as in the case of the annexation of foreign territory, or by authority of Congress, exercised either by declaring certain classes of persons to be citizens, as in the enactments conferring citizenship upon foreign-born children of citizens, or by enabling foreigners individually to become citizens by proceedings in the judicial tribunals, as in the ordinary provisions of the naturalization acts.
If you are going to cite Wong Kim Ark as the legal authority for your position, it specifically says the foreign born children of American citizens can only be naturalized citizens.