On page 12 the filing begins arguing there are three class of citizens, naturalized, "native born", and natural born citizens. It treats "native born" the same as naturalized and puts Harris in the "native born" class.
Under US law and case law, there are only two types of citizens, naturalized and natural born. There is no third class of "native born" citizens who are not natural born citizens and are legally treated as naturalized citizens, or any third classification citizen at all.
By claiming and arguing from a third class of American citizenship that does not exist this case will fail.
(Under US law and case law, there are only two types of citizens, naturalized and natural born.)
So why does the presidential qualification clause say Citizen and Natural Born Citizen?
[No Person except a natural born Citizen, or a Citizen of the United States, at the time of the Adoption of this Constitution, shall be eligible to the Office of President]
Well that makes perfect sense. For the longest time, I didn't realize that the people who debated the 14th amendment regarded it as a "naturalization" process. They say so in the debates, which you can read online.
But let me tell you, they are looooong and boring.
So just being born here makes you a citizen under the 14th amendment, and the people who wrote it *SAY* it is "naturalization."