I was looking for support for my point of view (that taking an oath or affirming of allegiance is not necessary to establish a finding of owing allegiance), and made the mistake of excluding only military (or government actor) defendant cases. I didn't pause to consider that naturalized citizens take an oath of allegiance.
Robert Henry Best
Philip Vigol
Tokio Rose
Assundry others all convicted of treason.
Your argument is stronger IMO.