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A Critique of “On the Meaning of ‘Natural Born Citizen'”
The Post & Email Newspaper ^ | 02 Apr 2024 | Joseph DeMaio

Posted on 04/03/2024 6:50:18 PM PDT by CDR Kerchner

(Apr. 2, 2024) — Introduction

In 2015, two former high officials in the Office of the Solicitor General in the U.S. Department of Justice – Messrs. Paul Clement, a Republican, and Neal Katyal, a Democrat – jointly authored an article on the Constitution’s “natural born Citizen” term (hereafter, for brevity, “nbC”). Entitled “On the Meaning of ‘Natural Born Citizen,’” the article appeared in the March 2015 edition of the Harvard Law Review Forum (128 Harv.L.Rev.F. 161), which describes itself as the “the online companion to the print journal (i.e., the Harvard Law Review) and where “[i]t hosts scholarly discussion of our print content and timely reactions to recent developments.” Even today, the article is still widely cited as an authoritative source on the nbC issue, thus now warranting a revisiting for a more detailed examination of its contents.

By way of background, Paul Clement was nominated in 2005 by President George W. Bush to be the 43rd Solicitor General of the United States. He served in that capacity – well and honorably – between 2005 and 2008. After graduating magna cum laude from Harvard Law School, he clerked (1993-1994) for Associate Supreme Court Justice Antonin Scalia, in your humble servant’s view, one of the best Supreme Court Justices of the last century.

(Excerpt) Read more at thepostemail.com ...


TOPICS: Chit/Chat; Education; History; Miscellaneous
KEYWORDS: barackobama; birther; constitution; constitutionalist; eligibility; kamalaharris; naturalborncitizen; nicoleshanahan; president; tedcruz
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An excellent and scholarly article by the constitutional scholar Joe DeMaio analyzing the 2015 paper written by Paul Clement and Neal Katyal about the constitutional term "natural born Citizen".
1 posted on 04/03/2024 6:50:18 PM PDT by CDR Kerchner
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To: CDR Kerchner

Funny, they mention Cruz. He originally said that he was not qualified, was not an NBC. Then, when he decided he wanted to run, he changed his mind. Well, he’s not.


2 posted on 04/03/2024 7:11:04 PM PDT by Reno89519 (If Biden is mentally unfit to stand trial, he is mentally unfit to be president. He needs to resign.)
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To: CDR Kerchner

zfg what these alleged ‘scholars’ declared to be the definition of NBC. Common sense tells us what the founders meant. And obama was not ever a NBC.

It’s pretty shameles and disturbing how they’re re-writing history. And all for the sake of protecting affirmative action obama.


3 posted on 04/03/2024 7:11:36 PM PDT by imabadboy99
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To: imabadboy99

more G W MORON hangers on foisting their neoCON BS on the public. We all know what natural born citizen means, yet they use mental gymnastics to tell us that it’s a meaningless term.

Citizen at birth does NOT = natural born citizen. Never has. But the constitution was “reinterpreted” for affirmative action globohomo obama because he’s part of their satanic one-world club.


4 posted on 04/03/2024 7:17:29 PM PDT by imabadboy99
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To: CDR Kerchner

imho there should be an amendment to the law to clarify the meaning of natural born citizen.


5 posted on 04/03/2024 7:22:56 PM PDT by ckilmer
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To: ckilmer

“there should be an amendment to the law to clarify the meaning of natural born citizen.”

This is the only way that it will ever be defined and not interpreted. The courts all of then including by lack of action the Supreme Court have left the current interpretation to be if you are born on American soil you are a natural born citizen. Argue till blue in the face won’t change the fact that right now for all legal standing this is what the courts plural have said is the law of the land. Don’t like , scream to the hills about doesn’t matter it is standing policy and will not change until either the Supreme Court over turns USA v Wong and a slew of other rulings or a amendment is passed over their heads. That’s just how it is. I look forward to the 400+ replies these threads always get with all the huff and puff and mental masturbation. Nothing will change until one of the above two things happens. The likely hood of the USSC ruling that the big I was retrospectively ineligible is like lottery odds as in virtually zero. So the amendment route is the only way and also not very likely since the blue states don’t want one citizen parent which would also stop their precious anchor babies in the same amendment one cannot be done without the other. So the blue states will never slammed out the 14th anchor baby clause.


6 posted on 04/03/2024 7:58:45 PM PDT by GenXPolymath
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To: GenXPolymath

Stupid phone auto spell.

The likelihood of the USSC ruling that the big O was retrospectively ineligible is like lottery odds as in virtually zero. So the amendment route is the only way...


7 posted on 04/03/2024 8:00:26 PM PDT by GenXPolymath
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To: CDR Kerchner

Here’s where I hang my hat. Vattel and the letter between Jay and Washington concerned about a “foreigner” being commander in chief.

If you have a choice at birth let’s say like Obama who could be a Brit by virtue of his father’s citizenship or a US by virtue of his mother (assuming he was born in Hawaii), then you are not natural born to the US because you have a choice. It would seem that the founders coming off the revolution would not want the son or daughter of a British citizen to be president, even though they grandfathered themselves.

So the citizenship of the parents determines. Jindal, Obama, Haley, Harris, Vivek not eligible.

I do acknowledge we need congressional action or USSC decision to have any certainty. Of course the court rejected 6 cases on Obama’s qualifications.


8 posted on 04/03/2024 8:04:31 PM PDT by coalminersson (since )
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To: CDR Kerchner

If you need to go through the naturalization process in order to become a citizen, you are not “natural born.” Otherwise, you are. It really is that simple, regardless of how some want to make it complicated.


9 posted on 04/03/2024 9:03:56 PM PDT by DennisR (Look around - God gives countless clues that He does, indeed, exist .)
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To: coalminersson

ditto


10 posted on 04/03/2024 9:11:43 PM PDT by justrepublican (Screaming like a "Vexatious requester" at a Wellstone memorial........)
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To: coalminersson

Don’t leave Cruz off that list.


11 posted on 04/03/2024 9:27:40 PM PDT by moonhawk (Jeffrey Epstein did't kill himself; George Floyd did.)
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To repeat once again - history and reality already dictate what it meant at the time it was written - and also what Courts have already ruled. Papers making arguments do not change reality:


If the Framers did not intend for the phrase they put into the Constitution - Natural Born Citizen - to mean what it meant at the time they wrote it, they would have written out a definition into the Constitution to redefine it. Since they did not, we can only assume it meant what the phrase meant when they wrote it out - the English common law definition - those born within the borders of the realm are naturally born citizens. There are a number of court cases where it is defined in this manner with regard to those born with far looser connections to the United States than Marco Rubio, Chester Arthur, (or Kamala Harris). The first case where it seems this was dealt with by a court was Lynch vs. Clarke in New York over a dispute with who could inherit property - there was a law on the books stating that only a “U.S. Citizen” could inherit property, and the presiding judge (apparently in this court the judge was called a “Vice Chancellor”) made this declaration: “Suppose a person should be elected president who was native born, but of alien parents; could there be any reasonable doubt that he was eligible under the Constitution? I think not. The position would be decisive in his favor, that by the rule of the common law, in force when the Constitution was adopted, he is a citizen...Upon principle, therefore, I can entertain no doubt, but that by the law of the United States, every person born within the dominions and allegiance of the United States, whatever the situation of his parents, is a natural born citizen. It is surprising that there has been no judicial decision upon this question.” In another case decided by the U.S. Supreme Court over the citizenship of a person born who was born to Chinese parents (it was illegal at that time for Chinese immigrants to become U.S. Citizens) it was declared that he was a natural born citizen by virtue of having been born in the United States, and Justice Field, who wrote the opinion, actually referenced the Lynch v. Clarke decision in the ruling of the Court: “After an exhaustive examination of the law, the Vice-Chancellor said that he entertained no doubt that every person born within the dominions and allegiance of the United States, whatever the situation of his parents, was a natural-born citizen, and added that this was the general understanding of the legal profession, and the universal impression of the public mind.” This case was In re Look Tin Sing. Another U.S. Supreme Court case was United States v. Wong Kim Ark https://www.law.cornell.edu/supremecourt/text/169/649 dealing with the same issue of a child born to Chinese parents made the same ruling and also declared him to be a natural born citizen in the ruling by virtue of his right to citizenship by birth. All of those cases were in the 1800s.

There was a U.S. Supreme Court case in 1939 with the title Perkins v. Elg http://caselaw.findlaw.com/us-supreme-court/307/325.html which dealt with the issue of a woman who was born in the U.S. to Swedish citizens who returned to Sweden with her when she was four years old. Her father was naturalized prior to this as a U.S. Citizen and held dual citizenship. She then came back to the U.S. and was admitted entry as a citizen at the age of 21. For whatever reason, her father later did away with his U.S. Citizenship status and the equivalent of the INS at the time declared she was to be deported. The U.S. Supreme Court ruled against this, finding she was a natural born U.S. Citizen by right of birth and even declared she was eligible to be President of the United States in the ruling. A past President, Chester Arthur, was born with an Irish father who was not yet naturalized as a U.S. Citizen, though his mother was born in Vermont where Arthur himself was born.

Detractors like to ignore all of information and court cases and instead rely totally on a case Minor v. Happersett - seeming to deliberately misquote the ruling - indeed, the justices specifically stated they were not making a finding of every scenario that constitutes a natural born citizen in their ruling: “The Constitution does not, in words, say who shall be natural-born citizens. Resort must be had elsewhere to ascertain that. At common-law, with the nomenclature of which the framers of the Constitution were familiar, it was never doubted that all children born in a country of parents who were its citizens became themselves, upon their birth, citizens also. These were natives, or natural-born citizens, as distinguished from aliens or foreigners. Some authorities go further and include as citizens children born within the jurisdiction without reference to the citizenship of their [p168] parents. As to this class there have been doubts, but never as to the first. ***For the purposes of this case it is not necessary to solve these doubts.***” Minor v. Happersett - full text of ruling https://www.law.cornell.edu/supremecourt/text/88/162



12 posted on 04/03/2024 9:40:36 PM PDT by Republican Wildcat
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To: DennisR

I agree, if “Going through the naturalization process”...also includes birthright citizenship, as it should because this is also citizenship bestowed by state law, not as a consequence of natural law.


13 posted on 04/04/2024 5:52:55 AM PDT by batazoid (Plainclothes cop at Capital during Jan 6 riot...)
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To: coalminersson

Concur..this is the correct definition


14 posted on 04/04/2024 5:53:59 AM PDT by bunkerhill7 (Don't shoot until you see the whites of their lies)
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To: Republican Wildcat

Here’s the problem with the conclusion of all these cases using 14A §1 birthright citizenship: They are all antithetical to the very point of requiring a citizen to be born of two citizen parents so as to ensure as much as possible the Commander in Chief’s sole loyalty is to the United States.


15 posted on 04/04/2024 6:14:19 AM PDT by batazoid (Plainclothes cop at Capital during Jan 6 riot...)
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To: Republican Wildcat

Chester Alan Arthur is generally believed to have been born in northern Vermont, but opponents at the time spread the rumor that he had actually been born in Canada.


16 posted on 04/04/2024 6:35:06 AM PDT by Verginius Rufus
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To: CDR Kerchner

NOT ELIGIBLE. Nimarata Randhawa (the fraud Nikki Haley’s maiden name) is NOT eligible to be president. She is an anchor baby born to non-citizens.

https://www.thegatewaypundit.com/2024/01/no-constitution-does-not-allow-children-born-non/


17 posted on 04/04/2024 6:45:21 AM PDT by Chauncey Gardiner (Vivamus stultus ignarus mori )
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To: CDR Kerchner
I think the article linked in this post tells us why all of this is wishful thinking.
18 posted on 04/04/2024 6:53:49 AM PDT by Mr. Jeeves ([CTRL]-[GALT]-[DELETE])
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To: GenXPolymath
until either the Supreme Court over turns USA v Wong

Point of order. Wong Kim Ark was not declared by the court to be a "natural born citizen." They declared him to be a "citizen", by operation of the 14th amendment.

People keep claiming that Wong Kim Ark involves "natural born citizen", but the truth is that it did not decide that issue. People merely interpret it as though it had.

And yes, all the courts will parrot crap they have been told without bothering to do any thinking on their own.

Our court system is the dumbest bunch of bootlickers in America.

19 posted on 04/04/2024 8:51:07 AM PDT by DiogenesLamp ("of parents owing allegiance to no other sovereignty.")
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To: DennisR
If you need to go through the naturalization process in order to become a citizen, you are not “natural born.” Otherwise, you are.

That's not accurate. Any person born to an American female on foreign soil is a "citizen" who did not have to go through the naturalization process because congress made their naturalization automatic. (Rogers vs Bellei comes to mind.)

The 14th amendment is exactly the same. It naturalizes large classes of people without resorting to any process beyond being born on US land.

But these sorts of automatic naturalizations are very different from "natural born citizens."

A "natural born citizen" does not require any sort of positive law to be a citizen. They are a citizen by the operation of natural law, i.e. "nature."

20 posted on 04/04/2024 8:55:20 AM PDT by DiogenesLamp ("of parents owing allegiance to no other sovereignty.")
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