You need to read an article “can the simple cite be trusted”. Since the court in Ark never stated that he was an NBC, it was improper for the lower court to state that the appellee in that case was one, based on Ark anyway.
My point is that high state courts, lower courts and the United States Supreme Court have been using the terms “natural born citizen,” “native citizen,” and “citizen-at-birth” interchangeably for centuries now.
US Supreme Court Justice Joseph Story in his concurring opinion in “Inglis v. Trustees of Sailor’s Snug Harbor,” 28 U.S. 3 Pet. 99 99 (1830): “The 5th section of the 2d article provides, “that no person except a natural born citizen,” shall become president. A plain acknowledgment, that a man may become a citizen by birth, and that he may be born such.”
The US Supreme Court have termed persons made citizens at birth by statute, "naturalized", and in the last half of the 20th Century at that. I've already given the citation.
But, with one exception, no court has ruled that anyone other than a person born in the country to two citizen parents was eligible to the office of President. Not once.
Meanwhile:
"US Supreme Court Justice Joseph Story in his concurring opinion in “Inglis v. Trustees of Sailor’s Snug Harbor,” 28 U.S. 3 Pet. 99 99 (1830): “The 5th section of the 2d article provides, “that no person except a natural born citizen,” shall become president. A plain acknowledgment, that a man may become a citizen by birth, and that he may be born such.”
So? no one is challenging that one becomes natural born by the circumstances of ones birth. Nor that one becomes a citizen by birth in the United States.
"The citizens are the members of the civil society; bound to this society by certain duties, and subject to its authority, they equally participate in its advantages. The natives or indigenes are those born in the country of parents who are citizens. Society not being able to subsist and to perpetuate itself but by the children of the citizens, those children naturally follow the condition of their fathers, and succeed to all their rights."Mr. Chief Justice Marshall, quoting an older (even then) translation of Vattel's "Law of Nations",in The Venus, 12 U.S. 8 Cranch 253 (1814)
The original French, which Marshall could probably read, was "Les Naturales ou Indigenes", which translates properly (try each word on Bablefish),as "Naturals or natives". Thus that early translation put "natives" in there twice and left out "naturals", but then again, it was by an Englishman.