I'm glad you mentioned Lynch v. Clarke (A state case, not a Federal case.) The logic of the court was that since New York did not have a statute defining citizenship, the court had decided to use the English Common law definition. The New York Legislature immediately rebuked the court by passing a citizenship definition statute that effectively overturned the ruling in Lynch v. Clarke for any subsequent cases.
As I keep telling you, It is the DUTY of the PEOPLE to REBUKE the COURT when the court is wrong.
Great find...