[BuckeyeTexan]

I think you're missing the point. Leo doesn't attempt to support his claim by pointing to the word "naturalization" in the title of a law. He's asserting that a law which grants citizenship is, in and of itself, an act of naturalizing a group of citizens. (i.e. A natural-born citizen does not require a law to clarify his status.)

The Minor Court also noted that the “substance” of the 1790 act, which granted US citizenship at birth via naturalization, had remained as law up until 1875 when the Minor case was decided. So, clearly, while citizens may either be born or naturalized, some born citizens are simultaneously naturalized at birth.

[Kleon]

He's asserting that a law which grants citizenship is, in and of itself, an act of naturalizing a group of citizens. (i.e. A natural-born citizen does not require a law to clarify his status.)

In which case, even the precedent he claims comes from the Minor case would be an act of naturalization. He also says this precedent could be reversed by "a Constitutional amendment which specifically defines 'natural-born Citizen' more inclusively than Minor did," but that too would be an act of naturalization if we accept the above argument.