"It thus clearly appears that, by the law of England for the last three centuries, beginning before the settlement of this country and continuing to the present day, aliens, while residing in the dominions possessed by the Crown of England, were within the allegiance, the obedience, the faith or loyalty, the protection, the power, the jurisdiction of the English Sovereign, and therefore every child born in England of alien parents was a natural-born subject unless the child of an ambassador or other diplomatic agent of a foreign State or of an alien enemy in hostile occupation of the place where the child was born.
III. The same rule was in force in all the English Colonies upon this continent down to the time of the Declaration of Independence, and in the United States afterwards, and continued to prevail under the Constitution as originally established."
Was U.S. vs. Wong Kim Ark Wrongly Decided? by P.A. Madison on December 10, 2006
It doesn't argue the question of "natural born," but argues that ALL "citizenship" granted under the rubric of Wong Kim Ark is incorrect, and inconsistent with the rule of Elk.
Pretty easy read.