Actually no, not in the way you would have us believe. In Minor v. Happersett the question before the court was not whether Virginia Minor was a natural born citizen or an naturalized citizen or native born or whatever other category you choose to create. The question was whether when the 14th Amendment granted privileges and immunities to citizens - natural born or otherwise - it included the right to vote. The court did not rule on what kind of citizenship Minor had. It ruled that citizenship of any kind did not automatically include the right to vote, and denied Minor that ability. The definition of what constituted a natural born citizen was not a question before the court, so any comments on natural born citizenship were obiter dictum.
Sorry, but the syllabus of the decision and the decision itself acknowledged that her citizenship was PART of a key part of the decision.
1. The word "citizen" is often used to convey the idea of membership in a nation.
2. In that sense, women, of born of citizen parents within the jurisdiction of the United States, have always been considered citizens of the United States, as much so before the adoption of the fourteenth amendment to the Constitution as since.
Do you see this?? Women born of citizen parents have always been considered citizens as much before the 14th amendment as SINCE. This means the court is recognizing natural born citizenship without regard to the 14th amendment. Here's more, but from the opinion of the court this time:
The argument is, that as a woman, born or naturalized in the United States and subject to the jurisdiction thereof, is a citizen of the United States and of the State in which she resides, she has the right of suffrage ...
The part underlined is from the 14th amendment. In case there's any doubt, the court goes on to say this amendment was NOT needed.
There is no doubt that women may be citizens. They are persons, and by the fourteenth amendment "all persons born or naturalized in the United States and subject to the jurisdiction thereof" are expressly declared to be "citizens of the United States and of the State wherein they reside." But, in our opinion, it did not need this amendment to give them that position.
The question before the court was whether V. Minor was a 14th amendment citizen who therefore had a presumed right of suffrage as one the immunities and privileges of citizens. The court rejected her 14th amendment claim specifically because she fell under their definition of natural born citizen (as is shown from the syllabus).
The fourteenth amendment did not affect the citizenship of women any more than it did of men. In this particular, therefore, the rights of Mrs. Minor do not depend upon the amendment. She has always been a citizen from her birth, and entitled to all the privileges and immunities of citizenship. The amendment prohibited the State, of which she is a citizen, from abridging any of her privileges and immunities as a citizen of the United States; but it did not confer citizenship on her.