This is an important point. The Minor court did not specifically say that Virginia Minor was born of citizen parents, but it was understood by the Supreme Court more than 20 years later in Wong Kim Ark, when Justice Gray explained the holding in Minor:
Minor v. Happersett (1874), 21 Wall. 162, 166-168. The decision in that case was that a woman born of citizen parents within the United States was a citizen of the United States, although not entitled to vote, the right to the elective franchise not being essential to citizenship.
See?? Justice Waite did not specifically say Minor had citizen parents, but Justice Gray understood that she did AND he made sure to include this factor as part of the holding. Why do you think he did that??
Justice Horace Gray was appointed by Chestur Arthur.
Arthur did a lot of document shredding a la a burning trash can before he died.