Then how, pray tell, did it ever get to the Supreme Court? Obviously he had "standing." :)
At no time was Bellei an NBC, since he was not born in the USA, nor was he born abroad of two citizen parents - the definition of NBC recognized in WKA, based on both the NBC clause and the 14th Amendment. Thus his case fell under the laws of Congress, rather than a Constitutional right.
"The central fact in our weighing of the plaintiff's claim to continuing and therefore current United States citizenship is that he was born abroad. He was not born in the United States. He was not naturalized in the United States. And he has not been subject to the jurisdiction of the United States. All this being so, it seems indisputable that the first sentence of the Fourteenth Amendment has no application to plaintiff Bellei. He simply is not a "Fourteenth Amendment first sentence" citizen."
"Held: Congress has the power to impose the condition subsequent of residence in this country on appellee, who does not come within the Fourteenth Amendment's definition of citizens as those "born or naturalized in the United States," and its imposition is not unreasonable, arbitrary, or unlawful. Afroyim v. Rusk, supra, and Schneider v. Rusk, supra, distinguished. Pp. 401 U. S. 820-836."
http://supreme.justia.com/cases/federal/us/401/815/case.html
The only similarity between him & Obama is that Obama was eligible for UK citizenship, but refused to claim it - which, when it transferred to Kenya, he would have needed to do by his 18th birthday.