The fact remains, Minor v. Happersett has been presented to the Supreme Court of the United States in several Petitions for Writs of Certiorari as cited precedent in Obama eligibility appeals, to no avail.
Twenty-four years after Minor was decided, the Supreme Court ruled that:
[An alien parent’s] allegiance to the United States is direct and immediate, and, although but local and temporary, continuing only so long as he remains within our territory, is yet, in the words of Lord Coke in Calvins Case, 7 Coke, 6a, strong enough to make a natural subject, for, if he hath issue here, that issue is a natural-born subject”
In Minor v. Happersett, Chief Justice Waite, when construing, in behalf of the court, the very provision of the Fourteenth Amendment now in question, said: "The Constitution does not, in words, say who shall be natural-born citizens.
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the view that all children born in the United States of citizens or subjects of foreign States were excluded from the operation of the first sentence of the Fourteenth Amendment is manifest from a unanimous judgment of the Court, delivered but two years later, while all those judges but Chief Justice Chase were still on the bench, in which Chief Justice Waite said: "Allegiance and protection are, in this connection" (that is, in relation to citizenship), reciprocal obligations. The one is a compensation for the other: allegiance for protection, and protection for allegiance. . . . At common law, with the nomenclature of which the framers of the Constitution were familiar, it was never doubted that all children, born in a country of [p680] parents who were its citizens, became themselves, upon their birth, citizens also. These were natives, or natural-born citizens, as distinguished from aliens or foreigners.
This is the last point in the Wong Kim Ark decision which uses the specific term "natural-born citizen." It could not be used in any application to Wong Kim Ark because his parents were not citizens.