Larry Tribe is incorrect on this point.
Minor v. Happersett states there is no doubt that an individual born under US jurisdiction to citizen parents is a natural born citizen. But, it also says that some authorities go further and extend that status to those born under other circumstances, about which there are doubts. It goes further to state that such doubts can be resolved. Being born out of the jurisdiction of the US leaves open the possibility of birthright citizenship from another nation that determines citizenship in that manner. Being born to a noncitizen parent leaves open the possibility of citizenship by descent from another nation that determines citizenship in that manner. Every individual circumstance is different, with different legal ramifications, for those who were not born to citizen parents within US jurisdiction. It’s clear to me at least that the concern was legal jurisdiction over a President, and only US jurisdiction was acceptable.