That would be incorrect. In ‘ex parte Lockwood’ the court said - “In Minor v. Happersett, 21 Wall. 162, this court held that the word ‘citizen’ is often used to convey the idea of membership in a nation, and, in that sense, women, if 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 of the constitution as since;”
It’s clear that the SCOTUS considered Minor v. Happersett as establishing precedent on Federal Citizenship - ie. it was a Holding AND NOT Dicta.
Courts cite DICTA all the time. Dicta is not binding.
At least, that is what birthers say when anyone points out the WKA ruling...