First, a memo produced in 1968 by Charles Gordon, then the General Counsel of the United States Immigration and Naturalization Service, which says: “The Framers were well aware of the need to assure full citizenship rights to the children born to American citizens in foreign countries.” He also points out a 2011 Congressional Research Service Memo entitled the “Qualification for President and the ‘Natural Born’ Citizenship Eligibility Requirement.” The document concludes:
While at the immigration agency, Mr. Gordon argued eight cases before the Supreme Court. ‘’He was known as a liberal and someone in favor of a more open, fairer immigration policy,’’ Mr. Roberts said, but sometimes he had to argue positions with which he disagreed.