And the Juvenile death penalty was upheld in Stanford v. Kentucky in 1989. Yesterday it was overturned in Roper v. Simmons. Why should they uphold a 1880 decision on immigration in light of increased abuse in the time since? Times change. That was the whole point of Roper v. Simmons.
And besides Native Americans were not included as citizens in 1880 despite being native born. It took an act of Congress (note that it was not a judicial decision, but an act of Congress) to give them citizenship in 1924.
However, this entire discussion is academic, as can be seen from this quote from the article:
Advocates for and against the measure, which has surfaced in various forms before, said the bill is unlikely to go far in Congress. The bill is now in the House Judiciary Committee. No hearing on the bill has been scheduled.
"This is really a perennial bill; it comes up each spring," said Angela Kelley, deputy director of the National Immigration Forum, an immigrant-rights advocacy group based in Washington, D.C. "It gets a handful of co-sponsors and never sees the light of day."
I tend to believe Ms. Kelley is right about the bill not seeing the light of day, especially given the fact it's a perennial bill.