I think not.
"The foregoing considerations and authorities irresistibly lead us to these conclusions: The fourteenth amendment affirms the ancient and fundamental rule of citizenship by birth within the territory, in the allegiance and under the protection of the country, including all children here born of resident aliens, with the exceptions or qualifications (as old as the rule itself) of children of foreign sovereigns or their ministers, or born on foreign public ships, or of enemies within and during a hostile occupation of part of our territory, and with the single additional exception of children of members of the Indian tribes owing direct allegiance to their several tribes. The amendment, in clear words and in manifest intent, includes the children born within the territory of the United States of all other persons, of whatever race or color, domiciled within the United States. Every citizen or subject of another country, while domiciled here, is within the allegiance and the protection, and consequently subject to the jurisdiction, of the United States."
Donofrio's claim is that Obama cannot be a natural born citizen because his father was not a U.S. citizen. In the Ark decision, the Court makes it clear that the citizenship status of the parents is irrelevant, that it is the 14th Amendment and the provisions contained in it that is the key. To claim otherwise is idiotic, as Justice Gray wrote. "To hold that the fourteenth amn dment of the constitution excludes from citizenship the children born in the United States of citizens or subjects of other countries, would be to deny citizenship to thousands of persons of English, Scotch, Irish, German, or other European parentage, who have always been considered and treated as citizens of the United States." Stop and think of that. If Donofrio is right then Giuliani was most likely ineligible to run for president. He's second generation Italian immigrant. Unless it can be shown that his grandparents on both sides have become naturalized citizens before Giuliani's parents were born then one or both were not U.S. citizens. And unless you can show where Giuliani's parents went through the naturalization process before Rudy was born, then according to Donofrio Rudy is ineligible. So it is with the decendent of almost any immigrant.
I think what you are missing is the distinction between a “citizen” and a “natural born citizen”. Leo is not arguing that Obama, if born in Hawaii, is not a citizen. Rather, he is arguing that because he was also a citizen of Great Britain, that he is not a “natural born” citizen, and thus cannot serve as President.