Additionally, it should be reiterated that Wong Kim Ark was not ruled as a natural born citizen, and in fact, the case referred to by Justice Gray (appointed by Chester Arthur, btw), Minor, doesn’t even seem to support the position that Wong Kim Ark was a citizen at all.
Let’s not get confused by the facts.
Huh? Wong Kim Ark was granted citizenship, and Gray wrote the majority opinion. Are you saying he disagreed with his own opinion? Here's how it concludes, after a very long dissertation:
"The evident intention, and the necessary effect, of the submission of this case to the decision of the court upon the facts agreed by the parties, were to present for determination the single question, stated at the beginning of this opinion, namely, whether a child born in the United States, of parents of Chinese descent, who, at the time of his birth, are subjects of the emperor of China, but have a permanent domicile and residence in the United States, and are there carrying on business, and are not employed in any diplomatic or official capacity under the emperor of China, becomes at the time of his birth a citizen of the United States. For the reasons above stated, this court is of opinion that the question must be answered in the affirmative.
Order affirmed."
He was ruled a citizen by birth. That is a natural born citizen. The ruling didn't distinguish between the terms because no such distinction exists.