You miss my point. I’m not concerned with the reason Steinkauler was an NBC. I’m only saying that Ulysses S. Grant’s Attorney General apparently saw no difference between “native-born” and “natural born” when it came to presidential eligibility. This contradicts the longstanding effort by many on these threads to claim otherwise.
In modern usage, all natural born are native born however, not all native born are natural born.
What is the difference between a ‘native citizen’ and ‘natural born citizen’?
As the President is required to be a native citizen of the United States . Natives are all persons born within the jurisdiction and allegiance of the United States.
James Kent, COMMENTARIES ON AMERICAN LAW (1826)
That provision in the constitution which requires that the president shall be a native-born citizen (unless he were a citizen of the United States when the constitution was adopted) is a happy means of security against foreign influence, A very respectable political writer makes the following pertinent remarks upon this subject. Prior to the adoption of the constitution, the people inhabiting the different states might be divided into two classes: natural born citizens, or those born within the state, and aliens, or such as were born out of it.
St. George Tucker, BLACKSTONES COMMENTARIES (1803)
The 5th section of the 2d article provides, that no person except a natural born citizen, shall become president. A plain acknowledgment, that a man may become a citizen by birth, and that he may be born such.
Amy v. Smith, 11 Ky. 326, 340 (Ky. 1822)
Before our Revolution, all free persons born within the dominions of the King of Great Britain, whatever their color or complexion, were native-born British subjects; those born out of his allegiance were aliens. . . . Upon the Revolution, no other change took place in the law of North Carolina than was consequent upon the transition from a colony dependent on an European King to a free and sovereign State; . The term citizen, as understood in our law, is precisely analogous to the term subject in the common law, and the change of phrase has entirely resulted from the change of government.
State v. Manuel, 4 Dev. & Bat. 20, 24-26 (1838)
Every person, then, born in the country, and that shall have attained the age of thirty-five years, and been fourteen years a resident within the United States, is eligible to the office of president.
Lysander Spooner, The Unconstitutionality of Slavery, pg. 119 (1845)
But the Secretary of State, according to the allegation of the bill of complaint, had refused to issue a passport to Miss Elg “solely on the ground that she had lost her native born American citizenship.” The court below, properly recognizing the existence of an actual controversy with the defendants, declared Miss Elg “to be a natural born citizen of the United States,” and we think that the decree should include the Secretary of State as well as the other defendants.
PERKINS V. ELG, 307 U. S. 325 (1939)