This is exactly what the WKA court rulled Mr. Ark to be. A "citizen." Something the recent state of Indiana court found to be a fact.
In both cases, neither was found to be a "natural born Citizen."
In fact, the article in which this information comes from: "The New York Legal Observer" Edited by Samuel Owen, we see mention of Vattel and his authority on citizenship and that "the rule of Vattel, is controlled by the intention with which the father takes up his abode in the foreign country."
Barry's father, Sr. was here on a student visa. A temporary visitor. He had zero intention of making the U.S. his perminant abode (or domocile). He had every intention of going back to Kenya with his American education in an attempt to be a power player in Kenyan economics.