The question presented by the record is 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 domicil 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 by virtue of the first clause of the Fourteenth Amendment of the Constitution
The Court very correctly continues by never once uttering the phrase "natural born citizen" anywhere in the opinion.
The lower court used incorrect language. The Supreme Court corrected the error by restating the question before the court to be (beginning of the opinion):
The question presented by the record is 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 domicil 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 by virtue of the first clause of the Fourteenth Amendment of the Constitution
The Court very correctly continues by never once uttering the phrase “natural born citizen” anywhere in the opinion.
Wong Kim Ark has been cited more than 1000 times in subsequent court decisions and as recently as 2009 concerning the natural born citizen status of Barack Obama.
The Indiana Court of Appeals ruled that it was constitutional for Obama to receive Indiana’s Electoral College votes as a natural born citizen and they based their decision, in part, on the precedent established in Wong Kim Ark.
At the Supreme Court, Justice Scalia has written in several concurrences that there are only two forms of US citizenship for all Americans: born citizenship and naturalized citizenship. There is no difference in the law between a Citizen of the United States at birth and a “natural born citizen.”