They say there is doubt about persons being born in the country, without reference to the citizen parents, being CITIZENS. It does not says there is doubt about them being “natural-born citizens.” One class of citizens has doubt, but the first class of citizens — natural born citizens — does not. Since V. Minor met the definition of NBC, there was no need to resolve doubts. BUT, the thing you need to understand is that the court does NOT suggest that the doubts about the second class of persons can be resolved. Of course, looking at Wong Kim Ark, the only way to resolve the doubt was to see if the parents satisfied the subject clause of the 14th amendment. Had they been citizens, then their child would have been a natural-born citizen. He wasn’t.
These were natives or natural-born citizens, as distinguished from aliens or foreigners. Some authorities go further and include as citizens children born within the jurisdiction without reference to the citizenship of their parents. As to this class there have been doubts, but never as to the first. For the purposes of this case, it is not necessary to solve these doubts.. Then look at WKA
it is well to bear in mind the often quoted words of Chief Justice Marshall:Minor v. Happersett was about whether the 14th amendment meant women could vote. It was not about who was a citizen by birth. Justice Gray, after citing numerous cases,(many of which speak of birth within the country to alien parents as "natural born") comes to his point:"It is a maxim not to be disregarded that general expressions in every opinion are to be taken in connection with the case in which those expressions are used. If they go beyond the case, they may be respected, but ought not to control the judgment in a subsequent suit when the very point is presented for decision.
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...later in the case he says
The Fourteenth Amendment, while it leaves the power where it was before, in Congress, to regulate naturalization, has conferred no authority upon Congress to restrict the effect of birth, declared by the Constitution to constitute a sufficient and complete right to citizenship.Got that? The Fourtheenth Amendment conferred no authority to restrict the effect of birth, or change the Constitutional mention of two categories: born and naturalized. The amendment "affirms the ancient and fundamental rule of citizenship by birth within the territory" - jus soli.