Historical practice confirms that birth on soil that is under the sovereignty of the United States, but not within a State, satisfies the Natural Born Citizen Clause. For example, Vice President Charles Curtis was born in the territory of Kansas on January 25, 1860 — one year before Kansas became a State. Because the Twelfth Amendment requires that Vice Presidents possess the same qualifications as Presidents, the service of Vice President Curtis verifies that the phrase “natural born Citizen” includes birth outside of any State but within U.S. territory.
The way that reads Tribe/Olson are arguing that jus solis was satisfied. Why even make that argument if jus solis was not relevant?
They didn’t bother to explain why that did not apply to indians and that from a man named Tribe.