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In the late 1800s (1880s and 1890s) some US Secretaries of State began to increasingly deny citizenship to people who had been born here to alien parents and then left the country, mostly by being carried abroad as children.

So... NOT everyone born in the U.S. was a U.S. citizen.

And the reasons the Secretaries of State explicity gave for that was that such persons weren't U.S. citizens because they were born "'subject to a foreign power,' therefore not "subject to the jurisdiction of the United States"

FACTS are a bi*ch, huh Jeff...

So... NOT everyone born in the U.S. was a U.S. citizen.

Not everybody born in the US was a US citizen, but some or most of those particular people, legally speaking, actually were. Even if the State Department denied the fact.

This is according to the ancient rule of citizenship which the Court (accurately) told us had always applied.

People who were NOT US citizens included:

the children born here of foreign ambassadors
children born here of foreign royalty
children born here into Indian tribes
children born here who as slaves
children born here to invading armies

There's an argument to be made for children of illegal aliens and even of temporary visitors as well.

I think there's actually at least SOME argument to be made against people here on temporary visas. I think the argument is a weak one and would likely not stand. But I think there's enough wiggle-room in Wong Kim Ark that the argument could at least be MADE.

There is no longer any such wiggle room when it comes to the children of aliens who actually reside here.

And in Obama's case, he had a citizen mother. So there's no argument there. That's plenty. Like it or not, he's a natural born citizen.