The ‘doubt’ that did not need to be resolved was the doubt of 14th Amendment-based anchor baby status (when the parents are both aliens).
That was the ‘doubt’ they are referring.
Their RULING was based on the status of Virginia Minor as a natural born Citizen - she was born in county to two US citizen parents.
She did not need for and the 14th Amendment had no bearing on her citizenship status (or voting rights).
To provide complete context of the quote posted here is the rest of that paragraph:
“... It is sufficient for everything we have now to consider that all children born of citizen parents within the jurisdiction are themselves citizens. The words “all children” are certainly as comprehensive, when used in this connection, as “all persons,” and if females are included in the last they must be in the first. That they are included in the last is not denied. In fact the whole argument of the plaintiffs proceeds upon that idea.”
Further in the ruling.
“The fourteenth amendment did not affect the citizenship of women any more than it did of men. In this particular, therefore, the rights of Mrs. Minor do not depend upon the amendment. She has always been a citizen from her birth, and entitled to all the privileges and immunities of citizenship. The amendment prohibited the State, of which she is a citizen, from abridging any of her privileges and immunities as a citizen of the United States; but it did not confer citizenship on her. That she had before its adoption.”
The court found that Ms. Minor was a member of the ‘first’ class posted. That is the natural-born citizen class.
This was no “philoophical rationale” - it was the absolute core of the ruling.
Minor v. Happersett was a women’s suffrage appeal. Virginia Minor wanted to vote and she tested to see if the 14th Amendment gave her that right.
No court decision has ever successfully applied Minor v. Happersett to presidential eligibility.
For example:
Allen v Obama, Arizona Superior Court Judge Richard E. Gordon: “Arizona courts are bound by United States Supreme Court precedent in construing the United States Constitution, and this precedent fully supports that President Obama is a natural born citizen under the Constitution and thus qualified to hold the office of President. Contrary to Plaintiff’s assertion, Minor v. Happersett, 88 U.S. 162 (1874), does not hold otherwise.”—Pima County Superior Court, Tuscon, Arizona, March 7, 2012
http://www.scribd.com/doc/84531299/AZ-2012-03-07-Allen-v-Obama-C20121317-ORDER-Dismissing-Complaint