Unless you are not 'subject to the jurisdiction thereof' which applies to only four or so categories of people:
I wish I had read further. Your post sums it up perfectly.
Sorry!
I agree. Does any aspect of Donofrio’s case even challenge the actual location/country of Obama’s birth? If not, then it’s even a greater longshot.
What's the status of legal aliens who plan on becoming a citizen but have not yet taken the oath?
In either case, are one or the other, or both, subject to the jurisdiction of the United States yet?