The Supreme Court defined natural-born citizen as all persons born in the country to parents who were its citizens. Black’s Law Dictionary isn’t controlling here.
Which cases are you referring to? Vivian Daniel’s concurrence in Dred Scott? Fuller’s dissent in Wong Kim Ark? Neither is controlling law and both are only sources of dicta. They, like Black’s have only persuasive authority (if any). To the best of my knowledge there are no cases directly on point and those two only tangentially address the issue and have no force of law. Black’s is at least based on common law definitions which have been adopted across courts in Anglo-American legal history for defining those terms. I’m not saying SCOTUS won’t at some point possibly say that the clause does require both birth in the US and US citizen parents but the current law is open to interpretation at best. You can’t definitively say one way or the other what the term “natural born citizen” means by merely referring to currently existing SCOTUS case law.
Also, the text in Minor v. Happersett that states “The Constitution does not, in words, say who shall be natural-born citizens. Resort must be had elsewhere to ascertain that. At common-law, with the nomenclature of which the framers of the Constitution were familiar, it was never doubted that all children born in a country of parents who were its citizens became themselves, upon their birth, citizens also. 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. 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”
is also dictum and as such has no real weight behind it.
Plus all that quoted dictum in Minor says is that it is clear that at least someone who was born in the US and has 2 citizen parents is a natural born citizen- something I don’t think anyone is arguing against. It’s where one of those elements is missing that is at issue. And all the court said about it (if you even assume what they said has ANY weight)is “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.” Of course there have been doubts- otherwise the arguments over this issue would not continue. It doesn’t say conclusively, however, one way or the other that they are not natural born. The dicta merely says those who have both are without a doubt natural born.