It was merely dictum in Minor. The point in Minor was not to define the term natural born citizen for purposes of the natural born citizen requirement but rather to determine whether the 14th Amendment mandated that women have the right to vote as US citizens. Bingham drafted that Amendment about 80 years after the term was used for the presidency requirement which means it may or may not actually view the term “natural born citizen” similarly as the founders. Further, the term “natural born citizen” nowhere appears in the 14th Amendment. The Amendment merely states “[a]ll persons born or naturalized in the United States”; that is it protects the rights of citizens. The natural born issue was not important to the holding in Minor and thus merely dicta with no real weight beyond possibly being persuasive.
It was also merely dictum in Wong Kim Ark.
No it wasn't. This specifically addressed Minor's citizenship AND rejected her 14th amendment citizenship claim:
The question is presented in this case, whether, since the adoption of the fourteenth amendment, a woman, who is a citizen of the United States and of the State of Missouri, is a voter in that State, notwithstanding the provision of the constitution and laws of the State, which confine the right of suffrage to men alone.
Her citizenship is a key part of the question ... and a key part of the argument as framed by the court.
The argument is, that as a woman, born or naturalized in the United States and subject to the jurisdiction thereof, is a citizen of the United States and of the State in which she resides, she has the right of suffrage as one of the privileges and immunities of her citizenship, which the State cannot by its laws or constitution abridge.
The citizenship argument is framed as being due to the citizen clause of the 14th admendment. The SCOTUS unanimously rejected this argument.
There is no doubt that women may be citizens. They are persons, and by the fourteenth amendment "all persons born or naturalized in the United States and subject to the jurisdiction thereof" are expressly declared to be "citizens of the United States and of the State wherein they reside." But, in our opinion, it did not need this amendment to give them that position.
This isn't just referring to Minor's citizenship, but women as a class. The court justifies its opinion (note it strictly says this is the court's OPINION, so it's not simply dicta) by proceeding to explain how people became citizens prior to the 14th amendment. After defining NBC, the court explains how native women and children are distinguished from alien women and children through the original naturalization laws. It concludes the citizenship argument (which constitutes roughly half the decision, pun intended) by again rejecting the 14th amendment for V. Minor and women in general who meet its definition of NBC.
In this respect men have never had an advantage over women. The same laws precisely apply to both. 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.
As for Wong Kim Ark, again, it's not simply dictum. Gray expressed the impact of the decision as showing that the Supreme Court, through post-14th amendment decisions, was "committed to the view that all children born in the United States of citizens or subjects of foreign States were excluded from the operation of the first sentence of the Fourteenth Amendment ..." The "committment," Gray said, is "manifest from a unanimous judgment of the Court ..." The Minor decision was that unanimous judgment. Here is how Gray officially affirms Minor AFTER citing its NBC definition:
Minor v. Happersett (1874), 21 Wall. 162, 166-168. The decision in that case was that a woman born of citizen parents within the United States was a citizen of the United States, although not entitled to vote, the right to the elective franchise not being essential to citizenship.
When Gray says the Court has expressed a commitment through a unanimous decision that DEFINES NBC, then gives that definition and affirms a FINDING based on birth in the country to citizen parents, it is NOT "merely dictum."
There is more proof from WKA that Minor rejected the 14th amendment for NBCs:
In Minor v. Happersett, Chief Justice Waite, when construing, in behalf of the court, the very provision of the Fourteenth Amendment now in question, said: "The Constitution does not, in words, say who shall be natural-born citizens. Resort must be had elsewhere to ascertain that."
I'll simplify this: When Minor construed the Constitution, specifically the citizen clause of the 14th amendment, the court said it did NOT say who shall be natural-born citizens. This shows specifically how NBCs were EXCLUDED from the birth clause. The Minor decision relied on an NBC definition from OUTSIDE of the Constitution and OUTSIDE of statutory law. Its definition is a verbatim match of law of nations. Again, it's not dictum because it goes to the heart of the question, the argument and the finding of the court in BOTH of these landmark cases.
Wong Kim Ark does not use the term of art "natural born citizen". Even though Wong Kim Ark was wrongly decided, it decided only that Wong Kim Ark was just a "citizen."
They did not declare him eligible for the Presidency, merely to the equal status of a naturalized citizen.