But does “natural born” mean “native born” or “naturalized” - meaning the Justice himself wrote this very sloppily.....not something to hang a 200 year hat on.....
It means neither.
Natural Born is born of two citizen parents....where ever. If my folks had been visiting a foreign country or temporarily residing there because of business or some other consideration....and indeed had planned on (and in fact did) return to this country after my foreign birth.....I would be called a "Natural Born" citizen. I derived that status by blood and by the fact my parents were citizens.
If I had been born in this country of non citizen parents (or only one citizen parent) I would be called a "Native Born" citizen. Indeed a citizen....but ineligible to become the "Commander in Chief" because of potential divided loyalties to the home country of my one (or both) non citizen parents.
Naturalized Citizen is a citizen by statute....and not birth.
Justice Douglas referred to all three in his decision.