Conservative justices have tended to be more likely than liberal or moderate justices to rely on the legal principle of “stare decisis” (let the decision stand, the policy of courts to abide by or adhere to principles established by decisions in earlier cases.), reliance on historical judicial precedent.
The 1898 SCOTUS ruling in U.S. v Wong Kim Ark has never been overturned.
The majority ruled in Wong:
[An alien parent’s] “allegiance to the United States is direct and immediate, and, although but local and temporary, continuing only so long as he remains within our territory, is yet, in the words of Lord Coke in Calvin’s Case, ’strong enough to make a natural subject, for, if he hath issue here, that issue is a natural-born subject’
‘Subject’ and ‘citizen’ are, in a degree, convertible terms as applied to natives; and though the term ‘citizen’ seems to be appropriate to republican freemen, yet we are, equally with the inhabitants of all other countries, ’subjects,’ for we are equally bound by allegiance and subjection to the government and law of the land.’
…every child born in England of alien parents was a natural-born subject, unless the child of an ambassador or other diplomatic agent of a foreign state, or of an alien enemy in hostile occupation of the place where the child was born.
The same rule was in force in all the English colonies upon this continent down to the time of the Declaration of Independence, and in the United States afterwards, and continued to prevail under the constitution as originally established.”
Liberal and moderate judges who believe that the Constitution is “a living document” are more likely to ignore precedent and try to overturn what has already been decided.