My daughter was born to Americans parents in an Army hospital in Landstuhl Germany. I as a person of German descent was by German law qualified to apply for German citizenship. From reading some of the “theories†here I suppose that that means she is not a native of the United States. To me it all boils down to this: because the Constitution does not define the word, it only rules out absolutely a person who like John Peter Altgeld, whose parents were both German-born and who came to the USA when he was 2 years old.
“A person born out of the jurisdiction of the United States can only become a citizen by being naturalized, either by treaty, as in the case of the annexation of foreign territory, or by authority of congress, exercised either by declaring certain classes of persons to be citizens, as in the enactments conferring citizenship upon foreign-born children of citizens, or by enabling foreigners individually to become citizens by proceedings in the judicial tribunals, as in the ordinary provisions of the naturalization acts.” U.S. v. Wong Kim Ark, 169 U.S. 649, 702-703