…the  only time the US Supreme Court ever did define the class of persons who  were POTUS eligible under Article 2 Section 1 was in Minor v.  Happersett, 88 U.S. 162 (1874), wherein it was held:
“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.” Minor v. Happersett, 88 U.S. 162, 168.
 
There’s  a quote for you. It really exists. And it tells you exactly who are  natural-born citizens; those born in the country of parents who are  citizens. The words are plain-spoken and self-evident. There are two  classes of persons discussed in the above quotation. Those born in the  country of citizen parents were labeled by the Court as “natives or  natural-born citizens”, but these were also further identified as being  “distinguished from aliens or foreigners”. The distinction is crucial.
On  one side are those who have no citizenship other than that of the  United States… as distinguished from those on the polar opposite side  who have absolutely no claim to citizenship in the United States; “These  were natives, or natural-born citizens, as distinguished from aliens or  foreigners.” Those who fall in between these two extremes make up a  third class of persons whose citizenship status, the Court noted, was  subject to doubt:
“Some authorities go further and include as  citizens children born within the jurisdiction without reference to the  citizenship of the parents. As to this class there have been doubts, but  never as to the first.” Id. (Emphasis added.)
 
Had this third  class been contemplated as having any claim to being natural-born  citizens, the distinction employed by the court would not make sense.  The distinction was employed to more specifically identify the class of  persons who were natural-born citizens under Article 2, Section 1,  Clause 5. The two classes discussed are in direct polar opposition to  each other. Had this distinction not been employed, it might be argued  that those born in the country of one citizen parent were also  natural-born. But the distinction leads to the necessary conclusion that  the Court in Minor was identifying a two-citizen parent rule.
For  example, a person born in the US to a British father and U.S. citizen  mother would, at the time of the adoption of the Constitution (and at  the time Minor v. Happersett was decided), be considered as a  natural-born subject of the U.K. Whether this child would be, at his  birth, a citizen under the 14th amendment, was left undecided by the  Court in Minor. But let’s assume that the child was a U.S. citizen.  Where does that child fit into the distinction offered by the Court in  Minor? The child is not on either polar extreme, since the child was not  exclusively a US citizen at birth, nor was the child exclusively a  British subject at birth.  He does not fit into the distinction.
By  choosing two extremes – those who, at their birth, are nothing but U.S.  citizens – “as distinguished from aliens or foreigners” – those who, at  their birth, are in no way U.S. citizens – the Supreme Court in Minor  provided the necessary criteria to properly discern their holding.
Nothing  has been left open as to the Minor Court’s definition of a natural-born  citizen. This is further made clear by the Court’s other – somewhat  overlooked – federal citizenship holding:
“The very idea of a  political community, such as a nation is, implies an association of  persons for the promotion of their general welfare. Each one of the  persons associated becomes a member of the nation formed by the  association…
"For convenience it has been found necessary to give a  name to this membership. The object is to designate by a title the  person and the relation he bears to the nation. For this purpose the  words ‘subject,’ ‘inhabitant,’ and ‘citizen’ have been used, and the  choice between them is sometimes made to depend upon the form of the  government. Citizen is now more commonly employed, however, and as it  has been considered better suited to the description of one living under  a republican government, it was adopted by nearly all of the States  upon their separation from Great Britain, and was afterwards adopted in  the Articles of Confederation and in the Constitution of the United  States. When used in this sense it is understood as conveying the idea  of membership of a nation, and nothing more.”
Minor v. Happersett, 88 U.S. 162, 165-166 (1874). (Emphasis added.)
 
Therefore,  when the Court uses the words, “citizen” or “citizenship”, no other  meaning may be imputed other than, “membership of a nation”. But Jack  Maskell believes he can overrule this specific holding of the Supreme  Court by inserting the words “natural-born” where they do not appear.  ”Natural-born” only pertains to a requirement for the municipal office  of President. Those who are natural-born meet that qualification, but  all who are citizens, natural-born, naturalized abroad, naturalized  here, at birth or later in life, are members of our nation. The word  citizen – according to the Supreme Court in Minor – refers to “membership of a nation, and nothing more“. It’s the “nothing more” that  Maskell fails to recognize.
In Maskell’s CRS memo, he alleges  that the following statement from Minor left open the issue of whether  persons born of aliens could be considered as natural-born citizens:
“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.”   Id. at 167-168. (Emphasis added.)
 
Reading this passage in light  of the definition of “citizen” from pg. 166 of Minor’s unanimous  opinion, it becomes evident that what is referred to here is membership  in our nation, and nothing more. Any attempt to insert the words –  “natural-born” – into this passage to imply that the court left open the  issue of whether those whose citizenship was in doubt might also be  eligible to be President would be in direct opposition to the Court’s  very holding of the case. This expression of doubt must be limited to  the political status of the person, not to their eligibility to hold a  municipal office. Political status is a legal term of art which means,  “membership in a nation, and nothing more”. Presidential eligibility  refers to municipal status. The holding not only determined Virginia  Minor’s citizenship, it directly defined “citizen”, and that definition  remains the law of the land today.
First, on pgs. 165-166, the  Court defined the meaning of the word “citizen”. Then, on pgs. 167-168,  the [C]ourt defined the class of “natural-born citizens”. The Court left  open the issue of who were “citizens” under the 14th Amendment, which  the Court wisely avoided by exercising judicial constraint. Instead, the  Court construed Article 2 Section 1, Clause 5, the natural-born citizen  clause. In doing so, they defined and closed that class to persons born  in the country to parents who are citizens.
The Minor Court’s  unanimous opinion and definition of natural-born citizen have never been  overruled or even questioned. In fact, the very passage defining the  natural-born citizen class was re-stated in Justice Gray’s opinion from  Wong Kim Ark. Had he intended to take issue with that definition, or to  expand it, then his opinion would certainly contain something like this:
Wong Kim Ark is a natural-born citizen eligible to be President.
 
But  no such statement exists. It’s also important to remember at all times  that the Court in Minor specifically avoided construction of the 14th  Amendment, thereby defining the class of natural-born citizens and  identifying Virginia Minor as a member of that class. Virginia Minor  directly petitioned the Court to determine that she was a citizen under  the 14th Amendment. But the Minor Court declined to construe the 14th  Amendment, and thereafter set about defining the class of persons who  were natural-born citizens of the United States in determining that she  was a citizen.
In 1996, the US Supreme Court’s majority opinion  by Justice Breyer in Ogilvie Et Al., Minors v. United States, 519 U.S.  79 (1996), openjurist.org/519/us/79/ogilvie-v-united-states  stated that when the Court discusses a certain reason as an independent  ground in support of their decision, then that reason is not simply  dictum:
“Although we gave other reasons for our holding in  Schleier as well, we explicitly labeled this reason an ‘independent’  ground in support of our decision, id., at 334. We cannot accept  petitioners’ claim that it was simply a dictum.”
 
The Minor  Court’s construction of Article 2, Section 1, Clause 5, of the United  States Constitution was the independent ground by which the Court  avoided construing the 14th Amendment’s citizenship clause.
Therefore,  such construction is precedent, not dicta, despite POTUS eligibility  not being an issue. The Court determined it was necessary to define the  class of natural-born citizens, and the definition is current legal  precedent.
Had the Court in Wong Kim Ark identified him as a  natural-born citizen, there would have been no need to construe the 14th  Amendment, just as it wasn’t necessary to construe it to determine  Virginia Minor’s citizenship. But Wong Kim Ark was not natural-born, and  therefore the Court was required to construe the 14th Amendment to  determine his citizenship status.
Again, had Justice Gray’s  opinion intended to state that Ark was natural-born, there would be a  sentence in Gray’s opinion stating, Wong Kim Ark is a natural-born  citizen. But there isn’t. No amount of tongue twisting can insert those  words where they do not exist and do not belong.
The same is true  for the Supreme Court’s unanimous opinion in Minor v. Happersett. Had  the court intended to say – Some authorities go further and include as  natural-born citizens children born within the jurisdiction without  reference to the citizenship of the parents – then that is exactly what  the US Supreme Court would have said.  But they didn’t.
And the  same can be said for the framers of the 14th Amendment. Had they  intended to include the words “natural-born citizen” in the [14th] Amendment,  then that is exactly what they would have done. But they didn’t. Any  attempt to read those words into the 14th Amendment would render Article  2, Section 1, Clause 5, to be superfluous. And that goes directly  against our entire body of national jurisprudence on the issue of  statutory construction.