Coito ergo sum wrote:
But, my argument is not based on my preconceived notions. I've drawn a conclusion based on my review of the law. Just because my conclusions are not determinative does not mean that my conclusions are preconceived.
What law are you referring to? What law have you cited that defines "natural born citizen" as you suggest? None. There is no such law. That's the problem. The only law we have is the presidential qualification provision and a couple of Supreme Court rulings that are not on-point but are indicative of support for the Vattel theory, not indicative of support of your notion that "natural born citizen" is synonymous with "citizen" and is a function of being born under US jurisdiction regardless of the citizenship of one's parents.
If you have a law that defines "natural born citizen" I'd love for you to cite it, because that would go a long way towards resolving this dispute.
You don't have such a law, so your "review of the law" appears to be quite superficial and based only in your preconceived notions of the meaning of the phrase "natural born citizen" and not in the actual law and precedents and historical understandings upon which this dispute is legitimately based.
I'm willing to admit that I could be wrong and that the Vattel theory is bunkum in its entirety and would accept a Supreme Court decision on the meaning of "natural born citizen," and that's precisely why I'm arguing that the Court should take up the controversy and resolve it with finality after a proper review of the evidence.
You, on the other hand, don't want the case to come to court so you characterize the controversy as being "without legal merit." That leads me to believe that there is more legal merit there than you care to admit and you're afraid of the consequences of a court actually examining all the evidence and making a ruling.
Given the efforts of the Democrats in Congress back in 2008 to enact legislation to explicitly define the meaning of "natural born citizen" specifically to accommodate the fact that Obama doesn't qualify, I think that the Vattel theory has substantial and important legal merit and that the Democrats, and you, are scared to death that the controversy will come before the Court and Obama will lose. This, I suspect, is why there is so much institutionalized resistance to such a case getting before the federal courts, and I suspect another attempt at a fait accompli, which is exactly what happened when Obama was elected the first time.
Regardless of the outcome, I wish to see the ambiguity fully and finally resolved and any such future controversy forestalled by having the Supreme Court hand down a declaratory judgment (on appeal) stating the precise meaning of the term "natural born citizen" REGARDLESS of how the Court rules.
That you do not wish to see this sort of finality and certainty in such an important legal issue as the precise definition and meaning of the qualification for President is more than a little alarming, and it indicates to me that you want the ambiguity to remain, so that it can be misused in the future to allow your favorite unqualified candidate to become President in defiance of the Constitution.
YOUR notions are preconceived because you'd support anything that was anti-Obama.
Yes, I would because Obama is a Progressive Marxist and is a danger to the Republic, that much I know with certainty, but that's entirely beside the point of this controversy. I'd also feel the same way about ANY candidate for President, from either side. It just so happens that Obama is the perfect case for the Court to take up because his situation makes the controversy ripe for a decision.
Yes, but in the other instances the difference is that the congressmen did not need to be born here in the US at all. They just need to be 25 years old and have been a US citizen for 7 years.
You might have a point that there must be different meanings to different terms if a congressman had to be a citizen "born in the US," but the President had to be a "natural born citizen." Then there might be an issue that the drafters used different terms for a reason, and that they must mean something different.
So, your attempt to manufacture a distinction that "natural born citizen" is used solely as a qualification for President is a red herring.
One does not even need to have been born in the US -- or even be a US citizen to be a SCOTUS Justice, by the way.
It's far from a red herring. It's the fundamental argument. The Founders discussed the qualifications for Senators and Representatives at length during the writing of the Constitution and the Ratifiers discussed them publicly as during the ratification debates. It's idiocy to assume that they did not have as much concern for the qualifications for President. It's particularly idiocy because of the language that they actually used in that qualification, which is substantially and deliberately DIFFERENT from the qualifications for Senator or Representative, and deliberately MORE RESTRICTIVE which is clearly evidenced by the "natural born citizen" requirement.
You well know the maxims of statutory interpretation, but
here are some for the edification of others:
LAW SCHOOL FOR LEGISLATORS
Rules of Statutory Interpretation
I. Role of the Court.
1. The proper interpretation of a statute is a judicial function.
In re Complaint of Rovas Against SBC Michigan, 482 Mich 90, 99 (2008)
2. When interpreting a statute, the court attempts to ascertain and give effect to the
intent of the Legislature.
People v Gardner, 482 Mich 41, 84 (2008)
3. Court may not speculate about the probable intent of the legislature beyond the
language expressed in the statute.
Griswold Properties LLC v Lexington Ins. Co., 276 Mich App 551, 556 (2007)
4. In determining legislative intent, the courts look first into the specific language of the
statute.
People v Underwood, 278 Mich App 334, 338 (2008)
II. Clear vs. Ambiguous Language
1. Statutory language is ambiguous when it is equally susceptible to more than one
meaning, not when reasonable minds can disagree regarding its meaning.
Toll Northville LTD v Twp. of Northville, 480 Mich 6, 15 (2008)
2. Clear and unambiguous language in given its plain and ordinary meaning.
In re LE, 278 Mich App 1, 22 (2008)
3. An undefined term is given its plain and ordinary meaning.
(a) A "legal term of art" is given its peculiar legal meaning.
(b) Terms that have a unique legal meaning are given the definition found in a
lay dictionary, such as Random House Webster's College Dictionary.
Brackett v Focus Hope, Inc., 482 Mich 269, 275 (2008); MCL 8.3(a)
4. Clear and unambiguous language should be enforced as written.
In re McLeod USA Telecommunications Services, Inc. 277 Mich App 602, 609
(2008)
5. If the language is clear and unambiguous, the courts must apply it as written even
if it leads to absurd results.
Kimmelman v Heather Downs Management Ltd., 278 Mich App 569 (2008)
6. "Absurd" means utterly and obviously senseless, illogical or untrue; contrary to all
reason and common sense. It does not mean that reasonable people would think
that the Legislature acted improvidently.
McGhee v Helsel, 262 Mich App 221, 226 (2004)
7. The court may depart from a literal interpretation of unambiguous statutory
language that produces an absurd and unjust result that is inconsistent with the
purpose and policies of the statute.
People v Bewersdorf, 438 Mich 55,68 (1991)
III General Principles of Interpretation
1. Every word of a statute should be read to give it meaning, and so the court must
avoid interpretations that render words unnecessary or meaningless.
In re MCI Communications, 460 Mich 396,415 (1999)
2. Unclear statutory language will be construed so as to avoid absurd results, injustice
and prejudice to the public interest.
Hill v City of Warren, 276 Mich App 299, 305 (2007)
3. Statutes are to be read as a whole to ascertain the intent of the Legislature, and any
provisions that are apparently inconsistent are interpreted to produce a harmonious
whole, if reasonably possible.
Macomb County Prosecutor v Murphy, 464 Mich 149, 160 (2001)
Bailey v Oakwood Hosp. and Medical Center, 472 Mich 685, 693 (2005)
Nowell v Titan Ins. Co., 466 Mich 478, 482 (2002)
4. Statutes that relate to the same subject ("in pari materia") are to be read and
construed together.
In re MCI Telecommunications Complaint, 460 Mich 396, 417 (1999)
5. In interpreting a statute, the court presumes that the legislature is aware of:
(a) judicial interpretations of existing law
Ford Motor Co. v City of Woodhaven, 475 Mich 425, 439 (2006)
(b) the existence of the common law, so that (i) statutes are interpreted
consistent with their terms even if those terms conflict with the common law
and (ii) common law rules are not abolished by implication.
Spires v Bergman, 276 Mich App 432, 438 (2007)
Houghton Lake Area Tourism and Conservation Bureau v Wood,
255 Mich App 127, 149 (2003)
(c) the laws on the same subject and the effect of new enactments on existing
laws.
Wayne County v Wayne County Retirement Comm'n.,
267 Mich App 230, 244 (2005)
(d) the rules of statutory interpretation.
People v Clark, 274 Mich App 248, 252 (2007)
IV Rules for Interpreting Specific Language
1. A word or phrase is given meaning by its context or setting
Crowe v City of Detroit, 465 Mich 1, 6 (2001)
2. Where a general term follows a series of specific terms, the general term is
interpreted to include only things of the same kind, class, character or nature of
those specifically enumerated
Neal v Wilkes, 470 Mich 661 (2004)
3. Where a statute contains a specific provision and a more general related provision,
the specific one controls.
In re Haley, 476 Mich 180,199 (2006)
4. The expression of one thing in a statute means the exclusion of other similar things:
Alan v Wayne County, 388 Mich 210,253 (1970)
5. "Last antecedent rule": a modifying or restrictive word or clause contained in a
statute refers solely to the immediately preceding clause or last antecedent, unless
something in the statute requires a different interpretation.
Stanton v City of Battle Creek, 466 Mich 611, 616 (2002)
6. "And" and "or" are not interchangeable, and the court will give them their strict
meaning when that does not render the sense dubious and there is no clear
contrary legislative intent.
Niles Twp v Berrien County Bd of Commissioners, 261 Mich App 308, 318 (2004)
7. "All" in a statute leaves no room for exceptions.
People v Monaco, 474 Mich 48, 55 (2006)
8. The word "shall" refers to a mandatory duty or requirement.
Wayne County v State Treasurer, 105 Mich App 249, 252 (1981)
9. "May" is permissive and indicates discretion.
In re Forfeiture of Bail Bond, 276 Mich App 482, 492 (2007)
V External Aids to Interpretation
1. Preamble to statute is not binding authority for interpreting a statute, but it may be
considered.
Malcolm v City of East Detroit, 437 Mich 132, 143 (1991)
2. Statutory headings are not conclusive proof of legislative purpose, but they may be
considered.
Camaj v SS Kresge co., 426 Mich 281, 290 (1986)
Bankhead v McEwan, 387 Mich 610 (1972)
3. Official comments to a uniform act may be considered, although they lack the force
of law.
In re Estate of Seymour, 258 Mich App 249,254 (2003)
4. A statute is considered in light of circumstances that existed at the time of
enactment, not with reference to later developments.
Cain v Waste Management, Inc., 472 Mich 236, 258 (2005)
5. Statements of individual legislators during the debate on a bill or statements made
later are not considered since they cannot be attributed to the entire legislature.
In re Complaint of MCTA, 241 Mich App 344, 374 (2000)
6. Courts may look at legislative history, including the journals chronicling legislative
history and changes to the bill.
In re MCI Telecommunications Complaint, 460 Mich 396, 415 (1999)
Jenks v Brown, 219 Mich App 415, 419 (1996)
7. Legislative analysis is generally not a persuasive indicator of legislative intent.
Analysis are not an official record of the Legislature, they represent the views of
staff, rather than legislators and are not part of the legislative process.
People v Davis, 468 Mich 77, 79 (2003)
Morales v Michigan Parole Bd., 260 Mich App 29, 44 (2003)
8. Interpretations of statutes by the agency that administers it are given great
deference. But agency interpretations are not given deference if they are contrary
to the plain meaning of the statutory language.
Adrian School Dist v Michigan Public School Employees Retirement System,
458 Mich 326, 337 (1998)
Ludington Service Corp. v Acting Commissioner of Insurance, 444 Mich 481,
498 (1994)
The term "natural born citizen" is therefore meaningful and distinct from "citizen" or "naturalized citizen" or even "inhabitant."
We know that any person born within the territory of the United States is a "citizen."
INA: ACT 301 - NATIONALS AND CITIZENS OF THE UNITED STATES AT BIRTH
Sec. 301. [8 U.S.C. 1401] The following shall be nationals and citizens of the United States at birth:
(a) a person born in the United States, and subject to the jurisdiction thereof;
(b) a person born in the United States to a member of an Indian, Eskimo, Aleutian, or other aboriginal tribe: Provided, That the granting of citizenship under this subsection shall not in any manner impair or otherwise affect the right of such person to tribal or other property;
(c) a person born outside of the United States and its outlying possessions of parents both of whom are citizens of the United States and one of whom has had a residence in the United States or one of its outlying possessions, prior to the birth of such person;
(d) a person born outside of the United States and its outlying possessions of parents one of whom is a citizen of the United States who has been physically present in the United States or one of its outlying possessions for a continuous period of one year prior to the birth of such person, and the other of whom is a national, but not a citizen of the United States;
(e) a person born in an outlying possession of the United States of parents one of whom is a citizen of the United States who has been physically present in the United States or one of its outlying possessions for a continuous period of one year at any time prior to the birth of such person;
(f) a person of unknown parentage found in the United States while under the age of five years, until shown, prior to his attaining the age of twenty-one years, not to have been born in the United States;
(g) a person born outside the geographical limits of the United States and its outlying possessions of parents one of whom is an alien, and the other a citizen of the United States who, prior to the birth of such person, was physically present in the United States or its outlying possessions for a period or periods totaling not less than five years, at least two of which were after attaining the age of fourteen years: Provided, That any periods of honorable service in the Armed Forces of the United States, or periods of employment with the United States Government or with an international organization as that term is defined in section 1 of the International Organizations Immunities Act (59 Stat. 669; 22 U.S.C. 288) by such citizen parent, or any periods during which such citizen parent is physically present abroad as the dependent unmarried son or daughter and a member of the household of a person (A) honorably serving with the Armed Forces of the United States, or (B) employed by the United States Government or an international organization as defined in section 1 of the International Organizations Immunities Act, may be included in order to satisfy the physical-presence requirement of this paragraph. This proviso shall be applicable to persons born on or after December 24, 1952, to the same extent as if it had become effective in its present form on that date; and
(h) a person born before noon (Eastern Standard Time) May 24, 1934, outside the limits and jurisdiction of the United States of an alien father and a mother who is a citizen of the United States who, prior to the birth of such person, had resided in the United States. 302 persons born in Puerto Rico on or after April 11, 1899
And here's an item of interests regarding John McCain's eligibility:
Sec. 303. [8 U.S.C. 1403]
(a) Any person born in the Canal Zone on or after February 26, 1904, and whether before or after the effective date of this Act, whose father or mother or both at the time of the birth of such person was or is a citizen of the United States, is declared to be a citizen of the United States.
(b) Any person born in the Republic of Panama on or after February 26, 1904, and whether before or after the effective date of this Act, whose father or mother or both at the time of the birth of such person was or is a citizen of the United States employed by the Government of the United States or by the Panama Railroad Company, or its successor in title, is declared to be a citizen of the United States.
And specifically related to Obama's Hawiian birth:
Sec. 305. [8 U.S.C. 1405] A person born in Hawaii on or after August 12, 1898, and before April 30, 1900, is declared to be a citizen of the United States as of April 30, 1900. A person born in Hawaii on or after April 30, 1900, is a citizen of the United States at birth. A person who was a citizen of the Republic of Hawaii on August 12, 1898, is declared to be a citizen of the United States as of April 30, 1900.
And here's a further distinction between "nationals" and "citizens."
Sec. 308. [8 U.S.C. 1408] Unless otherwise provided in section 301 of this title, the following shall be nationals, but not citizens of the United States at birth:
(1) A person born in an outlying possession of the United States on or after the date of formal acquisition of such possession;
(2) A person born outside the United States and its outlying possessions of parents both of whom are nationals, but not citizens, of the United States, and have had a residence in the United States, or one of its outlying possessions prior to the birth of such person;
(3) A person of unknown parentage found in an outlying possession of the United States while under the age of five years, until shown, prior to his attaining the age of twenty- one years, not to have been born in such outlying possession; and
(4) A person born outside the United States and its outlying possessions of parents one of whom is an alien, and the other a national, but not a citizen, of the United States who, prior to the birth of such person, was physically present in the United States or its outlying possessions for a period or periods totaling not less than seven years in any continuous period of ten years-
(A) during which the national parent was not outside the United States or its outlying possessions for a continuous period of more than one year, and
(B) at least five years of which were after attaining the age of fourteen years.
The proviso of section 301(g) shall apply to the national parent under this paragraph in the same manner as it applies to the citizen parent under that section.
In the entire USCIS database, there is only
ONE reference made in passing to "natural born citizen," and that does not define the term at all except to distinguish "native" and "natural born" citizen women, and this is regarding repatriation, other than those citations to the Constitutional limitations on presidential qualifications that are required knowledge for naturalization applicants.
Therefore, it is reasonable to say that the USCIS does not view the term "natural born citizen" and "citizen" as synonymous, because it carefully avoids using the terms interchangeably, always referring only to "citizens by birth" or "naturalized citizens" or merely "citizens," but with one dicta exception never "natural born citizens."
This is compelling evidence that "natural born citizen" means something different from "citizen," or "citizen by birth" or "naturalized citizen."
Since we know that a "citizen" or a "citizen by birth" is the product of a) being physically born inside the US (or some territories with restrictions); b) to at least one parent who is a US citizen if born outside the US; c) to one foreign national parent if the other is a US citizen, either naturalized or by birth.
In no case are any such persons who derive their citizenship from a) being born in the US to a foreign parent(s); or, b) being born to a single US citizen parent either within or without the US, defined by the USCIS as a "natural born citizen."
Therefore, a "natural born citizen" is something else, and the only combination left that could describe this unique identifier is a child born to TWO parents, both of whom are US citizens, either by birth or naturalization.
Given the rules of statutory construction and the customary and historic administrative use of the relevant terms, there is no other rational or defensible alternative definition of "natural born citizen" to be had. To do as you do, which is to make "natural born citizen" and "citizen by birth" or "citizen" synonymous is to render the term "natural born" to be merely surplusage and therefore meaningless. But we know that this is not permissible under the canons of statutory interpretation and that the term "natural born" has special and specific meaning. As anyone can objectively see from the above, there is but one rational definition for that term, which is as meaning "born to parents both of whom are US citizens at the time of birth."
I never once said that natural born citizen doesn't mean something different from "citizen" or "naturalized citizen." It does.
A citizen can either be born a citizen, or be naturalized a citizen. If a law specifies that someone must be a "citizen" then either a natural born or natural-ized citizen will do. If the law specifies natural born citizen, then natural-ized citizen will not do.
And neither will a "citizen" or "citizen by birth." The Constitution and indeed all federal law I can find specifies "natural born citizen" in one place and one place only, but it specifies "citizen" in many millions of places throughout the laws, both federal and state. Again this shows that "natural born citizen" is a special class and sub-set of all citizens, not including citizens by birth or birth location alone, nor by naturalization, but rather a class of persons who are citizens by birth born to two parents who are both US citizens.
Seth wrote:
That phrase appears in one and only one place in the Constitution, the qualification to be President, and you know full well that every word of the Constitution must be presumed to have meaning and that none are surplusage.
Look - there is only one place where the Constitution prescribes that anyone must be born a citizen of the US to be anything.
That's in the qualification for President. There is no place where it says a person must be "born a citizen" of the US to qualify for some other office. If it did, then you would have a point. But, it doesn't, so you don't.
Correct, there are three classes of citizenship in the United States: Naturalized citizens, citizens, and natural born citizens. Naturalized citizens are granted citizenship by the government. Citizens are those persons born in the US or who are born to at least one US citizen parent if born outside the US. But only children born to two US citizens, whether born abroad or in the US, are natural born citizens.
Thus, the qualification for being a Senator is that one be a "citizen" for nine years, and for a Representative seven years. No distinction is drawn between naturalized citizens and citizens by birth location or parentage in those provisions. But there is such a specific distinction in the qualification to be President.
Constitutional Qualifications for Senator
U.S. Constitution
No Person shall be a Senator who shall not have attained to the Age of thirty Years, and been nine Years a Citizen of the United States, and who shall not, when elected, be an Inhabitant of that State for which he shall be chosen. [U.S. Constitution, Article I, section 3, clause 3]
Delegates to the 1787 Constitutional Convention supported establishing membership limitations for House and Senate members. Influenced by British and state precedents, they set age, citizenship, and inhabitancy qualifications for senators, but voted against proposed religion and property requirements.
Age: The constitutional framers debated the minimum age for representatives before they considered the same qualification for senators. Although Delegate James Wilson stated that “there was no more reason for incapacitating youth than age, where the requisite qualifications were found,” other delegates were in favor of age restrictions. They were familiar with England’s law requiring members of Parliament to be twenty-one or older, and they lived in states which either barred legislators under the ages of twenty-one or twenty-five from the upper chambers.
As introduced in May 1787, James Madison’s Virginia Plan left Senate age restrictions to the delegates to decide, only stating that members of the second branch must “be of the age of ____ at least.” Without debating the subject further, delegates voted in favor of filling the blank with thirty, and passed the clause unanimously on June 25, three days after designating twenty-five as the minimum age for representatives. In The Federalist, No. 62, Madison justified the higher age requirement for senators. By its deliberative nature, the “senatorial trust,” called for a “greater extent of information and stability of character,” than would be needed in the more democratic House of Representatives.
Citizenship: Under English law, no person “born out of the kingdoms of England, Scotland, or Ireland” could be a member of either house of Parliament. While some delegates may have admired the “strictness” of this policy, no framers advocated a blanket ban on foreign-born legislators. Instead, they debated the length of time members of Congress should be citizens before taking office. The states’ residency qualifications offered moderate guidelines in this regard. New Hampshire’s state senators needed to be residents for at least seven years prior to election. In other states, upper house members fulfilled a five, three, or one-year requirement, while state representatives completed a residency period of one to three years.
The Virginia Plan made no mention of citizenship when Edmund Randolph introduced it to the convention in May. Two months later, the Committee of Detail reported a draft of the Constitution. Article V, section 3 included a four-year citizenship requirement for senators. On August 9, Gouverneur Morris moved to replace the four-year clause with a fourteen-year minimum. Later that day, delegates voted against citizenship requirements of fourteen, thirteen, and ten years before passing the nine-year provision, making the Senate requirement two years longer than that for the House of Representatives.
At the convention, delegates viewed the nine-year citizenship qualification as a compromise “between a total exclusion of adopted citizens” and an “indiscriminate and hasty admission of them.” While they were concerned that the Senate, especially, might be subject to foreign influence, they did not wish to close the institution to naturalized citizens of merit. Two foreign-born framers expressed these opposing considerations. According to Pierce Butler, recent arrivals were dangerously attached to their countries of origin, a particular concern for senators whose role would include review of foreign treaties. From his own experience, he believed that naturalized citizens would need sufficient time to learn and appreciate American laws and customs before they could serve in government. For James Wilson, however, lengthy citizenship requirements “discouraged and mortified” everyone they excluded. He agreed with Benjamin Franklin that a strict policy would hinder positive immigration and offend those Europeans who had supported the Revolutionary War. On August 13, Wilson moved to reduce the Senate qualification by two years. Delegates rejected his motion, and confirmed the nine-year requirement by an 8 to 3 vote.
This points out that the matter of foreigners having influence in the Congress was of importance to the Founders, and it's asinine to assume that they did not have at least that much concern for the office of the President. And the historical evidence proves that they did have such concerns and rather than allowing a foreigner of any kind to hold that office, they set very strict requirements above and beyond mere "citizenship" for the Presidency. If they had meant that anyone who was a "citizen" could be President, they would not have included the term "natural born" at all, they would have simply set the same sort of requirement as they did for Senators.
But they didn't, they set a much higher bar.
Look at the 14th Amendment, incidentally, "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside." There are only two options. A citizen is either (a) born in the US, or (b) naturalized in the US. That's it. That usage does not conflict with the verbiage in the original constitution that the president must be a natural born citizen, because it's just specifying that he can't be the other kind of citizen (natural-ized) and be President.
Wrong. The 14th Amendment specifies that all persons born in the United States are "citizens," but it is utterly silent on who is a "natural born citizen" and cannot therefore be read as disclaiming another class or sub-set of citizenship of "natural born citizen." Yes, all persons born in the US, regardless of the nationality of their parents, are "citizens," but that does not mean that a select sub-set of those persons cannot be "natural born citizens" as distinct from "citizens." That is precisely what the inclusion of "natural born" in the Constitution does and means; there is a third class of citizens, natural born citizens born of two parents who are both US citizens, and only they are eligible to hold the office of President.
The 14th Amendment was also written to deal with the problem of freed slaves who were of uncertain citizenship, and the intent of the 14th Amendment was NOT to repeal or change the qualifications or those eligible to be President. There is no indication in the Amendment or the debates surrounding it evidencing an intent to repeal or change the meaning of Article II's language, so this is a vacuous argument. The 14th Amendent's language is broad and general and intended to sweep within the definition of "citizen" all those freed slaves who had previously been chattels. As a statute of general application, it does not overrule or repeal a statute of specific application unless it does so "manifestly and obviously" and with clear legislative intent to do so.
The provisions of Article II are a law of specific application that carves out a sub-set of all citizens who alone are eligible to be President that was not overruled or repealed by the 14th Amendment's general language and utter lack of manifest intent to so repeal that provision of Article II.
I have presented countervailing evidence -- the correct wording of the Constitution. I've pointed out the defects in your argument, which mean your arguments are defective, and therefore unpersuasive. Since you're making the positive assertion, you've failed your burden of proof.
Not really. All you've done is speciously claim that "citizen" or "citizen by birth" and "natural born citizen" are synonymous, but you've failed utterly to provide any precedent, ruling, regulation or legal argument supporting this claim or making a persuasive argument as to why this interpretation should be accepted, whereas I have pointed out in painful detail the obvious and only rational definition of "natural born citizen" that meets the necessary rules of statutory interpretation that were well known to the people who wrote the Constitution and ratified it.
"Seth is Grandmaster Zen Troll who trains his victims to troll themselves every time they think of him" Robert_S
"All that is required for the triumph of evil is that good men do nothing." Edmund Burke
"Those who support denying anyone the right to keep and bear arms for personal defense are fully complicit in every crime that might have been prevented had the victim been effectively armed." Seth
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