A modern court will often spell out its ‘holdings’ in specific detail. For example, in this case involving a suit against Jiffy Lube:
“P10 Plaintiffs contend the court erred in granting Jiffy Lube’s motion for summary judgment. [HN1] In reviewing a grant of summary judgment, we view the facts and the reasonable inferences to be drawn from those facts in the light most favorable to the party against whom judgment was entered...
...P12 [HN2] “To establish a claim for negligence, [***7] a plaintiff must prove four elements: (1) a duty requiring the defendant to conform to a certain standard of care; (2) a breach by the defendant of that standard; (3) a causal connection between the defendant’s conduct and the resulting injury; and (4) actual damages.” Gipson, 214 Ariz. at 143, P 9, 150 P.3d at 230. [HN3] Duty is an “obligation, recognized by law, requiring the [defendant] to conform to a certain standard of conduct, for the protection of others against unreasonable risks.” Ontiveros v. Borak, 136 Ariz. 500, 504, 667 P.2d 200, 204 (1983) (quoting W. Proffer, Handbook on the Law of Torts § 30, at 143 (4th ed. 1971)...
...[HN4] Whether a defendant owes the plaintiff a duty is a threshold issue. Gipson, 214 Ariz. at 143, P 11, 150 P.3d at 230. Absent a duty, a negligence action cannot be maintained. Id...
...In analyzing this issue, [HN5] the Arizona Supreme Court considered two factors in evaluating the existence of a duty: (1) the relationship between the parties and (2) public policy considerations. Id. at 144-146, PP 18-26, 150 P.3d at 231-233.”
All from JOSEPH BRYANT DIAZ; JOSEPH DIAZ, JR.; PATRICIA DIAZ, Plaintiffs/Appellants, v. PHOENIX LUBRICATION SERVICE, INC. dba JIFFY LUBE, Defendant/Appellee.
224 Ariz. 335; 230 P.3d 718; 2010 Ariz. App. LEXIS 70; 581 Ariz. Adv. Rep. 32
Modern folks being dumbed down, many courts will not very specifically mark out each step in their argument. That isn’t done everywhere, and certainly was not the habit of 100+ years ago. But the holding of a court is the entire reasoning used to reach the conclusion, not just the conclusive statement.
WKA spent at least 2 of the major sections discussing natural born subject / natural born citizen / native citizen, all of which it considered to be interchangeable. They did not write all that stuff just because. They wrote it because it was an integral part of their decision.
Unhappily, most birthers cannot read paragraphs and pages, and thus, like MamaTexas, become utterly confused.
And at an irreducible minimum, the argument used in WKA would be persuasive precedence, if not binding - although I think any court would treat it as binding. That has certainly been the case so far!
It's the entire rationale for their decision. That makes it binding precedent. So yes, I would agree that any court would treat it as binding.
Birthers say the very brief comment in Minor is "binding precedent." But it isn't. It's just a totally throwaway comment that is absolutely irrelevant to the resolution of that case.
Virginia Minor was NOT born of alien parents, so any comment they might make regarding people who were was simply not relevant to Minor. That, and the fact that the Court did no analysis of the issue at all, makes it absolutely classic DICTA, or side commentary.
WKA is very different. Here we have dozens of pages of legal and historical analysis that are completely relevant and in fact CORE to the final disposition of the case. So all of that discussion makes for a genuine binding precedent.
Again, that's why lower courts have simply declared Obama a natural born citizen, based on the WKA precedent, and why the Supreme Court absolutely refuses to rehear the arguments. They were exhaustively argued and decided in 1898.
But birthers won't tolerate the standard methods of the way the legal system reasonably works. Because competent law does not produce the results they want. Neither (as we've seen) will they tolerate making decisions that are based on the evidence, rather than on their feelings and preferences. For the same reason.