Minor v Happersett never approached the question of native born Vs natural born. It was not the question nor was it part of the answer.
The question was about women voting. It declared women citizens jsut as men based upon where they were born.
‘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. No State shall make or enforce any law, which shall abridge the privileges or immunities of citizens of the United States. Nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction, the equal protection of the laws.’
It never approached the question of what natural born citizen was or is, anymore than a native citizen. The intent of the court was to define who had the right to vote. Not who had the ability to hold the highest office in the land
Sorry, but this wrong. Virginia Minor sued for suffrage because she claimed she was a 14th amendment citizen.
"The argument is, that as a woman, born or naturalized in the United States and subject to the jurisdiction thereof, is a citizen of the United States and of the State in which she resides, she has the right of suffrage as one of the privileges and immunities of her citizenship, which the State cannot by its laws or constitution abridge."
The Supreme Court rejected her citizenship claim because she was a natural born citizen.
"But, in our opinion, it did not need this amendment to give them that position. Before its adoption the Constitution of the United States did not in terms prescribe who should be citizens of the United States or of the several States, yet there were necessarily such citizens without such provision."
To explain, it goes on to give a definition of natural born citizens with the requirements of jus soli and jus sanguinis criteria.
"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."
Justice Waite clarifies again that he rejects Minor's claim of 14th amendment citizenship because she is already a citizen (by virtue of meeting his definition of natural born citizen).
"The fourteenth amendment did not affect the citizenship of women any more than it did of men. In this particular, therefore, the rights of Mrs. Minor do not depend upon the amendment. She has always been a citizen from her birth, and entitled to all the privileges and immunities of citizenship. The amendment prohibited the State, of which she is a citizen, from abridging any of her privileges and immunities as a citizen of the United States; but it did not confer citizenship on her."
Justice Gray affirms this part of the decision, that Minor's citizenship is determined by jus soli and jus sanguinis factors.
"Minor v. Happersett (1874), 21 Wall. 162, 166-168. The decision in that case was that a woman born of citizen parents within the United States was a citizen of the United States, ...
Gray cited Minor's definition of natural born citizen verbatim. Those factors did NOT apply to Wong Kim Ark. Therefore Gray invented a concept that he called "citizenship by birth" which is the citizenship deriving from the 14th amendment. It is different from natural born citizenship. Gray notes that NBC is defined outside the Constitution while Citizenship by Birth is defined BY the Constitution, specifically the 14th amendment.
"In Minor v. Happersett, Chief Justice Waite, when construing, in behalf of the court, the very provision of the Fourteenth Amendment now in question, said: 'The Constitution does not, in words, say who shall be natural-born citizens. Resort must be had elsewhere to ascertain that.'"
"But citizenship by birth is established by the mere fact of birth under the circumstances defined in the Constitution."The intent of the court was to define who had the right to vote. Not who had the ability to hold the highest office in the land.
Sorry, but this fails on examination of the Minor decision, in which the very reason for defining natural born citizen was to explain what the Constitution means in Art II, Sec I.
"This is apparent from the Constitution itself, for it provides [n6] that 'no person except a natural-born citizen, or a citizen of the United States at the time of the adoption of the Constitution, shall be eligible to the office of President, ...'"