Thank you for the link to Rogers v. Bellei.
I read it in its entirety last night. The Court was split 5-4 (sound familiar?) but the scholarly arguments both for and against were quite illuminating.
I thank you for bringing that to our attention.
Yeah, sure does. But the split was over the constitutionality of residency limits in order to maintain the status of US citizenship. There was no split on the question of whether citizenship was acquired solely by statute. All 9 found that the appellant was naturalized, even though his citizenship attached at birth by operation of the statute, and even though appellant had not gone through a naturalization process.