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. 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.
First of all Minor v Happersett was made moot by passage of the 19th amendment.
Secondly the phrasing in the ruling: “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.” is a dicta, in legal terms for those of you in Rio Linda a side note with no legal weight.
Minor v Happersett made mention that there were some doubts by some as to the citizenship status of persons born in the United States to parents were not citizens at the time of their birth, the important and relative statement by the SCOTUS was that “for purposes of this case, it is not necessary to solve these doubts”. In other words the SCOTUS in Minor v Happersett did not and never made a ruling on whether or not a person born in the United States to non-citizen parents were natural born or not, they only made passing mention that “some” had doubts and stated it was irrelevant in this case anyway.
And a subsequent ruling by the SCOTUS - United States v. Wong Kim Ark, 169 U.S. 649 (1898) ruled otherwise.