The decision argued at great length that WKA met the qualification for both NBC & 14th Amendment. In fact, the court said that the NBC clause and the 14th were using the exact same criteria for citizenship.
“The real object of the Fourteenth Amendment of the Constitution, in qualifying the words, “All persons born in the United States” by the addition “and subject to the jurisdiction thereof,” would appear to have been to exclude, by the fewest and fittest words (besides children of members of the Indian tribes, standing in a peculiar relation to the National Government, unknown to the common law), the two classes of cases — children born of alien enemies in hostile occupation and children of diplomatic representatives of a foreign State — both of which, as has already been shown, by the law of England and by our own law from the time of the first settlement of the English colonies in America, had been recognized exceptions to the fundamental rule of citizenship by birth within the country. Calvin’s Case, 7 Rep. 1, 18b; Cockburn on Nationality, 7; Dicey Conflict of Laws, 177; Inglis v. Sailors’ Snug Harbor, 3 Pet. 99, 155; 2 Kent Com. 39, 42.
The principles upon which each of those exceptions rests were long ago distinctly stated by this court. [p683]”
If the set of people who are NBC is the exact same as the set of people who are 14th Amendment citizens, then the terms are equivalent.
The decision argued at great length that WKA met the qualification for both NBC & 14th Amendment. In fact, the court said that the NBC clause and the 14th were using the exact same criteria for citizenship.----------------------------------------------------------
Sorry, no. Even to this day, the U.S. Government does NOT necessarily consider a statutory citizen at birth to be a "natural born citizen" for Constitutional purposes.
"In any event, the fact that someone is a natural born citizen pursuant to a statute does not necessarily imply that he or she is such a citizen for Constitutional purposes."http://www.state.gov/documents/organization/86757.pdf