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There are varying forms of dicta. Without going into a long dissertation suffice for now that ratio decidendi — the rationale for the decision — is where legally binding precedents are created.

All remarks that are outside of the core reasoning for a case are considered to be one or another form of “side comments.” Such side comments may not be as thoroughly researched as the core reasoning. They are not part of the holding in a case, and they do not carry the same authority. For this reason, such statements simply do not – immediately, at least — create precedents. There’s a Latin term for this: dictum. And it simply means “something said.” The plural of “dictum” is “dicta,” which is the more commonly used term. And the most common kind of dicta is “obiter dicta,” which means “things said in passing.”

“An obiter dictum is a remark or observation made by a judge that, although included in the body of the court’s opinion, does not form a necessary part of the court’s decision. In a court opinion, obiter dicta include, but are not limited to, words “introduced by way of illustration, or analogy or argument.”

Unlike the rationes decidendi, obiter dicta are not the subject of the judicial decision, even if they happen to be correct statements of law. Under the doctrine of stare decisis, statements constituting obiter dicta are therefore not binding, although in some jurisdictions, such as England and Wales, they can be strongly persuasive. (Source: Wikipedia)

The paragraph you attribute to the definition of NBC reads:

“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. The words “all children” are certainly as comprehensive, when used in this connection, as “all persons,” and if females are included in the last they must be in the first. That they are included in the last is not denied. In fact the whole argument of the plaintiffs proceeds upon that idea.”

The above statement is considered orbiter dicta – non binding, non precedent setting. If it WAS ratio decidendi it would prove to you something else that you refuse to acknowledge.

The paragraph just prior to the one above reads:

“Additions might always be made to the citizenship of the United States in two ways: first, by birth, and second, by naturalization. This is apparent from the Constitution itself, for it provides 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,” and that Congress shall have power “to establish a uniform rule of naturalization.” Thus new citizens may be born or they may be created by naturalization.”

The Court here admits only two kinds of citizens: Those who are born citizens, and those who are created by naturalization. And they don’t subdivide those who are born citizens into “natural born citizens” and “persons who are merely born citizens, but are not ‘natural born.’” The fact is, no significant legal authority has ever, in the past history of the United States, claimed that such a division exists.

Now… where in Happersett does it say that two citizen parents are required in order to make a natural born citizen? It doesn’t.

It says that “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.”

Yes, it identifies those who are born in a country of two citizen parents as natural born citizens but nowhere does the Court say that those who are born in a country, but don’t have two citizen parents, are not natural born citizens.

There was not, and never had been, any fictional third category of native-born citizens who were born citizens, but who were not “natural-born.” Such a third category appears NOWHERE — not in Minor v. Happersett. Not in US v. Wong Kim Ark. And not in any other case in the entire history of American jurisprudence that anybody has ever produced.

The birther movement claims that the Supreme Court actually did address — in one or two sentences — the issue of whether such people were natural born, even though they didn’t address the issue of whether they were citizens.

When the Supreme Court addresses a matter,they address it. They don’t write just one or two sentences on a matter. They go extensively into the pros and cons.

The Court spent 6 entire pages on whether or not Virginia Minor was a citizen — when it had already been conceded by everybody that she was!

And the Court told us themselves, in Minor v Happersett, that they weren’t going to get into citizenship issues regarding the children born on US soil of non-citizen parents.

How much space would it take for the Supreme Court to actually explore the issue? Would one or two sentences do? It turns out that we know the answer to that question: It would take the Supreme Court more than 50 pages to explore that particular issue. Not two sentences.

And we know that, for a fact, because that’s exactly how much space it did take them, when they finally explored — and answered — that EXACT question. The case was United States v Wong Kim Ark.

Finally, in March 2012, the Arizona Superior Court, Pima County very specifically ruled that Minor v Happersett quite simply does not say what the birthers claim it says. Here’s what that court said:

“[Supreme Court] precedent fully supports that President Obama is a natural born citizen under the Constitution and thus qualified to hold the office of President. See United States v. Wong Kim Ark… Contrary to Plaintiff’s assertion, Minor v. Happersett, 88 U.S. 162 (1874), does not hold otherwise.“,

Source: http://www.scribd.com/doc/84531299/AZ-2012-03-07-Allen-v-Obama-C20121317-ORDER-Dismissing-Complaint

At least NINE federal and state courts — not even counting US v Wong Kim Ark — have either found or stated that citizen parents are NOT required to make a natural born citizen, or have given examples of people who were “natural born citizens,” who clearly did NOT have two US citizen parents. These cases include:

Nwankpa v. Kissinger, 376 F. Supp. 122 (M.D. Ala. 1974)

Diaz-Salazar v. INS, 700 F.2d 1156 (7th Cir. 1983)

Mustata v. US Dept. of Justice, 179 F.3d 1017 (6th Cir. 1999)

Tisdale v. Obama (US District Court for the Eastern District of Virginia, Richmond Division, 2012)

Lynch v. Clarke (New York, 1844)

Ankeny v. Governor of the State of Indiana, 916 NE2d 678, 688 (2009), (Ind. Supreme Court, Apr. 5, 2010)

Farrar-Welden-Swensson-Powell v Obama (Georgia, 2012)

Allen v Democratic Party (AZ Superior Court, Pima Co., 2012)

Purpura & Moran v. Obama (New Jersey, 2012)

At the same time, no court has ever ruled that two citizen parents are required.

I won’t even get into US v Wong Kim Ark because it would take up too much verbiage but it IS the 800 pound gorilla in the room that totally slaps down the birther movement with a giant bat and it DOES SET precedent.