SENSE and non-SENSE

UPDATE:  Please read my Comment below, containing an excerpt from the Supreme Court’s ruling in the Slaughterhouse Cases, which emphasizes this point with relation to the 14th Amendment’s language on citizens.  In short, if the 14th Amendment can be said to be conferring citizenship rather than merely codifying those definitions already understood in law and practice then, it does so only by establishing the distinction between the rights accruing to citizens as citizens of the U.S.A. which rights are now uniform; versus the rights of citizens as citizens of the states (in which they reside), which vary according to the state.  

© 2011 jbjd

No legally binding definition exists of the phrase “natural born citizen” as written in Article II, section 1 of the U.S. Constitution; and no such definition will be forthcoming until a federal appeals court, including the U.S. Supreme Court, rules, this is the definition, in the holding of a case or controversy directly on point, that is, one which requires the court to formulate such definition so as to reach resolution of the matter properly before the court.

I have said this a ‘million’ times, with only slight variation, since I began blogging in 2008. And, as I have also indicated, for a couple of reasons, at this point, that is, now that President Obama has been elected; I couldn’t care less whether he is a NBC; and I have been saying this for a long time, too. What difference does it make whether he is a NBC when we enacted no laws that required our state Electors to elect only a President who is Constitutionally eligible for the job!  (This would explain my insistence that present calls for Impeachment cannot be predicated only on his Constitutional ineligibility for office.) And, regardless of the absence of documentary evidence available in the public record that, he is even a C, which status certainly was well defined and accepted by the aforementioned legal authorities even before this definition was codified in the 14th Amendment for the purpose of qualifying who is entitled to “privileges and immunities”; it appears true that, millions of my fellow citizens who voted for (Electors for) the man, could not have cared less whether he is a NBC, either, even before his election.

Thus, I have steered clear of substantively addressing the ‘legal’ arguments out there which insist, a binding definition of NBC exists.

However, obviously, this recognition of the status quo, that is, no legally binding definition exists of NBC; and my present indifference to Obama’s Constitutional eligibility for office; have had little to do with my continuing efforts to identify a mechanism for determining whether he is a NBC, for those people who want to know. Indeed, my mission has always focused on the larger issue of understanding how our government, in general; and particularly our electoral system works and, where it does not work, how we might fix it.  (Yes, in so doing, I figured out how to spark the court case that could result in a legally binding definition of NBC but, that is not the focus of this post.)

And it is because my focus is on fixing what is broken in our system that, notwithstanding I have refused to enter the ‘legal definition of NBC’ fray in the past; for the moment, I changed my mind.  Because now, 3+ years into our national discussion about Constitutional eligibility; about to dive into a new general election cycle; we are still being sidetracked by such folly.  So, responding to a comment from long-time “jbjd” reader, Mick; I decided to weigh in, once and for all, on the case most often cited to sustain this drivel.

From Mick:

Again, a circular firing squad you present. If there is no judiciable definition of natural born Citizen, as you say, then how can the Secretary of State of any state verify whether a POTUS candidate is eligible? As usual, many words in this post saying nothing, except the whining about someone stealing your “work”. How about this definition, straight from SCOTUS in Minor v. Happersett: “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.” Pretty plain to most people with any sense.

Here is my response.

Mick: The legal case you mention – Minor v. Happersett – does not rest on defining what is meant by the term “natural born citizen.”  Indeed, the case is not at all concerned with distinguishing from among “natural born citizen”; or “native citizen”; or “naturalized citizen.” Rather, this is a (state) voting rights case to determine only whether MO law can rightly prohibit women from voting, brought under the “rights and privileges” clause of the 14th Amendment. In other words, is suffrage a “right” or “privilege” that now must be protected for female citizens otherwise prohibited under state law from voting on account of their gender?  But as a threshold matter, the court must first determine whether the word “citizen” as this is used in the 14th Amendment; means women, too.

Thus, the court conducts an extensive analysis (non-binding dicta) of the legal posture of historical authorities, both in common law, statutes, and state constitutions, with respect to the meaning of citizen, as this applies  generically.  It acknowledges, these authorities have always been consistent in saying, the child born in this jurisdiction, of citizen parents is a natural born native citizen; but inconsistent on whether the same can be said of children born here of non-citizen parents. Both of Ms. Minor’s parents were citizens at the time of her birth.  The court wrote, therefore, there was no need to “reach” the question as to whether she would still be a native natural  born citizen if her parents were not citizens.

Here is the whole quote from that same passage you excerpted in your comment. Now, see if this makes more sense.

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.

Then, having determined, Ms. Minor is by all other means, a citizen; the court similarly conducts an extensive analysis (non-binding dicta) of the legal posture of historical authorities, both in common law, statutes, and state constitutions, with respect to the meaning of citizen, as this applies  to women.  And, it concludes, women were always historically considered citizens (who satisfied the uniformly accepted threshold requirement of birth in this jurisdiction to citizen parents).  Thus, the word “citizen” in the 14th Amendment as this relates to the “privileges and immunities” clause, means, women, too.  (The court makes clear that, as she is a natural born native citizen, her citizenship, and impliedly the citizenship of all women and men similarly situated, (though not necessarily the citizenship of people born here to non-citizen parents, or who achieved citizenship through naturalization because, as the court had already pointed out, the authorities had heretofore been mixed as to whether these were citizens and, it would not resolve that issue here) was not newly conferred by the 14th Amendment but only newly codified as entitling them as citizens to the same “privileges and immunities” as all citizens of the several states. That is, the 14th Amendment does not create a new definition of citizen.)

Then, having determined, Ms. Minor is by all other means, a citizen; and that, citizen means, women; the court similarly conducts an extensive analysis (non-binding dicta) of the legal posture of historical authorities, both in common law, statutes, and state constitutions, with respect to whether suffrage can be said to be a “right” or “privilege” under the 14th Amendment.  And that’s where Ms. Minor’s case fails. Because voting in the several states had always been largely exclusive to men.  Even when it was not exclusive to citizens.

Besides this, citizenship has not in all cases been made a condition precedent to the enjoyment of the right of suffrage. Thus, in Missouri, persons of foreign birth, who have declared their intention to become citizens of the United States, may under certain circumstances vote. The same provision is to be found in the constitutions of Alabama, Arkansas, Florida, Georgia, Indiana, Kansas, Minnesota, and Texas.  Id.

In other words, Ms. Minor was entitled to all of the privileges and immunities of all citizens; and voting wasn’t one of those privileges and immunities.

Finally, you ask, how can the Secretary of State of any state verify whether a candidate for President is eligible for the job?  S/he cannot.  Because, right now, no law says, s/he must, even in those states that require candidates to be qualified for office to appear on the ballot.  Yep; even in those states where the legislature has already acted, no SoS had promulgated rules and regulations defining such ballot eligibility, let alone identifying whose job will be, to check.

In conclusion, Mick, no legally binding definition exists of the phrase “natural born citizen” as written in Article II, section 1 of the U.S. Constitution; and no such definition will be forthcoming until a federal appeals court, including the U.S. Supreme Court, rules, this is the definition, in the holding of a case or controversy directly on point, that is, one which requires the court to formulate such definition so as to reach resolution of the matter properly before the court.  And, absent a legally binding definition of NBC; no state with a law requiring candidate eligibility to appear on the ballot, has even (attempted) to enact rules and regulations to define NBC for the sole purpose of determining ballot eligibility.

Make sense?  ADMINISTRATOR

****************************************************************************************************************************************************

For those of you who will not read the whole case, here is a syllabus, prepared by the court.

Syllabus

SUPREME COURT OF THE UNITED STATES


88 U.S. 162

Minor v. Happersett


Argued: February 9, 1875 — Decided: March 29, 1875


ERROR to the Supreme Court of Missouri; the case being thus:

The fourteenth amendment to the Constitution of the United States, in its first section, thus ordains; [n1]

“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.”

And the constitution of the State of Missouri [n2] thus ordains:

“Every male citizen of the United States shall be entitled to vote.”

Under a statute of the State all persons wishing to vote at any election, must previously have been registered in the manner pointed out by the statute, this being a condition precedent to the exercise of the elective franchise.

In this state of things, on the 15th of October, 1872 (one of the days fixed by law for the registration of voters), Mrs. Virginia Minor, a native born, free, white citizen of the United States, and of the State of Missouri, over the age of twenty-one years, wishing to vote for electors for President and Vice-President of the United States, and for a representative in Congress, and for other officers, at the general election held in November, 1872, applied to one Happersett, the registrar of voters, to register her as a lawful voter, which he refused to do, assigning for cause that she was not a “male citizen of the United States,” but a woman. She thereupon sued him in one of the inferior State courts of Missouri, for wilfully refusing to place her name upon the list of registered voters, by which refusal she was deprived of her right to vote.

The registrar demurred, and the court in which the suit was brought sustained the demurrer, and gave judgment in his favor; a judgment which the Supreme Court affirmed. Mrs. Minor now brought the case here on error.

1. The word “citizen” is often used to convey the idea of membership in a nation.

2. In that sense, women, of born of citizen parents within the jurisdiction of the United States, have always been considered citizens of the United States, as much so before the adoption of the fourteenth amendment to the Constitution as since.

3. The right of suffrage was not necessarily one of the privileges or immunities of citizenship before the adoption of the fourteenth amendment, and that amendment does not add to these privileges and immunities. It simply furnishes additional guaranty for the protection of such as the citizen already had.

4. At the time of the adoption of that amendment, suffrage was not coextensive with the citizenship of the States; nor was it at the time of the adoption of the Constitution.

5. Neither the Constitution nor the fourteenth amendment made all citizens voters.

6. A provision in a State constitution which confines the right of voting to “male citizens of the United States,” is no violation of the Federal Constitution. In such a State women have no right to vote.

****************************************************************************************************************************************************

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19 Responses to SENSE and non-SENSE

  1. jbjd says:

    When I wrote this article, I had no idea that a couple of other bloggers had also recently posted items in which they discussed the role they had determined the 14th Amendment plays in the discussion as to President Obama’s Constitutional eligibility for POTUS. I have now read those other articles and am satisfied that my current dissertation dispels the misinformation contained in both. But, just to make sure you ‘get it,’ I want to emphasize what this case was; and what it was not, only insofar as it pertains to the issue of citizenship. And for this, I leave you with another summary on the ‘citizenship’ portion of the 14th Amendment, which clearly spells out that the rights of citizens qua citizens of the U.S. are established independent of the rights as citizens of the state in which they reside. Thus, this establishes a uniform application of preexisting principles of citizenship which had been disparately applied based on state residency; color/servitude; and residency in the (federal) District of Columbia. That is, if you are born in the U.S.A. then, you are a citizen of the U.S.A., regardless of whether you are a citizen of a particular state; and, as such, you are entitled to the same “privileges and immunities” as every other U.S. citizen. In other words, those citizens previously called slaves, if born here, were always U.S. citizens notwithstanding they were denied the rights and privileges of such citizenship. And, the residents of Washington, D.C., previously denied their rights as citizens inasmuch as such rights were deemed to emanate from the states; were similarly identified as citizens of the U.S., again, entitled to the rights and privileges of all other citizens.

    From the Slaughterhouse Cases:


    The first section of the fourteenth article to which our attention is more specially invited opens with a definition of citizenship — not only citizenship of the United States, but citizenship of the States. No such definition was previously found in the Constitution, nor had any attempt been made to define it by act of Congress. It had been the occasion of much discussion in the courts, by the executive departments, and in the public journals. It had been said by eminent judges that no man was a citizen of the United States except as he was a citizen of one of the States composing the Union. Those, therefore, who had been born and resided always in the District of Columbia or in the Territories, though within the United States, were not citizens. Whether [p73] this proposition was sound or not had never been judicially decided. But it had been held by this court, in the celebrated Dred Scott case, only a few years before the outbreak of the civil war, that a man of African descent, whether a slave or not, was not and could not be a citizen of a State or of the United States. This decision, while it met the condemnation of some of the ablest statesmen and constitutional lawyers of the country, had never been overruled, and if was to be accepted as a constitutional limitation of the right of citizenship, then all the negro race who had recently been made freemen were still not only not citizens, but were incapable of becoming so by anything short of an amendment to the Constitution.

    To remove this difficulty primarily, and to establish clear and comprehensive definition of citizenship which should declare what should constitute citizenship of the United States and also citizenship of a State, the first clause of the first section was framed.

    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.

    The first observation we have to make on this clause is that it puts at rest both the questions which we stated to have been the subject of differences of opinion. It declares that persons may be citizens of the United States without regard to their citizenship of a particular State, and it overturns the Dred Scott decision by making all persons born within the United States and subject to its jurisdiction citizens of the United States. That its main purpose was to establish the citizenship of the negro can admit of no doubt. The phrase, “subject to its jurisdiction” was intended to exclude from its operation children of ministers, consuls, and citizens or subjects of foreign States born within the United States.

    The next observation is more important in view of the arguments of counsel in the present case. It is that the distinction between citizenship of the United States and citizenship of a State is clearly recognized and established. [p74] Not only may a man be a citizen of the United States without being a citizen of a State, but an important element is necessary to convert the former into the latter. He must reside within the State to make him a citizen of it, but it is only necessary that he should be born or naturalized in the United States to be a citizen of the Union.

    It is quite clear, then, that there is a citizenship of the United States, and a citizenship of a State, which are distinct from each other, and which depend upon different characteristics or circumstances in the individual.

    We think this distinction and its explicit recognition in this amendment of great weight in this argument, because the next paragraph of this same section, which is the one mainly relied on by the plaintiffs in error, speaks only of privileges and immunities of citizens of the United States, and does not speak of those of citizens of the several States. The argument, however, in favor of the plaintiffs rests wholly on the assumption that the citizenship is the same, and the privileges and immunities guaranteed by the clause are the same.

    http://www.law.cornell.edu/supct/html/historics/USSC_CR_0083_0036_ZO.html

    • Wayne says:

      Howdy jbjd,

      RE: From the Slaughterhouse Cases:

      What consequence, if any, would the last sentence of the portion of Slaughterhouse below have on Judge Malihi’s decision?

      The first observation we have to make on this clause is that it puts at rest both the questions which we stated to have been the subject of differences of opinion. It declares that persons may be citizens of the United States without regard to their citizenship of a particular State, and it overturns the Dred Scott decision by making all persons born within the United States and subject to its jurisdiction citizens of the United States. That its main purpose was to establish the citizenship of the negro can admit of no doubt. The phrase, “subject to its jurisdiction” was intended to exclude from its operation children of ministers, consuls, and citizens or subjects of foreign States born within the United States.  

      • jbjd says:

        Wayne: I don’t understand your question. Besides, I found ALJ Malihi’s reliance on SCOTUS cases inapposite to a ‘ruling’ on the administrative issue before him. (And, while I have this opportunity, I just want to point out, the use in this case of the phrase “establish the citizenship of the negro” cannot be interpreted as indicating, ‘the negro had no U.S. citizenship prior to the 14th Amendment.’ Rather, given the fact, U.S. citizenship existed before the 14th Amendment; and, that the 14th Amendment neither granted citizenship nor defined citizenship but merely qualified the rights inherent to such citizenship; the word “establish” here means, put on record, so as to avoid any further denial that they are citizens, once and for all.) ADMINISTRATOR

  2. Mick says:

    All nonsense. you are obviously a double agent if you agree w/ Berg, i.e another Liberal in sheep’s clothing. The first holding in the case was that V. Minor was a Citizen. Waite SPECIFICALLY said that the 14th A was not needed to determine that fact, since she was a natural born Citizen, i.e born in the US of US Citizen parents. They first had to determine that Minor was a US Citizen before deciding the question of whether she had a Constitutional right to vote. NO STATUTE was needed to determine her US Citizenship, and Waite SPECIFICALLY separated her “class” from other Citizen classes. Repeating, FIRST they had to determine she was a US 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.”

    Then Waite goes on to say that the 14A is not needed:

    “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.”

    The Waite ups the ante:

    “To determine, then, who were citizens of the United States before the adoption of the amendment, it is necessary to ascertain what persons originally associated themselves together to form the nation and what were afterwards admitted to membership.”

    Then the clincher:

    “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”

    Then:

    “It is sufficient for everything we have now to consider that all children born of citizen parents within the jurisdiction are themselves citizens”

    (paragraph omitted by jbjd)

    Mick: You still don’t get it. The SCOTUS in Minor did not seek to formulate a definition of citizenship, whether NBC or otherwise; it did not “find” or “hold” an NBC has 2 citizen parents; nor did its ruling depend on such definition. (Remember, we had citizens BEFORE the 14th Amendment, even without any Constitutional definition as to what “citizen” means.) Rather, the Minor court merely sought to ascertain from empirical evidence, in the absence of any Constitutional definition, whether people in Ms. Minor’s circumstances historically were considered to be citizens. Because if she was considered a citizen (of whatever kind) before the 14th Amendment then, the word citizen in that amendment applied to her and, as a result, she is entitled to the “privileges and immunities” of her fellow citizens.

    Know what’s funny? No 14th Amendment jurisprudence in the past 100+ years, coming from recognized expert legal theorists; has adopted Leo’s viewpoint as to what that citizenship clause means, or what Minor means. I am not saying, Leo must be wrong because he is the only one reaching this conclusion. However, having done a couple of searches to see who is promoting what I am describing as this baseless interpretation throughout the blogosphere; it appears to me, they are zealously clinging to this tripe because such beliefs have spawned a cottage industry that depends on accepting the false premise, the court has ruled, without 2 citizen parents, one cannot be said to be natural born. And that, therefore, Obama cannot be said to be natural born. And this false theory appeals to those people who hate Obama so much they have lost all reason to discern fact from fiction, and patriots from charlatans, however well intentioned they may be.

    Finally, as you can see, this time I edited out your extraneous ‘name calling.’ Next time, I will reject the comment in its entirety. ADMINISTRATOR

  3. Mick says:

    To be afforded the guarantees of the 14A one must be a US Citizen, either Born or naturalized. Waite says explicitly that to even be afforded consideration before the court as to citizenship rights, that one of the holdings of the Court MUST be that the plaintiff is a US Citizen:

    “But if more is necessary to show that women have always been considered as citizens the same as men, abundant proof is to be found in the legislative and judicial history of the country. Thus, by the Constitution, the judicial power of the United States is made to extend to controversies between citizens of different states. Under this, it has been uniformly held that the citizenship necessary to give the courts of the United States jurisdiction of a cause must be affirmatively shown on the record. Its existence as a fact may be put in issue and tried. If found not to exist, the case must be dismissed.”

    Waite establishes Minor’s US Citizenship by specifically EXCLUDING the 14A, and uses A2S1C5 instead, thus making his determination of Minor’s natural born Citizenship, and the definition thereof as a holding, and precedent of US Law.
    Natural Born Citizens need no naturalization by the 14A. He did not say that other classes may be natural born Citizens, he said that they may not even be citizens, but if they were US Citizens it would be of the naturalized “class”. To be a citizen because of the 14A is to be naturalized, and Waite separated Minor from naturalized Citizens:

    “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. That she had before its adoption.”

    As proof of the precedencial value of Waites holdings about Original citizenship, cases thereafter, Pope v. Williams, and Boyd v. Nebraska both cited Minor v. Happersett as to original citizenship. No case has been on point about who is a eligible to be POTUS, but the precedencial value of Minor v. Happersett is clear. The fact that
    “recognized legal theorists” have not made this determination really means nothing, as recognized legal theorists, “law profs” w/ blogs, and other assundry “experts” have allowed the Usurpation w/o a peep, many being cowed by the “birther” epithet, or the scorn of those that seek to devalue American Citizenship. The Allegiance part of the Allegiance for Protection compact has been eroded by the acceptance of dual citizenship, making even the citizenship oath moot. Without Allegiance there is no Protection. I hold in contempt these supposed pillars of constitutional acumen, such as Tribe or Turley. They slept while the Republic burned. This Congress– both sides– will be shown as the worst ever in American history, and future citizens, if they are to exist, will spit on their memory. If you are so brave as to call Mr. Donofrio’s analysis incorrect, then be brave and take it up w/ him at his blog, instead of sniping from cover, I am sure that it would be educational.

    Mick: A case has precedential value only insofar as the court relies on a holding in that case to support its holding in another. The court in Pope v. Williams, which you rightly point out references Minor, only cites to Minor for this one holding that, suffrage is not intrinsically a “right or privilege” of citizenship (and, therefore, is not protected by the 14th Amendment):

    While the privilege to vote may not be abridged by a state on account of race, color and previous condition of servitude, the privilege is not given by the federal Constitution or by any of its amendments, nor is it a privilege springing from citizenship of the United States. Minor v. Happersett, 21 Wall. 162.

    (See, I even used Justia to show you where you (and Leo) went wrong.

    That is, consistent with what I have been saying all along, Minor is best looked at not as a citizenship case but as a voting rights case.

    Boyd v. Nebraska is also a voting rights case; and only mentions Minor in terms of repeating not a holding or finding from the Minor court, but a “remark” which, along with several other non-precedential comments, is used by the Boyd court in much the same way the Minor court had used such anecdotal evidence. That is, absent a more fixed definition of citizenship, for the purpose of voting, have the various jurisdictions considered as citizens, those people similarly situated to the Petitioner in this case?

    As remarked by Mr. Chief Justice Waite in Minor v. Happersett, 21 Wall. 162, 167: ‘Whoever, then, was one of the people of either of these states when the constitution of the United States was adopted, became ipso facto a citizen, – a member of the nation created by its adoption. He was one of the persons associating together to form the nation, and was, consequently, one of its original citizens. As to this there has never been a doubt. Disputes have arisen as to whether or not certain persons or certain classes of persons were part of the people at the time, but never as to their citizenship if they were.’

    http://www.utulsa.edu/law/classes/rice/USSCT_Cases/Boyd_v_Nebraska%20_Thayer_143_135.htm

    Finally, you write, “Waite establishes Minor’s US Citizenship by specifically EXCLUDING the 14A, and uses A2S1C5 instead, thus making his determination of Minor’s natural born Citizenship, and the definition thereof as a holding, and precedent of US Law.” But you don’t understand what that means. Because you keep thinking, the 14th Amendment is conferring brand new types of citizenship. It is not. As I have said, it is only codifying what citizenship already exists. And, since no one was in doubt as to whether someone in Minor’s situation was a citizen entitled to “rights and privileges,” the court did not have to check the definition of citizen now codified in the 14th Amendment. However, the court said, confusion among authorities existed as to whether someone born here of non-citizen parents was a citizen; and, presumably, had the court been facing a voting rights question brought by a Petitioner born here with non-citizen parents; the court would have looked to the 14th Amendment for clarification and read that the uniform standard is now codified that anyone born in this jurisdiction is a citizen.

    You rightly point out, the 14th Amendment did not confer citizenship on Minor; and, you correctly understand this to mean, she was already a citizen before the 14th Amendment. The court said, authorities have not been confused as to the status of a citizen born here to 2 citizen parents. However, you then wrongly assume this must mean, the 14th Amendment did confer citizenship on people born here of non-citizen parents; or people who were naturalized as citizens. In other words, you are claiming, since the only category of citizen the Minor court definitively identified as being considered a citizen by all authorities, in all jurisdictions, was someone born here of 2 citizen parents; that these other people were not citizens before the 14th Amendment clarified, they were. And this is patently absurd. The court said, ‘I am not going to bother considering whether under other circumstances Minor could be considered a citizen, given the inconsistent authorities; because in her present circumstances, the authorities are of one mind.’

    (This points to another common practice of the courts; they don’t reach.) ADMINISTRATOR

    • Mick says:

      No, Waite was saying that those naturalized by the 14A were NOT batural born Citizens.

      Mick: Okay, now I see your mistake. The phrase in your statement, “naturalized by the 14A” means, ‘naturalized citizens were not citizens until the 14th Amendment made them citizens.’ That is, before the 14th Amendment, we had no naturalized citizens. In other words, you are saying, ‘the 14th Amendment conferred citizenship on naturalized people.’ But, this is wrong. Naturalized citizens were citizens before the 14th Amendment. The 14th Amendment did not confer citizenship on anyone; it merely codifies the fact that citizens in the U.S. have always been created by birth and naturalization and then, more importantly, establishes that, regardless of how they became citizens; as citizens of the U.S., they now enjoy the same rights and privileges as all other U.S. citizens.

      As to the meaning of the term “natural born” to the extent the decision in Minor mentions the term, I repeat, the court by this use is not defining NBC, or “holding” that this is the definition of NBC. It is merely acknowledging that Minor is a citizen by citing that, even before the adoption of this Constitutionally codified definition of C; authorities throughout the states had unanimously agreed, a person born here with 2 citizen parents is one. THIS DOES NOT MEAN, THE COURT IS ADDITIONALLY SAYING, A PERSON BORN HERE OF 2 NON-CITIZEN PARENTS; OR PARENTS ONLY 1 OF WHOM IS A CITIZEN, IS NOT A NBC. INDEED, THE COURT SPECIFICALLY SAYS, ‘I DON’T HAVE TO REACH THAT ISSUE IN ORDER TO ESTABLISH THE THRESHOLD ISSUE IN THIS CASE, WHICH IS, IS MINOR A CITIZEN NOW ENTITLED BY THE 14th AMENDMENT TO THE RIGHTS AND PRIVILEGES OF ALL CITIZENS.’ But it doesn’t matter, anyway. Because the Minor court is not defining NBC. ADMINISTRATOR

  4. Mick says:

    Of course you ignore the most important part of the case:

    “But if more is necessary to show that women have always been considered as citizens the same as men, abundant proof is to be found in the legislative and judicial history of the country. Thus, by the Constitution, the judicial power of the United States is made to extend to controversies between citizens of different states. Under this, it has been uniformly held that the citizenship necessary to give the courts of the United States jurisdiction of a cause must be affirmatively shown on the record. Its existence as a fact may be put in issue and tried. If found not to exist, the case must be dismissed.”

    The court wasn’t willy nilly saying there are many types of natural born Citizenship, it was saying that Minor belonged to the class of US citizens known as natural born Citizens, who didn’t need the 14th Amendment to be deemed a US Citizen, and defined that clas of citizens, to the exclusion of the other class. I “understand” perfectly. Waite could have said Minor was a US Citizen by virtue of the 14th A, and birth in a US state, but he didn’t, and the HOLDING that Minor was a US Citizen construed A2S1C5.

    Boyd cited M v. H as to Original Citizenship:

    As remarked by Mr. Chief Justice Waite in Minor v. Happersett, 21 Wall. 162, 88 U. S. 167:

    “Whoever, then, was one of the people of either of these states when the Constitution of the United States was adopted became ipso facto a citizen — a member of the nation created by its adoption. He was one of the persons associating together to form the nation, and was consequently one of its original citizens. As to this there has never been a doubt. Disputes have arisen as to whether or not certain persons or certain classes of persons were part of the people at the time, but never as to their citizenship if they were.”

    This was a direct cite of Original Citizenship as paralleled w/ the Original Citizens at the time of the adoption of the US Constitution. Boyd was made a US Citizen (naturalized) by the acceptance of Nebraska as a territory and then state while Boyd was an inhabitant thereof.

    From the holding of Boyd v. Nebraska:

    “that in short he was within the intent and meaning, effect and operation, of the acts of Congress in relation to citizens of the territory, and was made a citizen of the United States and of the State of Nebraska under the organic and Enabling Acts and the act of admission.”

    It was not a “voting rights case”, it was a challenge that Boyd was not a US Citizen made by the Incumbant Governor after the Incumbant lost to Boyd. It was a direct holding as to the original citizenship naturalization of inhabitants of a new state. Did you not read the case, or did you assume that I did not?

    Mick: Last time. When a court talks about what others have said about citizenship; this is not the same as ruling on the definition of citizenship, where such definition is not otherwise explicitly spelled out in law. And, even Boyd, which, as you say, is not specifically a voting rights case; is still only a case that determines the narrow issue as to whether, absent a document attesting to naturalization; the Petitioner, elected Governor of his state, can be said to have been naturalized based on acting like a citizen, like voting.

    That where no record of naturalization can be produced, evidence that a person having the requisite qualifications to become a citizen did in fact and for a long time vote and hold office and exercise rights belonging to citizens is sufficient to warrant a jury in inferring that he has been duly naturalized as a citizen.

    You and I agree that the court has no question even before looking at the 14th Amendment whether Minor meets the threshold requirement of citizen as that word appears in the 14th Amendment in relation to “privileges and immunities.” But you mistakenly equate saying that; with saying, ‘she is not a 14th Amendment citizen.’ But, she is; that is, she was born under the jurisdiction of the U.S. and so, is entitled to the “rights and privileges” of U.S. citizens. And, your interpretation also wrongly leads to the conclusion that the court is essentially saying, ‘some people who are not citizens now well might be categorized as citizens under the 14th Amendment but since we already know, Minor is a citizen; we don’t have to look at the ‘new’ definition of citizen in the 14th Amendment.’ No; people who would have been citizens of the U.S. before the 14th Amendment are still citizens; and those who would not have been, still are not. The 14th Amendment created no new citizens; it merely clarified, those people born in the U.S. and subject to the jurisdiction thereof (as opposed to, for example, ambassadors and the like); are citizens of the U.S., regardless of how the states previously classified them in relation to the states. (This codification of U.S. citizenship as opposed to state citizenship explains why, as I said previously, people born in Washington, D.C., not identified as citizens before the 14th Amendment because they were not born in a state; were now identified as citizens of the U.S.; and why slaves born here, though not specifically mentioned; were now similarly identified as having always been citizens of the U.S., even if not citizens of particular states. But the governing factor was always, were they born in the U.S.A. and subject to the jurisdiction of the U.S.) ADMINISTRATOR

  5. kj says:

    Boyd vs. Nebraska was primarily a citizenship case.

    The foreign born Boyd was elected governor of Nebraska although he did not have proof of his father’s (and his) naturalization. Boyd vs. Nebraska was a quo waranto challenge from the losing gubernatorial candidate based on Boyd’s lack of proof of US citizenship.

    Boyd’s father had declared an intent to naturalize, but no naturalization certificate could be produced. His father acted as a citizen and believed he was a citizen. Boyd also acted as a citizen and believed he was a citizen. The Supreme Court found the actions and service more important than the document, declared that Boyd was a defacto citizen, allowing him to serve as governor.

    You might want to check out naturalborncitizen.wordpress.com. Leo Donofrio claims to have found some misleading “editing” of Boyd vs. Nebraska on Justia.

    kj: Geesh, this is getting burdensome. Read my complete exchange with Mick. Here’s Boyd v. Nebraska from a .edu web site. http://www.utulsa.edu/law/classes/rice/USSCT_Cases/Boyd_v_Nebraska%20_Thayer_143_135.htm If you disagree with my 14th Amendment jurisprudence, or do not trust sources I provide; read any of the extensive 14th Amendment jurisprudence available throughout the web. (Don’t pick another blog as your source of information.)

    Rest assured, Leo got this wrong, again.

    On another web site, I read a comment about Leo’s latest ‘conspiracy’ theory regarding Justia. I pointed out, a commercial web site like Justia.com, which describes itself as a compiler of information available throughout the internet; is not an ‘official’ publication of our laws, or of our court cases. That is, no state has contracted with this publisher to be the printer of record of its legal documents. I said, if Leo cared whether his readers understood this salient point, he would have told them. I assured him, a legal pleading submitted by a 1st year law student which cited Justia.com as a primary source; would receive a failing grade. In other words, even assuming they alter text they purport is the transcript of a legal case; well, so what? And this anecdote illustrates one of the reasons I cannot refer people to Leo’s web site, or credit anything he says, especially insofar as this relates to the law.

    Pointing to the 14th Amendment so as to confirm, ‘I am a citizen,’ based on claim to have been born in the U.S.A., is totally appropriate. (But saying in one spot, I am a NBC; and in another, I am a native; is problematic. Because even if the term NBC has not been identified by the federal courts; that still is the exact language of eligibility in the Constitution.) ADMINISTRATOR

    P.S. I also posted this comment on that other blog…

    Now that you know Justia is just a commercial web site that compiles other public information; and that, as a commercial enterprise, its decision to manipulate its web site in whatever way it sees fit, is completely commonplace; let me ask you. What do you suppose is the purpose of posting such alarmist warnings as, ‘Archive the web page because they are trying to hide this “dangerous” ruling’?

    and this…

    How many times does someone have to lead you astray before you start focusing your energies on fixing the system that elected the President you have determined does not belong in office? (And how many times does someone have to be right to given the benefit of your doubt? Keep in mind, even assuming Obama is Constitutionally ineligible to be POTUS; where in your state law does it say, Electors can only elect a President who is Constitutionally eligible for the job?

    and this…

    Believing in a false premise, that is, a legally binding definition of NBC exists; only allows you, as a citizen, to avoid doing the hard work to establish standards for ensuring Constitutionally eligible candidates run for federal office. It also allows you to relegate the hard work of fixing this system, to an internet pundit whose multiple infirm legal filings have been rejected, time and time again, by the court. And, when that happens, instead of rationally examining the basis for those rejections, only excoriates the court as part of some greater ‘conspiracy.’

    • kj says:

      jbjd,

      Thank you for your reply. I sorry that this is getting burdensome for you. I wrote my comment before you had updated your comments. I read Boyd vs. Nebraska on my own a couple of months ago and was not basing my comment on Leo’s post.

      Of course, one must be wary of what he/she finds on the web and most don’t look beyond what he/she considers a trusted site. It is unfortunate when a “trusted site” knowingly or unknowingly publishes misquotes that seek to rewrite the literature. Whether there is a conspiracy or not (Donofrio is known to be paranoid), there are dedicated Obama supporters who haunt every website that raises legitimate questions and presents real research. People who look for ways to twist the arguments to their favor in any way possible. People in high places, including one who posted on the web a poorly altered long form BC to thumb their noses at voters asking a legitimate question. I’m sure that his minions have been here trying to undo what you have spent so much time assembling.

      Thank you again for your legal work on the case of Mr. Obama.

      kj: My bad. FYI, I used the Justia site in my response to Mick, because he values that site sufficiently to credit any alteration of data there as part of the greater ‘conspiracy’ that many people believe is concealing the otherwise well-known ‘fact’ Barack Obama is not a NBC. But normally, I would not cite to Justia. That said, I do trust Cornell’s Legal Information Institute (“LII”) which I cite often.

      What ‘grief’ comes my way on this blog may or may not be inspired by underhanded motives. I cannot say who disguises his or her actual motivation with feigned sleights. For the most part, however, I find that my work both here and throughout the blogosphere is well received, on sites politically on the left and on the right, even when readers disagree with my point of view. ADMINISTRATOR

  6. bob strauss says:

    jbjd, I remember you said the BC posted by Factcheck was a campaign ad. Below is a link to a Factcheck claim that the BC is not a forgery. I was wondering, what are we to believe, is it an ad or is it a birth certificate?
    **********************

    WND has posted the CRS memo on Scribd.com for download.

    Attached to the memo was an attack piece published by FactCheck.org to dismiss claims that Obama’s short-form Certification of Live Birth, originally published during the 2008 presidential campaign by DailyKos.com, was a forgery.

    Read more: Senator: Constitution doesn’t define presidential eligibility (link to WND removed by “jbjd”)

    scribd.com/doc/41916222/BILBRAY-MEMO-2009-Jun-8-Bilbray-Fax-Re-CRS-Research-Redacted

    bob strauss: Isn’t anyone listening? The electronic image which is part of the “Fight the Smears” web site, is advertising copy, per the U.S. Code. See DE-CODER RINGS (1 of 2) and (2 of 2). The creator of at least one of the fake-out fake document, which was posted at some point on DK; says he posted this there to drive ‘birthers’ crazy. (I just read something about this guy from DK; links are all over the web. But as I do not advocate that people interested in establishing a President’s Constitutional eligibility for office waste their time dissecting electronic images over the internet; I will not provide links.) This does not mean, the same COLB posted on FTS/APFC was not at some point also posted on DK.

    I will not bother to read the linked Scibd post, although I did look at it in case the CRS memo could be verifiably sourced directly to CRS, with no detour through WND. But it could not. ADMINISTRATOR

    • bob strauss says:

      Are we in the midst of a coverup, by the president of the USA?

      What about the phony social security number Obama uses, and the FOIA requests Obama, and the SS Administration, ignores?

      The latest BC is a complete and utter forgery.

      Hawaii looks complicit in the birth certificate scheme to defraud the USA.

      The DNC looks complicit in this big scheme to put an unqualified Obama in office, even to the extent of trying to change the requirements, and the meaning of A2S1C5, which failed, in order to clear the path for a non natural born Obama, to circumvent the meaning of A2S1C5.

      Obama is a usurper, and everyone knows it. The son of a Kenyan, and the son of an Indonesian, is not on the list as a qualified, natural born Citizen.

      His presidency is unconstitutional, and the deficiency must be remedied.

      We also have two supreme court justices appointed by the (name omitted by jbjd), what about them?

      Any ideas, as to a remedy?

      bob strauss: Except for deleting the name-calling; I posted your comment, in total, notwithstanding 1) I disagree with so many of your ‘conclusions’; 2) your conclusions, whiled couched as such, have no basis in fact; and 3) the sources of your misunderstanding as to the ‘facts’ can easily be traced to a handful of other blogs/bloggers, not “jbjd.” I figure, you needed to see your frustration in print, on my blog, having posted these same sentiments on other blogs, where they only meet like-thinking posters, avoiding the critical analysis to which such information is subjected here.

      But at least one of your conclusions is really bothersome here, because we have spent too much time teaching and learning how our political system works to revert back to those pre-2008 days of ignorance. First, even assuming based on documentary evidence available in the public record, Barack Obama could be said to be Constitutionally ineligible for the job; he is still the legal President of the United States. That is, as I have pointed out several times, the process prescribed in the Constitution for electing him President – the vote for him by state Electors; the Congressional ratification of that vote; and his subsequent swearing in by the CJ of the SCOTUS – was followed.
      ADMINISTRATOR

  7. bob strauss says:

    jbjd, I am fanning the flames of liberty, “no person except a natural born Citizen” is very explicit language, anyone acting as president who is not a natural born Citizen is unconstitutional. This needs to be remedied, not ignored.

    bob strauss: Even assuming that, everyone else who reads these words agrees with you, the language is explicit, that is, it means exactly what you say it means, the citizens of none of our 50 states have enacted laws requiring Electors to elect only a President who meets that determined eligibility for the job. And you miss the point of the 14th Amendment, anyway, which is to codify the entitlement of “privileges and immunities” to all U.S. citizens alike, as ‘citizen of the U.S.’ as opposed to ‘citizen of a state,’ which had previously left ‘citizens’ in Washington, D.C., for example; or ‘citizens’ called slaves, without traditional rights as citizens. Thus, saying one is a citizen under the 14th Amendment means, according to the codification of the requirements for the first time explicitly spelled out in the Constitution, anyone born here under the jurisdiction of the U.S. or, naturalized; is a citizen.

    In other words, regardless of the status of citizenship enjoyed by your parents, you are a citizen. Sure, the Constitution explicitly lists a unique category of citizen eligible to be President – NBC – but, nowhere else in the Constitution is that word defined. Recall that the Minor court used the terms “native” and “natural born” interchangeably, reasoning that, even before the Constitution clarified through the 14th Amendment that anyone born here is a citizen of the U.S. (entitled to the same “rights and privileges”); ‘authorities’ unanimously agreed, given her particular circumstances, Minor was a citizen. (Do you get that, before the 14th Amendment, people born in Washington, D.C., of 2 citizen parents, were mistakenly thought not be citizens because the common misunderstanding was that citizenship was tied to statehood and not ‘United States ‘hood’?) ADMINISTRATOR

    • bob strauss says:

      We have seen nothing but forgeries from the Obama camp, nothing but images, no real documents that prove he was born anywhere. US Citizens born before and after Obama have no trouble coming up with identification. Why is this guy special? Something is not Kosher.

      bob strauss: I have no idea what you are talking about. You cannot establish, for example, what documentation the President has produced as required to satisfy state or federal laws. And he was not required to produce any such documents in order to ‘run’ for office, under any federal or state laws!

      In addition, as I have been painstakingly trying to teach you, campaign advertising or blogs can say whatever they want. Did anyone submit what would otherwise have been considered an official document directly from the issuing authority, to any public official, which you are alleging was tampered with or altered? If not then, you are obsessed with a commercial. ADMINISTRATOR

  8. bob strauss says:

    Eight separate attempts to change the requirement that the president, and presidential candidates must be natural born Citizens. Born from Citizen parents.

    Why would they have to change anything if Obama was already eligible, as they contend?

    youtu.be/H3aCfR8rmrw

    bob strauss: I cannot look at a YouTube video as evidence of anything. And trying to change the Constitution, even if it did occur, could mean that someone else besides those of us associated with this blog are seeking a way to codify the definition of “NB,” now that the 14th Amendment fixed what is the definition of “C.” ADMINISTRATOR

  9. bob strauss says:

    jbjd this is from Leo Donfrio’s site, I sent him your post for clarification.

    bob strauss Says:
    July 2, 2011 at 2:15 PM

    Leo, jbjd seems to disagree with your opinion of Minor v Happersett, could you clear up any differences and set the record straight.

    UPDATE: Please read my Comment below, containing an excerpt from the Supreme Court’s ruling in the Slaughterhouse Cases, which emphasizes this point with relation to the 14th Amendment’s language on citizens. In short, if the 14th Amendment can be said to be conferring citizenship rather than merely codifying those definitions already understood in law and practice then, it does so only by establishing the distinction between the rights accruing to citizens as citizens of the U.S.A. which rights are now uniform; versus the rights of citizens as citizens of the states (in which they reside), which vary according to the state.

    © 2011 jbjd

    No legally binding definition exists of the phrase “natural born citizen” as written in Article II, section 1 of the U.S. Constitution; and no such definition will be forthcoming until a federal appeals court, including the U.S. Supreme Court, rules, this is the definition, in the holding of a case or controversy directly on point, that is, one which requires the court to formulate such definition so as to reach resolution of the matter properly before the court.

    I have said this a ‘million’ times, with only slight variation, since I began blogging in 2008. And, as I have also indicated, for a couple of reasons, at this point, that is, now that President Obama has been elected; I couldn’t care less whether he is a NBC; and I have been saying this for a long time, too. What difference does it make whether he is a NBC when we enacted no laws that required our state Electors to elect only a President who is Constitutionally eligible for the job! (This would explain my insistence that present calls for Impeachment cannot be predicated only on his Constitutional ineligibility for office.) And, regardless of the absence of documentary evidence available in the public record that, he is even a C, which status certainly was well defined and accepted by the aforementioned legal authorities even before this definition was codified in the 14th Amendment for the purpose of qualifying who is entitled to “privileges and immunities”; it appears true that, millions of my fellow citizens who voted for (Electors for) the man, could not have cared less whether he is a NBC, either, even before his election. Read more.
    https://jbjd.org/

    ed. She’s wrong, again. Obviously, Obama’s minions are out there scrubbing SCOTUS cases online from before the election because they saw it before we did. But stay tuned for more legal analysis on this issue. – Leo

    bob strauss: The last time I disagreed with Leo, he sent nasty emails, which I posted here on the blog. Saying I am “wrong, again” does not mean, insofar as I disagree with Leo, I was ever wrong, in the past; or that he provided sound evidence, I was wrong. (Notice, I don’t require irrefutable evidence, but just a rational basis.) As some of the several critiques of his work I have posted throughout this blog will attest – do a search, in the sidebar – when Leo says, I am wrong; this merely means, I, along with the legal authorities I have cited, disagreed with him. (You can use Leo & federal declaratory judgment; or Leo & quo warranto; or Leo & mandamus, etc.) ADMINISTRATOR

    • bob strauss says:

      I would like to see jbjd, and Leo Donofrio work together to help rectify the issue of the Constitution, Obama, and NBC.

      There must be a legal remedy in place for removing a usurper.

      bob strauss: We are all working together to perfect our government, who contribute to this blog. Surely you must realize, many of my ideas derive from collaboration with my readers; because I explicitly say so! ADMINISTRATOR

      • bob strauss says:

        Someone might have taken your advise.

        thepostemail.com/2011/07/07/atty-orly-taitz-files-motion-to-compel-in-social-security-case/

        bob strauss: I am not giving any other lawyers, legal advice here. I only explain the rules to lay people who, unfortunately, even now appear to be susceptible to the extremely poor ‘lawyering’ practiced by ‘birther’ professionals who sustain a cottage industry by duping an uninformed public, however unintentionally, into buying into the lie that this next ‘legal’ gambit, or that, will ‘blow the eligibility issue wide open.’ Followed by the perfunctory plea for funds.

        No court of law will grant a Motion to Compel production of social security numbers by the HI DoH or any state agency, submitted by a private party with no cognizable interest in those numbers that would cause the court to pierce confidentiality.

        And, FYI, everyone involved in these legal cases is operating ‘after the fact’ when it comes to my work, inasmuch as I am the first person, for example, who proposed standing in federal court (for those who sought relief of eligibility questions through the court) could be obtained through a federal Declaratory Judgment case using about-to-be-recalled military (national guard) (without jeopardizing the status of the Plaintiffs), in the fall of 2008; and who pointed to the use of state election laws to ensure the eligibility of elected officials, in August 2008. But while people ran with the idea of military plaintiffs; they changed the conditions, for example, using men not likely to be subject to recall. And none of these so-called patriots gathered their minions in the applicable states to petition state A’sG to exercise their discretion to investigate citizen complaints of election fraud.

        You can guess why. ADMINISTRATOR

        • bob strauss says:

          Will Taitz get the birth certificate, and SS-5 form for Obama, if the court compels the SSA, Fuddy and Onaka?

          bob strauss: While I usually grant all hypotheticals – after all, your guess is as good as mine – in this case, assuming the judge is sane at the time of the ruling, any Motion to Compel will be denied.

          The case that could result in production of the bc is an estoppel or unjust enrichment case brought against Obama and joining the HI DoH, that is, argue that he can no longer cling to privilege/confidentiality in requiring the DoH not to breach these rights, now that he has posted ‘facsimiles’ on line and claimed these are real, admittedly so as to quell doubts as to his citizenship status. (I first proposed this legal option in the summer of 2008, in an email to Andy Martin, whom I knew nothing about at that time except that, he had filed a suit to get the document based on a frivolous claim that, assuming Obama would be elected President, this bc would then be an historical document.) ADMINISTRATOR

  10. […] it does not. And I have explained several times, it does not. For example, see SENSE and non-SENSE, relying on such sources such as the Legal Information Institute of Cornell University School of […]

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