by Joseph DeMaio, ©2024
(Apr. 8, 2024) — [See the previous installments in this series here and here.
The writer first presents text from Paul Clement and Neal Katyal’s 2015 subject essay followed by his own commentary in bold, indented text. Page breaks in the original C&K text are indicated in brackets.]
Deep Dive Part 3
“While the field of candidates for the next presidential election is still taking shape, at least one potential candidate, Senator Ted Cruz, was born in a Canadian hospital to a U.S. citizen mother.15 Despite the happenstance of a birth across the border, there is no question that Senator Cruz has been a citizen from birth and is thus a “natural born Citizen” within the meaning of the Constitution.
[Again, this statement is simple ipse dixit based only on the manufactured narrative that “it is so because they say it is so.” The use of the term “happenstance” seems to have as its primary goal the trivializing and marginalizing of the fact that someone was born outside of the geographic boundaries of the United States.
[In point of fact, birth “in” the country is a sine qua non requirement of the definition of a natural born citizen in § 212 and was of central concern as well to the Founders, as corroborated by their inclusion of the “Citizen-grandfather” clause as an exception to the highly restrictive nbC eligibility clause.]
Indeed, because his father had also been resident in the United States, Senator Cruz would have been [subjunctive mood, relating to a hypothetical rather than actual situation] a “natural born Citizen” even under the Naturalization Act of 1790….
[But in any event, not after the January 29, 1795 repeal of 1 Stat. 103 by 1 Stat. 414, when the “natural born” adjective modifier of “citizens” was intentionally repealed. It was not accidentally “dropped” or discarded as only a “stylistic” change as suggested by the CRS and thereafter making persons born abroad to U.S. citizen “parents,” in the plural, “citizens” only, and not “Citizens” with an upper-case “C.”]
…. Similarly, in 2008, one of the two major party candidates for President, Senator John McCain, was born outside the United States [163 // 164] on a U.S. military base in the Panama Canal Zone to a….
[This is inaccurate by omission: both of John McCain’s parents were U.S. citizens when he was born. Accordingly, the sub rosa intimation that only one of McCain’s parents – “a” mother – was a citizen sufficient to bestow purported nbC status – like the situation of Senator Cruz – is misleading.]
…. U.S. citizen parent.16 Despite a few spurious suggestions to the contrary, there is no serious question that Senator McCain was fully eligible to serve as President, wholly apart from any murky debate about the precise sovereign status of the Panama Canal Zone at the time of Senator McCain’s birth.17 ….
[As to the assertion that John McCain was born to “a” U.S. citizen parent, while true that his mother, who actually gave birth, was a U.S. citizen when he was born, so too was his father. The suggestion that McCain otherwise satisfied the nbC definition despite only one parent being a citizen is misleading.
[As for the “murky debate” over the status of the Canal Zone, again, like the marginalizing of the “happenstance” that Senator McCain was born in a place other than “in the United States,” as required under § 212, the clouding of the issue with adjectives like “murky” is of little assistance in resolving precisely what the Founders intended in adopting the nbC term into the Constitution.
[As to the claim that there is “no serious question that Senator McCain was fully eligible to serve as President…,” the authors might wish to look closer into the record and decision in Hollander v. McCain. There, the court noted that its decision to deny relief and dismiss the plaintiff’s complaint was based on a lack of “standing” in the plaintiff, Fred Hollander, adding that “[t]he court does not reach the rest of the parties’ arguments, including, most notably, the question of McCain’s constitutional eligibility to be President.” (Emphasis added) If there are other sources for the claim that “no serious question” existed regarding Senator McCain’s purported eligibility, it would help if they were disclosed in the article.]
…. Indeed, this aspect of Senator McCain’s candidacy was a source of bipartisan accord. The U.S. Senate unanimously agreed that Senator McCain was eligible for the presidency, resolving that any interpretation of the natural born citizenship clause….
[As to the manufactured neologism ”natural born citizenship clause,” there is no such thing as the “natural born citizenship clause” in the Constitution. The purported “natural born citizenship” phrase is a neologism that appears nowhere in any U.S. Supreme Court case, as discussed here.
[Any mislabeling of Art. 2, § 1, Cl. 5 as such is an improper way of attempting to equate or analogize it to the term “citizenship” as defined under federal statutory law as well as under the 14th Amendment as construed in the Wong Kim Ark case. In addition, Senate Resolution 511, (cited by C&K in footnote 18, post) remains fatally flawed, as discussed here.
[Aside from the fact that a Senate resolution can express only the “sentiment” of the body and carries zero precedential or legal weight, S. Res. 511 is premised, in large part, on the false notion that the “rationale” of 1 Stat. 103 – stating that persons born “beyond sea” to U.S. citizen parents were considered to be nbC’s – persists to the present day despite the provision having been repealed in 1795 (not re-enacted “in the same words,” as Justice Gray claimed in WKA in 1898), and has never thereafter been included in any congressional enactment regarding naturalization.]
…. as limited to those born within the United States was “inconsistent with the purpose and intent of the ‘natural born Citizen’ clause of the Constitution of the United States, as evidenced by the First Congress’s own statute defining the term ‘natural born Citizen.’”18 ….
[To reiterate, the assertion that 1 Stat. 103 “defined” the nbC term is manifestly wrong. While the statute categorized certain individuals as being “considered” as natural born citizens, it made no attempt to define the term. Any contention to the contrary is clearly without support and inaccurate.
[In addition, regarding the statements in S. Res. 511 that “there is no evidence of the intention of the Framers or any Congress to limit the constitutional rights of children born to Americans serving in the military nor to prevent those children from serving as their country’s President…” and adding that “such limitations would be inconsistent with the purpose and intent of the ‘‘natural born Citizen’’ clause of the Constitution of the United States, as evidenced by the First Congress’s own statute defining the term ‘‘natural born Citizen…,’’ several comments are necessary.
[First, while there may be no Founders’ expression of intent to “limit” or “preclude” such persons from eligibility, there is also no expression of intent to ratify such eligibility in a way that is inconsistent with the Constitution’s nbC clause.
[Moreover, while the resolution addresses the “military” question both in terms of the parents’ service in the armed forces as well as such service “outside of our national borders” and adds that other presidential candidates born outside of our borders “were understood to be eligible…,” that does not suffice to establish, in actuality under the Constitution, that it is what the Founders intended.
[This is yet another reason supporting the conclusion that by enacting 1 Stat. 414, Congress sought to correct the error in 1 Stat. 103 erroneously asserting that children born to U.S. citizen parents abroad were only to be “considered” – as contrasted with being declared – “actual” nbC’s.
[Second, to reiterate, 1 Stat. 103 did not define the nbC term: instead, it only categorized certain people as being “considered” as being such. The only “definition” of the nbC term utilizing the word “citizen” – as opposed to a “subject” extracted from British common law – which was available and known to the Founders in 1787 was that set out in § 212.
[The non-sequitur trope that the Founders merely intended to substitute the word “citizen” for the word “subject” in purportedly adopting the nbC term in the Constitution is illogical. To contend that the Founders – having then recently thrown off the oppressive British yoke of “subject/liege” in favor of “citizen/republic” – would nonetheless adopt a British common law definition of nbC reinstituting the principles of a subservient “subject” through grammatical legerdemain makes no sense.
[Third, on the other hand, it can rationally be argued that children born to U.S. citizens who are serving in the United States military abroad – a circumstance virtually unknown to the Founders and certainly not reasonably foreseen or foreseeable by them in 1787 – ought to be treated as a special class also eligible to the presidency. Their parents’ allegiance and fidelity to the United States, particularly in an era of voluntary military service, cannot reasonably be challenged.
[However, in order to accomplish that goal – arguably, a laudable one – the solution is a formal constitutional amendment and not a “resolution” lacking the force of law. This is particularly so when the resolution relied upon to support Senator McCain was fatally flawed from the outset as being conceptually premised on the discarded rationale of a statute that Congress had entirely repealed 213 years earlier.
[Indeed, such a constitutional amendment could serve the same practical and salutary function today as did the “Citizen-grandfather” clause when added to the nbC provision in 1787. Moreover, not only would such an amendment likely be widely supported, ensuring swift ratification by the required 38 states, it would adhere to the Constitution’s Article V requirement dictating that alterations in the Constitution should be the result of formal amendments rather than Congressional resolutions, incompatible statutes or the isolated pontifications of academics and other extra-judiciary “experts.”]
…. And for the same reasons, both Senator Barry Goldwater and Governor George Romney were eligible to serve as President although neither was born within a state. Senator Goldwater was born in Arizona before its statehood and was the Republican Party’s presidential nominee in 1964,19 and Governor Romney was born in Mexico to U.S. citizen parents and unsuccessfully pursued the Republican nomination for President in 1968.20
[To reiterate, there has never been a Supreme Court decision “on the merits” addressing the nbC question in the context of a sitting president (or vice-president), and certainly not in the cases of Senator Goldwater or Governor Romney.
[This is why the issue is still being debated, although the currently-accepted narrative that one need only be born a citizen – whether here or anywhere on the planet “by happenstance” under the C&K view – has many adherents. That theory requires a much relaxed historical and legal analysis and posits, at the end of the day, that “it is close enough for government work.” The Founders likely would not agree.]
“There are plenty of serious issues to debate in the upcoming presidential election cycle. The less time spent dealing with specious objections to candidate eligibility, the better. Fortunately, the Constitution is refreshingly clear on these eligibility issues. ….
[The manufactured “refreshingly clear” descriptor makes sense only if it means “obscure” or “opaque.” Again, it is regrettable that two former Solicitors General must deploy such inconsistent language in an effort to drive home a highly debatable point. There is nothing “specious” about objections to a presidential candidate’s constitutional eligibility bona fides, particularly in the absence of a Supreme Court decision directly on point, the ex-cathedra bona fides of the authors aside.
[Moreover, if, as claimed by the authors, the Constitution itself is “refreshingly clear on these eligibility issues,” they should offer an explanation for the Supreme Court’s contrary finding in Minor that “the Constitution does not, in words, say who shall be natural-born citizens. Resort must be had elsewhere to ascertain that.” Ipse dixit founded on careless language that Congress identified in 1 Stat. 103 and repealed in 1 Stat. 414 229 years ago is not, respectfully, “close enough for government work.”
[Again, and tellingly, the C&K authors ignore altogether the de Vattel treatise, which provides “elsewhere” than the Constitution, in § 212 of the tome, the precise “words” the Court in Minor found to be missing in the founding document. In addition, the term “specious” is defined as “having a false look of truth or genuineness.”
[Against the backdrop of the Founders’ overriding goal of establishing a higher, rather than lower, barrier to the potential for insinuation of foreign influence into the presidency, it makes no sense at all to contend, without analysis, that the lower barrier presented by a “citizen at/by birth” standard – regardless of place of birth and citizen status for both parents – was intentionally selected by the Founders.
[Such an argument would also run directly contrary to Justice Story’s observation that the Founders’ goal in selecting the nbC restriction was to “cut off all chances for ambitious foreigners…” to insinuate themselves into the presidency. The term “all” does not mean “some” or “a few” chances, which latter terms are inherent in the “citizen at/by birth” theory of nbC bona fides. Stated otherwise, the term “all” encompasses the totality of relevant elements, not just “some” or a “few.” This is not a situation where one needs to parse what the meaning of “all”… is.
[In fact, the C&K article’s citation to Justice Story’s “cut off all chances…” quote in and of itself alone eviscerates the article’s contention that only one parent need be a citizen at the time of the child’s birth. This is plainly so because the other “foreign” or “non-citizen” parent would, under jus sanguinis (law of blood or descent) principles, automatically inject “some” or even a “50%” likelihood of foreign influence being insinuated into the person who would serve as the president.
[Furthermore, that foreign citizen’s nation – say, Argentina – could then, quite apart from the position taken by the child or, in fact, the Unites States, plausibly make the argument that the child was, at minimum, part Argentinian. This potential would never have been acceptable to the Founders, yet it is advanced as being entirely consistent with the “citizen at/by birth” theory of the C&K article.
[In addition, the term “spurious” is defined as “forged or of falsified or erroneously attributed origin.” Neither of those terms are properly applied to the argument that, as intended by the Founders, a “natural born Citizen” was a person born in the United States to two parents, both of whom were at the time of birth U.S. citizens.
[This is consistent, rather than at variance, with the definition of the term set out in § 212. The marginalization of de Vattel by C&K – again, neither he nor his treatise are even mentioned, even in passing, in the article – is regrettable. Even the WKA “holy grail” decision – hailed by “de Vattel Deniers” as “settling” the nbC issue (hint: no, it doesn’t) – cites and discusses de Vattel as well as § 212.]
…. To serve, an individual must be at least thirty-five years old and a “natural born Citizen.” Thirty-four and a half is not enough and, for better or worse, a naturalized citizen cannot serve. But as Congress has recognized since the Founding, a person born abroad to a U.S. citizen parent is generally a U.S. citizen from birth with no need for naturalization. And the phrase “natural born Citizen” in the Constitution encompasses all such citizens from birth.
[This bald statement constitutes plain and simple ipse dixit and is fundamentally at odds with both logic and the historical record.]
Thus, an individual born to a U.S. citizen parent — whether in California or Canada or the Canal Zone — is a U.S. citizen from birth and is fully eligible to serve as President if the people so choose.” (End of C&K article)
[Respectfully…, there is another interpretation which your servant posits is far more consistent with the history of the Eligibility Clause, the principles of § 212 and, of greatest importance, the intent of the Founders.]
Deep Dive Conclusion
All of the foregoing verbiage aside – from the arguments of two very smart former officials of the Solicitor General’s Office to those of your humble servant – the end resolution of the nbC question lies either in a binding decision of the Supreme Court or a ratified amendment of the Constitution. Neither of those two solutions seems likely in the near term, lamentably, because the vast majority of the body politic is simply indifferent to the issue. So the debate will continue. Move along…, nothing to see here. Sad.
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FOOTNOTES:
∗ Distinguished Lecturer in Law, Georgetown University; Partner, Bancroft PLLC. ∗∗ Paul and Patricia Saunders Professor of Law, Georgetown University.
1 U.S. CONST. art. II, § 1, cl. 5.
2 See, e.g., 8 U.S.C. § 1401(g) (2012); Immigration and Nationality Act of 1952, Pub. L. No. 82-414, § 303, 66 Stat. 163, 236–37; Act of May 24, 1934, Pub. L. No. 73-250, 48 Stat. 797.
3 See Smith v. Alabama, 124 U.S. 465, 478 (1888).
4 See Wisconsin v. Pelican Ins. Co., 127 U.S. 265, 297 (1888). 162 HARVARD LAW REVIEW FORUM [Vol. 128:161
5 See United States v. Wong Kim Ark, 169 U.S. 649, 655–72 (1898).
6 7 Ann., c. 5, § 3 (1708); see also British Nationality Act, 1730, 4 Geo. 2, c. 21.
7 See 1 WILLIAM BLACKSTONE, COMMENTARIES *354–63.
8 Ch. 3, 1 Stat. 103 (repealed 1795).
9 Id. at 104 (emphasis omitted).
10 See Christina S. Lohman, Presidential Eligibility: The Meaning of the Natural-Born Citizen Clause, 36 GONZ. L. REV. 349, 371 (2000/01).
11 See, e.g., British Nationality Act, 1730, 4 Geo. 2, c. 21. 2015] ON THE MEANING OF “NATURAL BORN CITIZEN”
12 Letter from John Jay to George Washington (July 25, 1787), in 3 THE RECORDS OF THE FEDERAL CONVENTION OF 1787, at 61 (Max Farrand ed., 1911).
13 3 JOSEPH STORY, COMMENTARIES ON THE CONSTITUTION OF THE UNITED STATES § 1473, at 333 (1833).
14 See Michael Nelson, Constitutional Qualifications for President, 17 PRESIDENTIAL STUD. Q. 383, 396 (1987).
15 See Monica Langley, Ted Cruz, Invoking Reagan, Angers GOP Colleagues But Wins Fans Elsewhere, Wall St. J. (Apr. 18, 2014, 11:36 PM), http://www.wsj.com/articles /SB10001424052702303873604579494001552603692. 164 HARVARD LAW REVIEW FORUM [Vol. 128:161
16 See Michael Dobbs, John McCain’s Birthplace, WASH. POST: FACT CHECKER (May 20, 2008, 6:00 AM), http://voices.washingtonpost.com/fact-checker/2008/05/john_mccains_birthplace .html [http://perma.cc/5DKV-C7VE].
17 See, e.g., Laurence H. Tribe & Theodore B. Olson, Opinion Letter, Presidents and Citizenship, 2 J.L. 509 (2012).
18 S. Res. 511, 110th Cong. (2008).
19 See Bart Barnes, Barry Goldwater, GOP Hero, Dies, WASH. POST, May 30, 1998, http://www.washingtonpost.com/wp-srv/politics/daily/may98/goldwater30.htm [http://perma.cc/K2MG -3PZL].
20 See David E. Rosenbaum, George Romney Dies at 88; A Leading G.O.P. Figure, N.Y. TIMES, July 27, 1995, http://www.nytimes.com/1995/07/27/obituaries/george-romney-dies-at-88-a -leading-gop-figure.html
Author – “Commenter Leland, …overlooks the conclusion of Blackstone that in order to serve on the British Privy Council – the highest office of trust below royalty in England – a person must be born a subject to two British subject parents, not one. See 1 Blackstone’s Commentaries on the Laws of England at 230.”
This is incorrect. Here is the relevant section of Blackstone on the qualifications to be on the Privy Council;
” AS to the qualifications of members to fit this board: any natural born subject of England is capable of being a member of the privy council; taking the proper oaths for security of the government, and the test for security of the church. But, in order to prevent any persons under foreign attachments from insinuating themselves into this important trust, as happened in the reign of king William in many instances, it is enacted by the act of settlement, that no person born out of the dominions of the crown of England, unless born of English parents, even though naturalized by parliament, shall be capable of being of the privy council.”
To summarize the qualifications of Privy Council membership:
1) any natural born subject of England can be a member
2) provided if the person is “born out of the dominions of the crown of England” the person must be born to English parents even if naturalized by parliament.
Blackstone told us what is a natural born subject – “THE children of aliens, born here in England, are, generally speaking, natural-born subjects, and entitled to all the privileges of such.” See 1 Blackstone’s Commentaries on the Laws of England at 373.
To the English birth in the dominion made a person a natural born subject even if their parents were aliens. They believed this isolated the person from foreign influences. That may not be what we believe today but it is what the English believed in the late 1700s. All the evidence is the Founders believed the same thing as the English.
Response from the author:
————————————
There he goes again.
Commenter Leland focuses on his disagreement with what your servant contends Blackstone said regarding the British Privy Council and not the core question posed. In any event, that which the commenter ascribes to Blackstone regarding eligibility to the British Privy Council completely eviscerates the conclusion of the Clement and Katyal 2015 article. That conclusion was that Senator Ted Cruz, born in Calgary, Alberta Canada to a mother who may have been, at the time, a U.S. citizen, but whose father was not a U.S. citizen, was an nbC eligible to the presidency.
The commenter’s irrelevant disagreement aside – and for the benefit of the commenter and others interested in the issue – the question posed, which remains both unaddressed and unanswered, of course, is this:
“Why would the Founders have adopted the lower and inferior definitional barrier to foreign influence inherent in the “citizen at/by birth” theory instead of the higher superior barrier afforded by § 212?”
This is not a complex question, but the “de Vattel Deniers,” including the commenter, seem to be perpetually confused and flummoxed when faced with the task of cobbling together a response, any response, much less a logical, rational answer.
Accordingly, one is left to conclude that the commenter and other de Vattel Deniers lack a contrary, logical or rational answer and therefore must be seen to have conceded that the Founders adopted the higher, superior definitional barrier of a “natural born citizen” articulated in de Vattel’s § 212. It is about time.
Interestingly, commenter Leland asserts in an earlier response to a reply by CDR (Ret) Charles Kerchner here that “[t]here is no evidence that Vattel was the source of the term [‘]natural born Citizen[’] in either Jay’s letter or the Constitution.”
Additional question to commenter Leland: “You mean no evidence other than precisely the same words of de Vattel in § 212, utilizing the word “citizen” (English) and “citoyens” (French) as opposed to “subject” (English) or “sujets” (French)? Is that the “no evidence” to which you refer?
Class dismissed.
Response to CDR Kerchner (Ret)
Maryland’s Constitution of 1776 had the following clause;
“III. That the inhabitants of Maryland are entitled to the common law of England, …and to the benefit of such of the English statutes, as existed at the time of their first emigration, and which, by experience, have been found applicable to their local and other circumstances, and of such others as have been since made in England, or Great Britain, and have been introduced, used and practiced by the courts of law or equity”
https://avalon.law.yale.edu/17th_century/ma02.asp
In 1779 Maryland passed an Act of naturalization with the following:
“That every person who shall hereafter come into this state …shall thereupon and thereafter be deemed, adjudged and taken, to be a natural born subject of this state; provided that no person who shall become a natural born subject of this state by virtue of this act, shall be appointed to any civil office …”
https://www.google.com/books/edition/The_Laws_of_Maryland_1692_1785/vC5EAAAAYAAJ?hl=en&gbpv=1&bsq=natural%20born%20subject
In 1797, they fixed “person who shall hereafter come into this state”.
An Act for the benefit of certain foreigners who emigrated and settled in this state before the act for naturalization
“Whereas doubts are entertained whether foreigners, who emigrated to this state previously to the session of assembly begun and held at the city of Annapolis on Thursday the twenty-second day of July, in the year one thousand seven hundred and seventy-nine, at which the act, entitled, An act for naturalization, was passed are entitled to the benefits of said act”
“Be it enacted, by the General Assembly of Maryland, That all foreigners, who emigrated and settled within the limits of Maryland before the said twenty-second day of July, in the year one thousand seven hundred and seventy-nine, …shall be deemed, construed and taken to have been, and they are hereby declared to have been, and to be, respectively, citizens of this state, and to have been, and to be, entitled to all and singular the immunities, privileges, rights and advantages, of natural born citizens, to all intent and purposes whatsoever …”
https://www.google.com/books/edition/The_Laws_of_Maryland/U440AQAAMAAJ?hl=en&gbpv=1&bsq=natural%20born
They went from using the term natural born subject to natural born citizen without ever having to explain what the difference was. They didn’t have to because everyone already knew what it meant to be natural born.
Mr. Leland:
You are being evasive in answering a direct question to you. I asked you what YOUR understanding is, you personally, not what the then new state of Maryland’s Constitution wordings were. Other states’ governing documents and state Supreme Court rulings back then disagreed with what Maryland’s Constitution wordings were about British Common Law. For example see this report about the Commonwealth of Pennsylvania’s rulings on what the understanding and meaning of the the term “natural born Citizen” was. They cited Emmerich de Vattel. See pages 18-27 of this report to the state legislature of Pennsylvania prepared in 1817: https://archive.org/details/digestofselectbr00robe
So, in the pronoun correct word-smith world of the far-left, in the language manipulating region of our nation abutting Maryland, the District of Wokestan and its native language of Newspeak which you are either participate in or have a great affinity for, I still think your answer to my question should hopefully be using the pronoun “I” in your answer.
Is that pronoun still in your Wokestan Newspeak vocabulary? So for a second time I am asking you for YOUR personal answer to my question. I repeat it here for your convenience:
“Punctuation aside for the moment, what is your understanding as to the meaning and definition of the “natural born Citizen” term as it relates to birth location and the citizenship status of both of the parents when their child is born?”
CDR Charles Kerchner (Ret)
Author: Natural Born Citizen
http://www.kerchner.com/books/naturalborncitizen.htm
CDR Kerchner – “You are being evasive in answering a direct question to you. I asked you what YOUR understanding is, you personally”
I would have thought that was obvious from my response. There is no evidence that Vattel was the source of the term natural born Citizen in either Jay’s letter or the Constitution. There is evidence that the Founders used both terms natural born subject and natural born citizen interchangeably. I personally subscribe to the notion that natural born citizen was derived from the English Law concept.
CDR Kerchber – “see this report about the Commonwealth of Pennsylvania’s rulings on what the understanding and meaning of the the term “natural born Citizen” was.”
Pennsylvania legislature passed an act in January 1777 that incorporated English Common Law and statute law into the state. See link starting on page 29.
https://www.google.com/books/edition/Laws_of_the_Commonwealth_of_Pennsylvania/k9owAQAAMAAJ?hl=en&gbpv=1&dq=The+common+law+and+such+of+the+statutes+of+England+as+were+in+force+in+the+Province+of+Pennsylvania+on+May+14,+1776&pg=PA432&printsec=frontcover
Response from Joseph DeMaio:
—————————-
Apart from failing to address and answer CDR (Ret) Kerchner’s question, commenter Leland states: “In 1779 Maryland passed an Act of naturalization…” which provided that “every person who shall hereafter come into this state …shall thereupon and thereafter be deemed, adjudged and taken, to be a natural born subject of this state….”
So what?
First, the fact that, prior to the execution and ratification of the U.S. Constitution – ahem, the “supreme Law of the Land…; any Thing in the Constitution or Laws of any State to the Contrary notwithstanding…, – individual states of the union may have cobbled together their own concepts of what the term “natural born” or “natural born Citizen” (“nbC”) may have meant to them is, to vastly understate the matter, immaterial as well as fatuous.
Stated otherwise, that which Maryland’s legislature deemed proper would fall by the wayside in any conflict with the U.S. Constitution.
Second, the commenter continues quoting from a Google copy of the laws of Maryland which includes this: “provided that no person who shall become a natural born subject of this state by virtue of this act, shall be appointed to any civil office …”
Oddly, the commenter substitutes an ellipsis for words omitted in the Maryland law after the word “office.” This seemingly replicates the tactics of the Congressional Research Service (“CRS”) when executing the “Elg Ellipsis” discussed here. The rest of the language from the Maryland law omitted by the commenter and applying to people who, despite being “naturalized” under the Maryland law as purported nbC’s – an intellectual non sequitur if ever there were one – were prohibited from being appointed to any civil office – or legally eligible to same – included: the chief executive of the state, the Governor of Maryland. If you doubt it, go check the Google link.
Finally, the commenter ignores the fact that the Maryland laws, including their amended versions, are state-limited naturalization laws restricted in their application to the State of Maryland. They had no force or effect in Rhode Island, Pennsylvania or Virginia, particularly after the ratification of the Constitution in 1790. They may have been interposed (as the commenter does here) as purportedly being “persuasive,” but outside of Maryland, while they may have been interesting to some, they were plainly not binding on the residents in Providence, Philadelphia or Richmond.
If the Maryland legislature determined for whatever reason to adopt its own curious localized definition of a “natural born subject,” a “natural born citizen” or for that matter, a “natural born refrigerator,” it was free to do so. But against Art. 2, § 1, Cl. 5 of the Constitution, the latter document prevails.
Author – “Oddly, the commenter substitutes an ellipsis for words omitted in the Maryland law after the word “office.””
The author misses the big picture. Maryland law matched English law on naturalizations. As Blackstone said “NATURALIZATION cannot be performed but by act of parliament: for by this an alien is put in exactly the same state as if he had been born in the king’s ligeance; except only that he is incapable, as well as a denizen, of being a member of the privy council, or parliament, &ci. No bill for naturalization can be received in either house of parliament, without such disabling clause in it” Book 1 Page 374
https://www.google.com/books/edition/Commentaries_on_the_Laws_of_England/eK4WAAAAQAAJ?hl=en&gbpv=1&dq=blackstone+commentaries&printsec=frontcover
Maryland adopted the same law. The case of Jonathan Hager in 1771 confirms this. Beginning on page 21 of the Society for the History of Germans in Maryland.
https://www.google.com/books/edition/Report_Society_for_the_History_of_the_Ge/rg1JAQAAMAAJ?hl=en&gbpv=1&bsq=natural%20born%20
Author – “If the Maryland legislature determined for whatever reason to adopt its own curious localized definition of a “natural born subject,” a “natural born citizen” or for that matter, a “natural born refrigerator,” it was free to do so.”
One of the pro-Vattel folks arguments is that the Framers did not have to tell people the meaning of the term natural born citizen because they already knew what it meant. But if each state had their own “curious localized definition” someone would have to explain to them what the new Constitution meant by it.
Maybe John Jay was using Maryland’s definition or one similar to it like Connecticut’s or Massachusetts’.
Reply from the author:
———————————-
One of the mildly irritating, yet simultaneously amusing facets of “de Vattel Denier” comments appearing here at The P&E, is their consistent and universal refusal to answer core, fundamental questions. In true Alinsky Rules for Radicals fashion, they deflect and instead focus on irrelevancies, bulking them up with words having no apparent goal other than linguistic volume.
Commenter Leland completely misses the point regarding the ellipsis omission pointed out in your humble servant’s prior response. Even in Maryland, a person arriving there and undergoing the “naturalization” process of state law was still declared to be ineligible to serve as that state’s chief executive: the Governor. Like the Congressional Research Service, that not-insignificant detail of state law was intentionally omitted from the comment. Under this same rationale – and apart from the fact that a naturalized U.S. citizen is also ineligible to serve as president – the natural born Citizen (“nbC”) clause of the Constitution highly restricts eligibility to the office.
Commenter Leland, although citing British legal scholar Sir William Blackstone for another purpose, overlooks the conclusion of Blackstone that in order to serve on the British Privy Council – the highest office of trust below royalty in England – a person must be born a subject to two British subject parents, not one. See 1 Blackstone’s Commentaries on the Laws of England at 230. This “two parent” requirement lies at the heart of both England’s Privy Council protocols as well as § 212 of Book 1, Ch. 19, The Law of Nations, by Emer de Vattel (“§ 212”).
The “citizen at birth” and “citizen by birth” theory advanced by Messrs. Clement and Katyal in their 2015 article regarding the nbC issue flatly rejects that requirement. But in doing so, it also advances the irrational conclusion that the Founders consciously and intentionally adopted an nbC definition which provided a lower, and thus inferior barrier to the potential for the insinuation of foreign influence into the presidency.
In light of the known and available § 212 definition of persons who “… sont ceux qui sont nés dans le pays, de parens citoyens…,” – and quite apart from the additional requirement of birth “in” the country where “les parens citoyens” were already its citizens – the contention that the Founders preferred the lower, inferior definitional barrier to the higher, superior barrier afforded by § 212 is not only counter-intuitive and irrational, it is in addition fatuous.
Still, that reality will not likely restrain the “de Vattel Deniers” from prattling on with bulky, but irrelevant, linguistics. Yet, hope springs eternal, so your servant will try one more time.
Accordingly, to commenter Leland or anyone else reading this response: why would the Founders have adopted the lower and inferior definitional barrier to foreign influence inherent in the “citizen at/by birth” theory instead of the higher superior barrier afforded by § 212? Huh?
Still waiting.
Regarding your conclusion that “…the end resolution of the nbC question lies either in a binding decision of the Supreme Court or a ratified amendment of the Constitution. Neither of those two solutions seems likely in the near term, lamentably, because the vast majority of the body politic is simply indifferent to the issue.”, I must take issue.
I do not believe that it matters whether the vast majority of the body politic is indifferent to the issue if someone, as in the case of Barry Soetoro, illegally represents himself as constitutionally eligible to be the POTUS while knowingly not so, and then, as he has done, proceeds to cover-up his criminal usurpation of the office of POTUS by fraud with manufactured multi-layered electronic files–forgeries–not representative of any physical document whatsoever, let alone an official government issued birth certificate.
Those are serious crimes against the Constitution of the United States of America, against the honor of the office of POTUS, and against ‘We the People’ of the United States of America.
Both of Obama’s criminal usurpations of the office of POTUS should be retroacatively abrogated as they took place during the commission of crimes.
Everything that the Manchurian Muslim from Mombasa signed while in the commission of the criminal usurpation of the office of POTUS and all that his illegal and illegitimate administration undertook while complicit in Obama’s criminal usurpation of the office of POTUS should as well be retroactively abrogated as having taken place during the commission of a crime.
President Trump’s next attorney general, assuming he chooses one who unlike Bill Barr has a spine, should take action on the findings of former Maricopa County, Arizona Sheriff Joe Arpaio’s volunteer Cold Case Posse investigation into Obama that was commanded under Sheriff Joe by former detective Mike Zullo.
Obama should be prosecuted for his crimes. Given the magnitude of Obama’s crimes there can be only one sentence that would be appropriate for an enemy agent of Islam who practices taqqiya who has criminally usurped the office of POTUS by fraud and conspired to cover-up that crime by publishing forged electronic files on the official White House website as “proof” that he is an Article ii natural born citizen of the United States of America.
There is no crime I know of more sinister than the criminal usurpation of the Oval Office by fraud. Obama has done more to advance the world domination agenda of the pan-Islamic Islamo-fascist civilization jihadist cause than the murderous pedophile who the Muslims call Mohamhead. (Any variation in spelling in English transliteration of the name is regarded as acceptable and there are many.)
IMO, if any decision is ever made by the Supreme Court involving Natural Born Citizen, it will determine that Barack Hussein Obama is eligible. The Supreme Court is not going to implicate Chief Justice John Roberts as being complicit in the treason involved with the installation of Barack Obama. The choice of the race protected, ineligible Obama was a brilliant one by Soros and other enemies of America. This includes the CIA and John Brennan who Obama, once sworn-in just happened to appoint as his CIA Director. Obama being race and once sworn-in ineligibility protected means any decision by the courts and especially the Supreme Court will find Obama eligible. Congress knows it must protect Obama, and others who may be ineligible but nevertheless are running for an office requiring a Natural Born Citizen. Congress does this to protect themselves.
This was obvious years ago, and the actions and inaction of Congress since then continue to reveal the WHY of their avoidance of making a decision on NBC…Another term of Trump scares them to death, which also happens to be what they fear will happen if their treason is revealed and acted on. A crime “too big to prosecute” happened and is destroying America as intended by the installers of the fraud Barack Hussein Obama…The most significant action all complicit can take to protect themselves is to insure Donald Trump is never President again. The fundamental change continues with Obama now in that 3rd term he said he would like to have. Obama also sees his job, and the job of all complicit in The Obama Fraud as protecting themselves from PRESIDENT Donald Trump……The is a repeat of the panic of both parties when Trump defeated Hillary Clinton in 2016 due to inadequate Democrat voter fraud. The desperate attempts to prevent Trump from being president again are even more intense this time because those complicit in The Obama fraud fear Trump will administer the “payback” they deserve for stealing the 2020 election and for the constant harassment of Trump, his family and associates.
“The body politic is simply indifferent to the issue”. That indifference is protecting the many complicit in The Obama Fraud and rewarding Obama with the finalization of his, “fundamental change” and the demise of America. Most who we elected and who swore an oath to protect the Constitution instead chose to protect what is most important, themselves….. The few who did speak out were shut-down as an example to the others………
Pray and vote for Trump………….
MAKE-THEM-BELIEVE MAKE BELIEVE…OR ELSE, get “MAKE BELIEVED [retaliated]”!
I believe you are right , Bob68, that the U.S. Supreme Court has evaded this obvious Obama Fraud and, therefore, will only surrender to Obama’s terrifying “black male blackmail nationwide-race-war” possibility so as to render an “Obamacare is a tax just as Obama is a natural born Citizen” decision if and when SCOTUS is ever pressed sufficiently to formally address the obvious Obama Fraud 08-28-08- Today.
It is natural that SCOTUS would first protect itself over any We the People. Also, I suspect too many U.S. Government employees today actually view “We the People” with contempt as if they are the governing elites and We the People are groveling “civilian pukes”.
Anyone who gets too close to “spilling the Obama-Hillary-Biden beans” may get “Seth Riched [robbed]” by the “criminalized” CIA it appears:
https://www.youtube.com/watch?v=5T2V6pweJ-A
This whole OBAMA FRAUD is much like a MAFIA OPERATION with its own nationally syndicated code of omerta-like silence, OR ELSE, hit jobs on the potential bean spillers.
For example, imagine what will happen if any one of the attorneys and judges involved in these past cases to expose Obama Fraud were to now come forward this election year and “spill the Obama beans”: 100% NATIONALLY-SYNDICATED OBAMA FRAUD JUDICIAL-MEDIA-OMERTA = http://tesibria.typepad.com/whats_your_evidence/birther%20case%20list.pdf
natural reality (Trump’s eyes):
https://www.youtube.com/watch?v=dOP5Y9OUJyk
vs
narrative reality (Obama and SCOTUS lies): MAKE -THEM-BELIEVE MAKE BELIEVE = https://www.youtube.com/watch?v=bnYJI4QTpXs
And if Trump is ever removed from the Town Square, won’t the CIA-mafia then try to harass “Obama birthers”, and possibly get birthers “Harrissed [executed]” or “Campbelled [accidented]” or “Epsteined [suicided]” or “JAN6ed [imprisoned]”, for relentlessly exposing the Obama Fraud for some 16 years now?
>”Harrissed” https://www.washingtontimes.com/news/2008/apr/19/key-witness-in-passport-fraud-case-fatally-shot/
>”Campbelled” https://www.youtube.com/watch?v=Cg6WotQeT-0
>”Epsteined” https://www.youtube.com/watch?v=_RBCPxTynVU
>”JAN6ed” https://www.youtube.com/watch?v=lmNuViMRCYA&rco=1
FEAR YEAR or FREE YEAR 2024?
https://imprimis.hillsdale.edu/disparate-impact-thinking-is-destroying-our-civilization/ :
ABA’s SUBJECTIVITY OR FIVE COMMON SENSES’ OBJECTIVITY?
color of body or competency of mind?
culpable or capable?
insanity or safety?
America’s “legal profession” continues to collapse and seems incapable of disciplining itself.
Ever since 08-28-08, when Crime Boss “Treason Queen” Pelosi over-ruled the Hawaii Democratic Party’s refusal to certify Obama as a Constitutionally eligible presidential candidate because they could not find Obama’s narrative birth certificate in Hawaii https://www.youtube.com/watch?v=rXFwqUi3zR0&feature=youtu.be , America’s “legal profession” has devolved to a pro-profit criminal enterprise where their law licenses operate as a LICENSE TO LIE with relative impunity. https://www.c-span.org/video/?320640-1/licensed-lie
America’s “legal profession” is out of control as it “legalizes” yesterday’s civil wrongs into today’s “civil rights” FOR PROFIT!
At what other time in U.S. history did the “legal profession” debate on the Constitutional-eligibility of any U.S. President continuously for some 16 years and counting [2008- 2024]?
TOO MANY LAWYERS ARE OUTLAWYER LIARS!
https://www.youtube.com/watch?v=lr0HVZkVdqo&list=UULFkMtkWJ_47DdM_P5yyAPMPg&index=30
It’s time to have a national elections MORATORIUM and a national open borders MORTORIUM and a “legal profession” MORATORIUM while honest responsible objective adult U.S. citizens study and mandate firm guidelines to protect the public from these three otherwise LAWLESS nationally-syndicated-for-profit criminal enterprises!
Author – “it only categorized certain people as being “considered” as being such.”
In the late 1700s the term “be considered as” usually meant is or are. We know that from its usage in a number of documents But we only have to look at the Naturalization Act of 1790 to verify it.
The 1790 Act uses the term “be considered as” three times;
1) aliens who finish the naturalization process “shall be considered as a Citizen of the United States.”
2) a child dwelling in the United States and under the age of 21 of a naturalizing alien “shall also be considered as citizens of the United States.”
3) a child born outside the US to US citizen parents “shall be considered as natural born Citizens.”
No one would argue that for the first two situations the naturalized alien and his child are only considered to be citizens. They are in fact citizens of the United States. And for the third case the use of the exact same language to describe such children can only mean the Congress intended for them to be natural born citizens.
Response from the author:
———————————–
The commenter quotes from your humble servant’s critique: “it [i.e., 1 Stat. 103] only categorized certain people as being ‘considered’ as being such” and concludes by stating “[a]nd for the third case the use of the exact same language to describe such children can only mean the Congress intended for them to be natural born citizens.”
There is no serious question that, in 1 Stat. 103, effective March 26, 1790, the Congress “intended” to characterize children born beyond sea to two U.S. citizen parents as “being” natural born citizens. But it is for that very reason that less than 5 years later, on January 29, 1795, Congress realized that its 1790 law very likely violated the nbC provisions of Art. 2, § 1, Cl. 5 of the Constitution. That error was corrected by the repeal of the “natural born” modifier of the subsequent word “citizen.”
And nowhere in 1 Stat. 103 does Congress articulate the notion that it was legislating with regard to persons who were “citizens at/by birth” regardless of unity of parental U.S. citizenship. Indeed, 1 Stat. 103 mandates that for the “characterization” to apply at all, the birth “beyond sea” must be to “citizen parents,” intentionally using the plural. The commenter and the C&K article ignore that reality.
Moreover, as noted in a law review article cited approvingly in the C&K article – Christina S. Lohman, Presidential Eligibility: The Meaning of the Natural-Born Citizen Clause, 36 GONZ. L. REV. 349, 371 (2000/01), “… one could certainly posit that the [Congress] recognized a possible constitutional conflict and sought to correct it. Further, the omission of ‘natural-born’ makes the statute look more like one devolving citizenship by naturalization.” Indeed, the title of the act itself establishes that it is a naturalization statute and not, as some might advocate, a backdoor, end-around run or “quarterback sneak” constitutional amendment.
Thus, even if one could correctly characterize or even erroneously “declare” as “natural born Citizens” persons born while 1 Stat. 103 was in effect prior to its repeal by 1 Stat. 414, the repealed statute does not define the nbC term: it merely states who shall be deemed or declared to be one. And even that circumstance, whether seen to be a “declaration of reality” or as merely a “characterization” evaporated completely when 1 Stat. 414 was enacted, repealing entirely 1 Stat. 103.
Finally, S. Res. 511, seeking to “validate” John McCain’s nbC status, as well as the C&K article being critiqued both ignore the reality that the “rationale” – much less the actual words – of long-repealed 1 Stat. 103 has not purportedly “remained constant” in the intervening 229 years. That assertion is demonstrably wrong.
The commenter also focuses on the “capitalization” issue regarding the letter “C.” The critique of the C&K article seeks only to point out the manifest error of the C&K article where it asserts: “Thus, in the relevant time period, and subject to certain residency requirements, children born abroad of a citizen parent were citizens from the moment of birth, and thus are “natural born Citizens.”
First, Art. 2, § 1, Cl. 5, the “Eligibility Clause, uses a capitalized “C” in the term “natural born Citizen” and in the “Citizen” included in the “Grandfather-Citizen exception. The First Congress is deemed to have been aware of this when it enacted 1 Stat. 103. It did not capitalize the “c” when in 1 Stat. 103 it purported to address the status of children born “beyond sea” to U.S. citizen parents.
The C&K article uses the term “thus” to extrapolate the conclusion that, under the ghost “rationale” of 1 Stat. 103 as then existing in 1790, a child born between 1790 and 1795 must also mean that children born today under the same circumstances, apart from other statutory provisions, “are natural born Citizens,” utilizing – in the 2015 article – an upper-case “C” as it now appears in the Constitution. This extrapolation is an unfounded linguistic non sequitur.
Second, and of equal or arguably even greater significance, the C&K article deploys the term “’a’ citizen parent…,” while even 1 Stat. 103 recognizes that the plural “parents” – indisputably referencing two U.S. citizen “parents” rather than “a” parent – is required. Indeed, as your servant has consistently posited in the past, if § 212 of Book 1, Ch. 19 of the de Vattel treatise was the source of the Founders’ definition of the nbC term, then even under 1 Stat. 103, the sine qua non of nbC status is birth to two persons, a mother and father, who are already citizens of the country where the birth occurs.
Both the commenter and the C&K article authors reject that fact. But all that does is sideline the issue rather than address and answer it. That solution, as also posited in the past, can come only after either a U.S. Supreme Court decision on the merits or a constitutional amendment. Pontifications from former Solicitors General, P&E commenters and even your humble servant may be interesting and even persuasive, but that are neither binding precedent nor recognized amendments to the Constitution. So the debate continues.
Author – From Part I – “The decision to “upper-case” the “c” in the Constitution is not merely a “stylistic” flair, but likely comes from replicating the “upper-case” “C” found in John Jay’s July 25, 1787 “hint” letter to Constitutional Convention Chairman, George Washington.”
It is much more likely that the capital “C” in citizen is just a “stylistic” flair. All of the Cs in citizen are capitalized in the Constitution. If they were trying to replicate the Jay letter or if they felt the term need emphasis, they would not have capitalized citizen throughout the document.
Occurrences of capitalized C in Citizen in the Constitution:
Article I Section 2 Clause 2
“No Person shall be a Representative who shall not have attained to the Age of twenty five Years, and been seven Years a Citizen of the United States”
Article I Section 3 Clause 3
“No Person shall be a Senator who shall not have attained to the Age of thirty Years, and been nine Years a Citizen of the United States”
Article I Section 2 Clause 5
“No Person except a natural born Citizen, or a Citizen of the United States, at the time of the Adoption of this Constitution”
Article III Section Section 2 Clause 1
“Controversies between two or more States;— between a State and Citizens of another State,—between Citizens of different States,—between Citizens of the same State claiming Lands under Grants of different States, and between a State, or the Citizens thereof, and foreign States, Citizens or Subjects.”
Article Iv Section 2 Clause 1
“The Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States.”
When the official printer for the Constitutional Convention (Dunlap & Claypoole) first published a printed copy of the Constitution to be distributed to the state legislatures and the general public, citizen was not capitalized. Not even in Article I Section 2 Clause 5.
The September 19th, 1787 edition of Dunlap & Claypoole’s Pennsylvania Packer can be viewed here:
https://onlineonly.christies.com/s/fine-printed-manuscript-americana/first-public-printing-united-states-constitution-51/116471
Mr. Leland:
Punctuation aside for the moment, what is your understanding as to the meaning and definition of the “natural born Citizen” term as it relates to birth location and the citizenship status of both of the parents when their child is born?
CDR Kerchner (Ret)
http://www.ProtectOurLiberty.org
Author – ““citizens” only, and not “Citizens” with an upper-case “C.””
The capitalization of the word citizen in the Constitution is strictly the stylist choice of the scribe Jacob Shallus. We know because at the time the capitalizing of nouns was falling out of favor and was dependent on the individual scribes preference.
For example, in the August 3rd, 1787 Committee of Detail manuscript draft of the Constitution, James Wilson capitalized the word Citizen every time [Note: the term natural born citizen does not appear in this draft]. However the August 6th printers version [Note: the Convention printed copies of committee’s reports to be handed out to delegates to review] of Wilson’s manuscript does not capitalize the word citizen.
The September 13, 1787 printer’s copy of the Committee of Style’s report of the Constitution does not capitalize the word citizen including when used in the term natural born citizen. Shallus’ manuscript version of the Constitution from September 17th of course does capitalize citizen in Article II. In fact, Shallus capitalized the word citizen every time it appears in the Constitution. For example Article III Section 2 Clause 1 “between a State and Citizens of another State,—between Citizens of different States,—between Citizens of the same State claiming Lands under Grants of different States, and between a State, or the Citizens thereof, and foreign States, Citizens or Subjects.” [Note: Subjects is also capitalized]
The manuscript copy of the Committee of Detail, the proof copy and the proof copy of the Committee of Style can be viewed here:
https://constitutioncenter.org/american-treasures/manuscript-of-the-committee-of-detail-report/kiosk
Excellent analysis and critique of the linguistic trickery used in the paper published in 2015 by Attorneys Paul Clement and Neal Katyal titled, “On the Meaning of Natural Born Citizen”. In that paper they argued that a person can be born in a foreign country with a foreign national father and thus being born a dual-citizen and with the innate attendant foreign allegiance and influence via birth, that said person is still a “natural born Citizen” and thus constitutionally eligible to be president and Commander in Chief. Think Ted Cruz for and example of such a foreign born person and one time candidate for President. This paper is often cited by the Vattel-deniers. DeMaio has exposed Clement and Katyal for what the were with this paper. Non-Constitutionalist legal guns for hire to write a paper to give Ted Cruz (and if it is ever proven Obama was not born in the USA as he personally stated in his early evolving life narratives) a pass and help further destroy our U.S. Constitution for purely political party purposes – both major political parties. The both major political parties want to run people who are not a true “natural born Citizen” of the United States per Natural Law and Vattel’s legal treatise on that which was widely read and used by the founders and framers to justify the revolution and write the founding documents. For some names from both parties see: https://www.scribd.com/lists/22182725/Some-Politicians-Seeking-High-Office-Who-Are-Not-A-Natural-Born-Citizen-of-U-S
I posted and excerpt and link back to his newspaper for the full article at the Free Republic site. See: https://freerepublic.com/focus/f-news/4229895/posts
Rafael E. (Ted) Cruz has never proffered his naturalization documentation to be a U.S. Ciitzen to the general public. Why? I believe that he has something to hide. I classify Ted Cruz the same as Barry HUSSEIN Soetoro (Obama) – an undocumented alien.
CDR Kerchner, I hope you will confer with Leonard Daneman in New Mexico. He did some brilliant legal research on this subject that deserves to be entered into this discussion.
I don’t know if he’s still alive or not, but if you reach him please give him my best.
Hope you are well in Christ Jesus. Thanks for all the work you’ve done in defense of the Constitution. And, Sharon Rondeau, please give Commander Kerchner my email.
Mr. Daneman communicated with me within the last two months.
Hello Chris,
Thank you for your words of appreciation for my efforts to continue to expose that Barack Hussein Obama, aka Barry Soetoro, is a con-man, grifter, Marxist, non-“natural born Citizen” of the United States, and unconstitutionally seated usurper of the office President and Commander in Chief that he fraudulently gained access to.
You may contact me directly regarding sharing any information you are referring to regarding legal research by Leonard Daneman of NM using the orange colored contact button located about 1/2 way down in the right side frame of my WordPress blog: https://cdrkerchner.wordpress.com/ or via my contact link at the bottom of http://www.kerchner.com/books/catalog.htm
Does the Antichrist Obama have a birth certificate?
Belief Watch: Is Obama the Antichrist?
Newsweek article by Senior Editor Lisa Miller.
Was it Dr. Corsi who went down to Kenya? I don’t remember. But whoever it was, they found suspicious evidence that there was one and that it had been removed. Then there was the reel of tape of incoming flights that had clearly been tampered with. Dr. Corsi found that.
I was at the Preliminary Release of the findings of Sheriff Joe’s investigation into Obama with permission from the commander of Sheriff Joe’s Cold Case Posse, Mike Zullo.
Dr. Corsi stood up to the podium before the presser began to announce the Breaking News that Andrew Breitbart had fallen over dead. Only hours earlier, Breitbart had called Sheriff Joe and/or Dr. Corsi to tell them that he had uncovered evidence on Obama that would, as I vaguely recall him saying, ‘change the election.’
Personally, I think they got Breitbart with the heart attack inducing drug that the CIA has admitted to possessing. I think they got Loretta Fuddy with that one too!
The only way Obama’s two criminal usurpations of the office of POTUS are ever addressed is if President Trump chooses an attorney general with a spine of steel and blood that runs red, white, and blue.
An interesting point on your characterization of Barry as ‘the Antichrist’ is that we cannot sum up the gematriatic value of his name in the Hebrew, Aramaic, or the Koine dialect of the Ancient Greek, (that is to say Biblical Greek), because we have not seen the morally depraved homosexual’s actual birth certificate and transliterated the name on that document into any those languages, but it would not surprise me in the least if the number of his name should be if summed up in those biblical languages 666, 666, and 666.