by Joseph DeMaio, ©2022 U.S. Supreme Court Chief Justice Morrison Waite, writing the majority opinion in Minor v. Happersett (1875), erroneously stated that Congress’s 1790 inclusion of U.S. citizens born “beyond the sea” as “natural born Citizens” was “retained in all the naturalization laws adopted since.” Twenty-three years later, U.S. Supreme Court Associate Justice Horace […]