Tuesday, June 20, 2017

Natural Born Citizen Debates - Redux


Natural Born Citizen Debates – Redux

Mario Apuzzo, David Ramsay, Emer de Vattel
vs.
Mark Levin, Larry Solum, Robert Natelson & Akhil Amar

I also posted this on Mario Appuzo’s Natural Born Citizen blog

Mario,

I have another suggestion for a heavy hitter “natural born citizen” debate opponent for you, Yale Law Professor Akhil Reed Amar, However, if his page 38 footnote inserted into his 2008 Slate.com essay in his last book is an indicator, you don’t stand a chance... cough, cough, of staying awake.

After the quote from my previous comment here on June 2, 2017 at 8:18 PM about Prof. Robert Natelson being added to the opposition’s natural born citizen debate roster to “clarify what he, Natelson, meant about Vattel’s clarification about “parents”, there are some comments by Yale Law Prof. Akhil Reed Amar from his 2016 book incorporating his essays, The Constitution Today – Timeless Lessons for the Issues of Our Era. My suggestion is that Prof. Amar should be included in the debate roster of those who propose that dual U.S./foreign citizenship is the original genesis original intent of Article II Section 1 clause 5and the Fourteenth Amendment, and that dual U.S./foreign citizenship is sufficient for a person to be “...eligible to the Office of President”.

To put it another way, Yale Law Prof. Amar should be included in the list of debaters against you on the side of the opposition who promote the shallow proposition that dual U.S./foreign citizenship parents, married or unmarried to each other, can produce a singular U.S. citizenship child, aka a natural born citizen, “by birth alone”. Also, to add to my debate suggestion against the proposition that dual U.S./foreign citizenship is sufficient to be eligible to be president, and contrary to Prof. Amar’s comments below (see relevant congressional statute conferred birth-based American citizenship in footnote 38 below), citizenship by positive law is NOT citizenship by “birth” alone and positive law should NOT be adduced in opposition to the proposition that a “natural born Citizen” is by “birth” alone and so is the ONLY U.S. citizen eligible to be president. If Levin, Solum, Natelson, and Amar will stipulate that positive law (“conferring”) is not the solution to clarifying natural law (“birth”), then the concomitant proposition follows that a “citizen” by positive law should NOT be adduced into the debate to define the meaning of “natural born Citizen” if eligibility to be president can be ONLY by “birth” alone.

My point is that all that Levin, Solum, Natelson, Amar and pinch hitters/debaters et al. need to do is persuade us today, and, in absentia of course, John Jay, George Washington, 100% of the delegates who adopted the language of the Constitution on September 17, 1787 and eventually 100% of the ratifiers of the several states, which includes ratifier John Jay from New York, that when John Jay suggested on July 25, 1787 in his note to George Washington that military “command” should not “devolve” on anyone but a “natural born Citizen”, the dual U.S./foreign citizenship is sufficient to be “...eligible to the Office of President” proponents need to clarify why Jay did NOT mean that eligibility to be president was derived exclusively by

ONLY singular U.S. citizenship; and
ONLY “by birth alone”; and
ONLY by birth to two U.S. citizen married parents; and
ONLY married to each (NOT multiple wives as with Muslims); and
ONLY before the birth of the child.

Also, in addition to what Jay did NOT mean exclusively in 1787 America, those who oppose ONLY singular U.S. citizenship need to persuade us today in 2017 America that Jay ALSO meant (and George Washington tacitly agreed when he passed Jay’s suggestion to the convention delegates) that “natural born Citizen” also meant, or, at least, “could” have meant, as the 1790 Naturalization Act “natural born citizen” language implied until corrected by the 1795 Naturalization Act “citizen” language, that eligibility to be president could be derived by those

1 – born on U.S. soil to only one U.S. citizen parent, married or not to the reproductive partner,
OR
2 – born on foreign soil to either two OR one U.S. citizen parent, married or not to the reproductive partner,
OR
3 – born on U.S. soil to ZERO U.S. citizen parents, married or not to the reproductive partner.

Number 3 is the absurd conclusion of the U.S. citizen parents are not necessary fiat decision of the 1898 U.S. v. Wong Kim Ark court that Levin, Solum, Natelson, and Amar, who, as proponents of dual U.S./foreign citizenship, are really proposing a shallow legal assumption about the legal meaning of “natural born Citizen” in Article II Section 1 clause 5 that leads to the equally shallow conclusion that the Fourteenth Amendment is constitutional authority for plop-and-drop “anchor babies” born on U.S. soil to alien parents and U.N. Ambassador Nikki Haley, Gov. Bobby Jindal, and Sen. Marco Rubio, also born on U.S. soil to alien parents, are “...eligible to the Office of President”.

Mario, all Levin, Solum, Natelson, and Amar and et al. need to do is persuade themselves first and then us that Jay was totally inclusive and not exclusive when he underlined the word “born” in his “natural born Citizen” note to Washington.

Simple, huh? That’s all they need to do.

For context about Prof. Amar, here is my previous comment about including Prof. Natelson into your debate roster.

After posting the previous comment today (June 2, 2017 at 12:38 PM) about debates with Mark Levin and Professor Larry Solum I remembered Professor Robert Natelson, author of The Original Constitution: What It Actually Said and Meant, 3rd Edition, published in 2014. He did not add anything to the text of the 2nd Edition published in 2011, but he did add footnote #25 about Emer de Vattel and how Vattel "clarified" what he meant by parents”. After the quote from Natelson’s book about Emer de Vattel is your quote about David Ramsay that Natelson should be asked about to clarify what he, Natelson, meant about Vattel’s clarification.”

Now, here are some of Prof. Amar’s comments related to why a “citizen” with only one U.S. citizen parent (see page 38 footnote below) is eligible to be president. He states on pages 4 and 5 that his book is composed of his essays: “The essays are organized by subject matter so that the reader may see the larger patterns of argument that run through them. … To preserve the integrity of the historical record, I’ve used this book’s footnotes and endnotes to identify all important substantive changes.”

Mario, to me this statement about substantive changes”, specifically his long footnote on page 38 about a “citizen” who is “...eligible to the Office of President” (my words), means that his footnote is all he thought was needed to deal with the “hullabaloo” about the “presidential eligibility” of then Senator Obama in 2008 and Senator Cruz in 2016.

Although “natural born citizen” is on page 36 in the text, the Index does not list “natural born citizen”, “natural”, “born”, or “citizen”, but it does list “citizenship rights, 406; birthright citizenship, 38(fn); detention of an “enemy combatant,” 207-208; Obama and Cruz’s presidential eligibility, 38(fn); presidential qualifications, 36, 263”. All empheses are in the original.

Page 36[-37]
Slate essay: The Constitution and the Candidates (2008)
presidential eligibility”

Consider next the Constitution’s rule that the president be “a natural born citizen”—a rule that focuses not on where a person becomes a citizen, but when. To be eligible, one must be born a citizen rather than naturalized at some later date. At the Founding, a special constitutional clause provided that even those who had not been citizens at birth could nevertheless become president, if they were citizens circa 1787. Thus, Alexander Hamilton, born in the West Indies, was clearly eligible. All those already in America in 1787 could be trusted; but the framers fretted that an Old World earl or duke might someday sail across the Atlantic with a boatload of gold and bribe his way into the presidency. (Rumor had it that George III’s second son, the Bishop of Osnaburgh, would soon head this way.) Thus, the “natural-born” clause’s main target of concern was not immigrants generally, but wealthy European aristocrats who might wreak havoc in an America lacking strong campaign finance laws.

The Constitution’s final requirement—fourteen years of U.S. residence—also focused on transoceanic travel and made clear that loyal Americans who had spent years or even decades abroad were nonetheless welcome to pursue the American presidency. (The document pointedly did not require decades of continuous and uninterrupted residence in the U.S.) ….”

[...snip… to page 37]

Later amendments have further opened the door of eligibility. Nothing at the Founding required that state election laws give equal treatment to black or female voters or office seekers. The Constitution’s Fifteenth and Nineteenth Amendments corrected these Founding lapses, promising blacks and women the rights to vote and to be voted for as full political equals.”

Page 38 footnote
Slate essay: The Constitution and the Candidates (2008)
– “birthright citizenship” & “Obama and Cruz’s presidential eligibility”

[After a short comment in the text about Sen. John McCain, the footnote that references the “hullabaloo” about natural born citizen – “hullabaloo” ??? – starts with “extra information for readers interested...”. A question for Prof. Amar: Is this long footnote the best that Prof. Amar, being a constitutional scholar and all that implies, like constitutional scholars Levin, Solum, and Natelson, is this footnote the best Prof. Amar can do… after eight years dealing with the “nbC” “hullabaloo”?]

[...the brackets [] below in the next paragraph are in the page 38 footnote]

[Extra information for readers interested in the more recent hullabaloo about Obama’s birth certificate and the questions raised about Ted Cruz’s presidential eligibility: Cruz is eligible even though he was undeniably born in Canada. At the time of his birth, the relevant congressional statute conferred birth-based American citizenship on any foreign-born baby who had at least one parent who was a U.S. citizen, so long as that parent had met certain conditions of extensive prior physical presence in the United States. On the day of his birth, Cruz’s mother was a U.S. citizen, even though his father was not; and his mother also met the relevant rules of extensive prior physical presence. Why then, would Obama have been any different even if he had been born in Kenya, as has been (preposterously but repeatedly) claimed by various critics, led by Donald Trump? Like Cruz, Obama’s mother was a U.S. citizen on the day of his birth, even though, like Cruz, his father was not. And nothing in the relevant congressional statute treats a Kenyan birth as any different from a Canadian birth. The answer to this puzzle is that the congressional law on the books when Obama was born required a foreign-born child to have at least one citizen parent who had been physically present in the United States at least five years after age fourteen. Obama’s mother did not clear this bar because she was only eighteen when she gave birth. So this birth had to happen in the United States to make her son a citizen at birth. Of course this birth did in actual fact happen in the United States—in the state of Hawaii—and except for the children of foreign diplomats, anyone born these days in the United States is a birthright citizen under the Constitution itself, whether or not the baby’s parents are themselves citizens. (This birthright citizenship is the clear command of the first sentence of the Fourteenth Amendment, see pp. 240-245.) For this law on the books on Obama’s birthday, see Act of June 27, 1952, 66 Stat. 235-36; Title III, ch. 1, section 301(a)(7). For on the meaning of “natural born” see p. 42 n. 14.]”

Page 207-208
New Republic essay: Go Directly To Jail
– “enemy combatant”

Question 5: What difference does it make that Padilla[*] is an American?

[* Jose Padilla, aka Abdullah al-Muhajir is a U.S. citizen, and is simply being “detained” as a “soldier”. The Arabic “abdullah” means “slave of Allah”]

“…. But the government is not (yet) charging Padilla with a crime. For now, they are simply treating him as a soldier. Why should he get more rights than a typical prisoner of war simply because he may also be a criminal? Why should he get more rights than all the detainees in Guantanamo simply because, unlike the rest, if he is indeed a soldier then he has also betrayed his country (whereas the others owed America no loyalty in the first place)?”

Page 264
Slate essay: Two and a Quarter
– “presidential qualifications”

Consider also the way that the states elect governors—directly by the voters, one person, one vote. If the federal electoral college is so good, why does no state closely follow it? Let’s scrap it. And if naturalized Americans like California’s Arnold Schwarzenegger and Michigan’s Jennifer Granholm can be trusted to serve as governors, why not amend the federal Constitution to allow them to run for president? In fact, in 2004, the Senate held hearings on just such a proposed amendment, sponsored by Republican Senator Orrin Hatch and strongly endorsed by several congressional Democrats.”

[Soft-socialist Schwarzenegger lost California to hard-socialists and Granholm did nothing to stop the socialists from “transforming” Michigan, so they are definitely not liberty vs. tyranny role models for amendment propositions for the same commonsense reason that the BREXIT initiator of 26 years ago and 2016 BREXIT hero Nigel Farage is not a role model to “transform” America, with or without absurd amendment propositions—they are not U.S. natural born citizens by “birth” alone.]

Page 406
Conclusion (not an essay)
– “citizenship rights”

Simply put, the written Constitution is often wise—typically, wiser than judges acting on their own steam—because the document distills the democratic input of many minds over many generations. … Later generations of ordinary Americans mobilized to enshrine in this terse text an end to slavery, a sweeping guarantee of equal birthright citizenship, an emphatic commitment to protecting civil rights against all levels of government, and radical expansions of the rights of political participation—to blacks, to women, to the poor, to the young, and more. These were epic democratic achievements, and they are all worthy of profound respect by today’s Americans. We, the people of the twenty-first century, thus do well to ponder the collected and collective wisdom of this old and intergenerational text.”

[This is not a previous essay, but it is definitely an excellent point about the Fourteenth Amendment and “citizenship rights” - except for Prof. Amar's implication that the Fourteenth Amendment is the constitutional authority that allows plop-and-drop anchor babies, who are born on U.S. soil to parents who are not U.S. citizens, to be eligible to be president. The implication is shallow, thoughtless, irrational, and contrary to self-preservation.]

Art
Original-Genesis-Original-Intent.blogspot.com



2017-06-02

Natural Born Citizen Debates

Mario Apuzzo, David Ramsay, Emer de Vattel
vs.
Mark Levin, Larry Solum, Robert Natelson

Mario,

After posting the previous comment today (June 2, 2017 at 12:38 PM) about debates with Mark Levin and Professor Larry Solum I remembered Professor Robert Natelson, author of The Original Constitution: What It Actually Said and Meant, 3rd Edition, published in 2014. He did not add anything to the text of the 2nd Edition published in 2011, but he did add footnote #25 about Emer de Vattel and how Vattel "clarified" what he meant by parents”. After the quote from Natelson’s book about Emer de Vattel is your quote about David Ramsay that Natelson should be asked about to clarify what he, Natelson, meant about Vattel’s clarification.

Professor Rob Natelson

"...Vattel wrote of citizenship following "parents," at several later points he clarified that, as in England, foreign-born children followed the status of their fathers."

On pages 147-48 Natelson explains what the language of the U.S. Constitution in Article II Section 1 clause 5 "...actually said and meant"; the footnote is on page 148:

"The Constitution imposed certain qualifications on the President. The Constitution implied, although it did not state explicitly until adoption of the Twelfth Amendment, that the same qualifications applied to the Vice President. Both had to be at least 35 years old, which was a significant requirement in an age in which even people who survived childhood often did not live beyond their 50s. The idea was to better assure a certain amount of maturity and wisdom. Also, both had to have resided within the country for the previous fourteen years.

"Most importantly, the President and Vice President had to be natural-born citizens or citizens at the time of ratification. We know exactly what the founders meant by the phrase "natural-born citizen" because they adapted it from the English legal term, "natural born subject," which in Britain defined who could serve in Parliament or the Privy Council(25). Essentially, a natural-born citizen was one who met either one of two requirements. First, a person qualified if born within the United States or within American territory, even if the person's parents were aliens. Alternatively, an individual qualified even if born outside the country if the individual's father was an American citizen not then engaged in traitorous or felonious activities.

"These birth and residence requirements were designed better to assure that these officers were truly sympathetic to those they were to govern, and to guard against the risk that they might be sympathetic to a foreign power(26).

"There was no constitutional requirement that a President or Vice President be male. The pronoun "he" used throughout the Constitution was generic(27)."
__________
"(25)Since the publication of the first edition, several readers have contacted me to argue that "natural born" should be defined as Emer Vattel defined it in his international law treatise. Invariably their argument is driven by hope that Vattel's definition, if applied, would disqualify from the presidency some politician they dislike.

"The Constitution's meaning does not, however, depend on one's political hopes. The document generally employed domestic legal terms according to English usage.

As Vattel acknowledged, the English standard for "natural born" varied from the international standard with respect to children born within the country; as to children born outside the country, the rules were the same. (Although at one point in his book Vattel wrote of citizenship following "parents," at several later points he clarified that, as in England, foreign-born children followed the status of their fathers.)”

David Ramsay

Mario, here is a short snippet of your comment about David Ramsay, and the url on your blog for those who want to read it all:
>> http://puzo1.blogspot.com/2015/07/july-4-1776-birth-day-of-nation-and.html

Here we have direct and convincing evidence of how a very influential Founder defined a natural born citizen. Noah Webster, 1828, in explaining how an American dictionary of the English language was necessary because American words took on different meanings than the same word in England, placed David Ramsay among great Founders such as “Franklin, Washington, Adams, Jay, Madison, Marshall, Ramsay, Dwight, Smith, Trumbull...”

[...snip...]

Ramsay, being of the Founding generation and being intimately involved in the events of the time would have known how the Founders and Framers defined a natural born citizen and he told us that such a person was one born in the country to citizen parents.

In giving us this definition, it is clear that Ramsay did not follow the English common law but rather natural law, the law of nations, and Emer de Vattel, who also defined the “natives, or natural-born citizen” the same as did Ramsay in his highly acclaimed and influential treatise, The Law of Nations, Or, Principles of the Law of Nature, Applied to the Conduct and Affairs of Nations and Sovereigns, Section 212 (1758 French) (1759 English).

We can reasonably assume that the other Founders and Framers would have defined a natural born citizen the same way that Ramsay did, ....

[...snip...]

It is valuable because it is evidence of the public meaning of these terms at the time they were framed and ratified."

In conclusion, Mario, for those who may wonder why the definition of natural born Citizen is so important I have very simple questions. Which words of the U.S. Constitution are NOT important? Were the words of the First Amendment intended to be temporary or perpetual? How about the Second Amendment? Was the “...the security of a free state” intended to be temporary or perpetual? Was John Jay’s statement in his note to George Washington that the “command in chief” should “devolve” ONLY on a “natural born Citizen” and “...eligibility to the Office of President” intended to be temporary or perpetual, generation to generation, election to election, POTUS to POTUS?

Well, Mario, you have written that you are ready to debate, so, Mark Levin, Larry Solum, Robert Natelson and et al., who will be the first to tap the plate? Batter up!

Art
U.S. Constitution: The Original Birther Document of the Union
OriginalBirtherDocument.blogspot.com

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