Euphemisms, such as passed away for die , are another aspect of language you should not use in your essays: if you write about and mean die , then say so. Clarity and accuracy are paramount. For these reasons academic writing can be rather tentative and cautious. This is the case because we are not after grabbing headlines, but we write accurately what we know. If our data suggest that X possibly leads to Y, we say just that. In this case we should never say that X leads to Y. In academia we are often unsure what really goes on, and we should be upfront about this.
Under the longstanding English common-law principle of jus soli , persons born within the territory of the sovereign (other than children of enemy aliens or foreign diplomats) are citizens from birth. Thus, those persons born within the United States are "natural born citizens" and eligible to be President. Much less certain, however, is whether children born abroad of United States citizens are "natural born citizens" eligible to serve as President. As early as 1350, the British Parliament approved statutes recognizing the rule of jus sanguinis , under which citizens may pass their citizenship by descent to their children at birth, regardless of place. Similarly, in its first naturalization statute, Congress declared that "the children of citizens of the United States, that may be born beyond the sea, or out of the limits of the United States, shall be considered as natural born citizens." 1 Stat. 104 (1790). The "natural born" terminology was dropped shortly thereafter. See, . , 8 . § 1401(c). But the question remains whether the term "natural born Citizen" used in Article II includes the parliamentary rule of jus sanguinis in addition to the common law principle of jus soli . In United States v. Wong Kim Ark (1898), the Supreme Court relied on English common law regarding jus soli to inform the meaning of "citizen" in the Fourteenth Amendment as well as the natural-born–citizenship requirement of Article II, and noted that any right to citizenship though jus sanguinis was available only by statute, and not through the Constitution. Notwithstanding the Supreme Court's discussion in Wong Kim Ark , a majority of commentators today argue that the Presidential Eligibility Clause incorporates both the common-law and English statutory principles, and that therefore, Michigan Governor George Romney, who was born to American parents outside of the United States, was eligible to seek the Presidency in 1968.