a lawsuit filed in an arizona superior court by kenneth allen ("allen v. arizona democratic party") alleged that obama was not a natural-born citizen because his father "was a resident of kenya and thus a british citizen". allen argued that the u.s. supreme court's ruling in "minor v. happersett" required a natural-born citizen to be born in the u.s. of two u.s. citizen parents; however, the judge dismissed the suit on march 7, 2012, ruling that "president obama is a natural born citizen under the constitution" and that "[c]ontrary to plaintiff's assertion, "minor v. happersett" ... does not hold otherwise."