Absolutely devoid of merit

And you just can't get any more devoid of merit than that.

A birther makes it to the 10th Circuit Court of Appeals:

[Previously] we explained that "[d]ismissal of a complaint for lack of subject matter jurisdiction would only be justified if 'that claim were so attenuated and unsubstantial as to be absolutely devoid of merit' or 'frivolous.'" Having carefully reviewed Mr. Craig's amended complaint, we find that it is "very plain" that his "alleged claim under the Constitution or federal statu[t]es" falls within this "wholly insubstantial and frivolous" category such that federal jurisdiction is not extant.

Mr. Craig has no legally cognizable right to be deemed "the First Legally recognized 'Natural Born American Citizen'" or "the Last" of them.

I would have thought President Tyler the first natural born Citizen (he was the first President born after the Adoption of this Constitution).

Craig v. United States (.pdf; 10 pgs.)

Meanwhile, the birther dentist Orly Taitz got punk'd.

What an astonishing surprise.