The First Circuit has determined that a child whose surviving parent naturalized before his 18th birthday does not derive citizenship if he does not live in the United States as a lawful permanent resident prior to his 18th birthday. The court construed former section 321(a) of the INA.
The full text of Thomas v. Lynch can be found here:
http://media.ca1.uscourts.gov/pdf.opinions/15-1805P-01A.pdf