I think his parents were American citizens. That's partially why John McCain could run for President despite being born in Panama.
And because Panama was a U.S. territory at the time, and I think there may be an exception if your parents are in the military and you are born overseas
There's no "exception," the rule has nothing to do with whether or not you're born in the US and has to do with whether or not you were born a US citizen, and the easiest way to prove US citizenship from birth is being born in the US.