The Supreme Court recently rejected the government’s extreme argument that any false statement given during a naturalization exam—even a misstatement that had no impact on the naturalization decision—could later be a basis for stripping the person of their citizenship.
In Maslenjak v. United States, the government’s interpretation of the law was so narrow that it would have criminalized minor falsehoods—such as failing to disclose even a minor speeding violation during a naturalization exam.
The government argued that it could revoke a person’s citizenship—part of the penalty for a conviction under the law—even if the statement was not directly related to or helped secure the naturalization. It simply had to be false and made during a naturalization exam.
In rejecting this argument, the Court found that the most natural reading of the law requires causality, stating, “[t]o get citizenship unlawfully… is to get it through an unlawful means—and that is just to say that an illegality played some role in its acquisition.”
The Court further pointed out that a person may be motivated to give a false statement due to fear, embarrassment, or a desire for privacy, as opposed to wanting to mislead for the sake of passing their naturalization exam. If the government was to revoke citizenship regardless of the statement’s intent, it would “[open] the door to a world of disquieting consequences.”
To illustrate this point, the Court explained:
“Suppose, for reasons of embarrassment or what-have-you, a person concealed her membership in an online support group… Under the Government’s view, a prosecutor could scour her paperwork and [charge her] on that meager basis, even many years after she became a citizen. That would give prosecutors nearly limitless leverage—and afford newly naturalized Americans precious little security.”
The Court also explained that there are instances in which the law can be practically applied. In these cases, a jury would have to decide “…how knowledge of the real facts would have affected a reasonable government official properly applying naturalization law.”
This means that cases where the misrepresentation has a direct impact on the applicant’s eligibility are fairly straightforward; they require the government to show just that the lie occurred and, therefore, the applicant did not meet the legal requirements for citizenship. An example of this would be an individual who lied about having been physically present in the United States for the required number of years; had she been truthful about the length of time she was in the United States, the officer would have determined she was ineligible for naturalization and denied her application.
Justice Kagan, who wrote the decision, emphasized the importance of naturalization for those who are eligible, explaining that the Court has “never read a statute to strip citizenship from someone who met the legal criteria for acquiring it.”
In rebuking the government’s limited argument, the Court concluded that the law was not a “tool for denaturalizing people who, the available evidence indicates, were actually qualified for the citizenship they obtained.”