Fedorenko v. United States

Background

A Ukrainian-born man who served during World War II as an armed guard at the Nazi camp Treblinka applied for a Displaced Persons Act (DPA) visa in 1949. He lied about his wartime role, saying he was a farmer and forced laborer. He entered the United States, lived quietly for decades, and became a naturalized citizen in 1970. Years later the Government sued to revoke his citizenship, alleging he hid service at Treblinka and therefore was ineligible for the visa and for naturalization.

Reasoning

The Court asked whether failing to disclose Treblinka service made the 1949 visa invalid and whether a judge could refuse denaturalization for equitable reasons. The majority held that the DPA excluded anyone who "assisted the enemy in persecuting civilians," and that serving as a concentration-camp armed guard met that exclusion regardless of whether the service was voluntary. Officials' testimony showed such guards were routinely found ineligible. Because the visa was void, the naturalization was "illegally procured." The Court also held district courts have no equitable power to keep citizenship once illegal procurement or willful material misrepresentation is proven.

Real world impact

This decision means the Government can strip citizenship when an immigrant obtained a visa by lying about disqualifying wartime conduct. It confirms that concealment of concentration-camp guard service is material and can invalidate visas. The ruling limits judges’ ability to block denaturalization on sympathetic facts after unlawful procurement is shown.

Dissents or concurrances

Justice Blackmun agreed with the result but urged applying Chaunt’s rigorous materiality test; Justice White would have remanded to apply Chaunt and review the District Court’s factual findings; Justice Stevens warned the majority’s reading of the DPA could wrongly threaten survivors coerced into camp roles.