Maslenjak v. United States
The Court ruled that federal prosecutors cannot revoke a person's citizenship simply for having told any lie during the naturalization process — the lie has to have actually mattered to the decision to grant citizenship.
The case involved a Bosnian refugee convicted of illegally procuring naturalization after she falsely denied knowing her husband had served in the Bosnian Serb Army; the Court sent her case back because the jury was never asked whether her lies actually affected her citizenship.
“The Government could thus take away on one day what it was required to give the day before.”
Explaining why letting any lie support revocation of citizenship would create an unfair mismatch between granting and revoking citizenship.
How it got here: A jury convicted Maslenjak under instructions that did not require her lies to have affected her citizenship; the Sixth Circuit affirmed, and she asked the Supreme Court to review that standard.
The Case in Depth
What happened
Divna Maslenjak, an ethnic Serb from Bosnia, obtained refugee status in the U.S. after telling officials her family feared persecution partly because her husband had evaded service in the Bosnian Serb Army. Years later, when applying for citizenship, she swore she had never lied to immigration officials. It later emerged she had known all along that her husband had actually served as an officer in that army, including in a unit involved in the Srebrenica massacre.
The question before the Court
Can the government strip someone of citizenship for lying during the naturalization process even if the lie had nothing to do with the decision to grant citizenship?
The Court's answer
No — the Court ruled that a false statement must have actually mattered to the decision to grant citizenship before it can support stripping someone of citizenship. Simply lying about something, even under oath during the naturalization process, is not enough on its own if the lie had no bearing on whether the person qualified for citizenship.
The Court set out a test: prosecutors must show either that the misrepresented facts were themselves disqualifying, or that they would have led a reasonable investigation to disqualifying facts. Even then, a defendant can avoid conviction by proving she actually qualified for citizenship despite her lies. Because the jury in this case was never asked to make these findings, the conviction could not stand.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Millions of naturalized citizens answer detailed, sometimes embarrassing questions on citizenship applications. This ruling protects them from having their citizenship revoked years later over trivial or irrelevant falsehoods, while still allowing prosecution when a lie actually helped someone obtain citizenship they didn't qualify for.
What changes now
The case returns to the lower courts, which must apply the new causation standard to decide whether Maslenjak's false statements actually influenced her naturalization or whether any error in her trial was harmless. This is a final merits ruling on the legal standard, though her individual case remains unresolved pending further proceedings.
What this does not decide
The Court did not decide whether Maslenjak's specific lies actually affected her naturalization or whether the trial error was harmless — those questions were left for the lower courts to resolve on remand.
Concurrences and dissents
Concurrence in part — Justice Gorsuch
Justice Gorsuch agreed that the statute requires proof of causation and that reversal was required because the jury was never instructed on causation at all. But he would have stopped there, criticizing the majority for going further and creating detailed new tests and an affirmative defense that the parties never fully briefed and lower courts never considered.
Concurrence — Justice Alito
Justice Alito agreed the conviction could not stand but would have framed the requirement as an ordinary materiality standard rather than a causation requirement. He argued the statute requires only that an illegal false statement have a natural tendency to influence the naturalization decision, not that it actually did so.
How the Court got there
The legal reasoning, step by step
- The Court examined the text of the statute making it a crime to 'procure, contrary to law' naturalization, reasoning that to procure something illegally means the illegal act must have somehow contributed to obtaining it — not merely occurred at the same time.
- Using an analogy of a person carrying a hidden weapon while filling out citizenship paperwork, the Court explained that an unrelated legal violation happening during the naturalization process doesn't make the citizenship itself illegally obtained unless there's a causal connection.
- The Court rejected the government's view that any violation of law occurring anywhere in the naturalization process was enough, noting this would let the government revoke citizenship over minor lies that would never have justified denying it in the first place, creating a mismatch between the rules for granting and revoking citizenship.
- For cases involving false statements, the Court set out an objective test: a jury must ask whether the truth would have mattered to a reasonable immigration official — either because the true facts were themselves disqualifying, or because they would predictably have led investigators to disqualifying facts.
- The Court added that even if the government makes this showing, a defendant can still avoid conviction by proving she was actually qualified for citizenship despite her lies, since the statute is not meant to strip citizenship from people who were legally entitled to it.
Doctrinal impact
Cases affected by this decision
Reaffirms Kungys v. United States (485 U. S. 759)
Relies on Kungys's approach to causation and materiality in the related civil denaturalization statute.