United States v. Morena

Background

An immigrant named Morena declared his intention to become a U.S. citizen on December 15, 1905, before Congress passed a new naturalization law on June 29, 1906. He later filed a formal citizenship petition on December 21, 1914, and was admitted as a citizen in April 1915. The Government asked a court to cancel that admission because the petition came more than seven years after his original declaration and more than seven years after the 1906 law took effect. A federal appeals court asked the Supreme Court to decide how the 1906 law applies to declarations made before the law took effect.

Reasoning

The Court examined the law’s text, including a proviso that said people who had earlier declared in accordance with the law at that time would not be required to renew that declaration. The Court rejected the idea that this proviso completely exempted old declarations from the new law’s seven‑year time limit. It explained that Congress may set reasonable deadlines and that the 1906 Act aimed to create a single, uniform rule for naturalization across the country. The Court therefore read the Act as applying a seven‑year deadline measured from the date of the Act to earlier declarations rather than preserving an unlimited time for their completion.

Real world impact

The ruling means people who declared intent before 1906 had to finish the naturalization process within the time set by the 1906 law, counted from the Act’s passage. That allows the Government to challenge and cancel very late petitions filed long after the Act took effect. This decision enforces a uniform national timetable for older declarations.