Maslenjak v. United States facts for kids
Quick facts for kids Maslenjak v. United States |
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| Argued April 26, 2017 Decided June 22, 2017 |
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| Full case name | Divna Maslenjak, Petitioner v. United States |
| Docket nos. | 16-309 |
| Citations | 582 U.S. ___ (more)
137 S. Ct. 1918; 198 L. Ed. 2d 460
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| Prior history | Conviction affirmed, 821 F.3d 675 (6th Cir. 2016); cert. granted, 137 S. Ct. 809 (2017). |
| Argument | Oral argument |
| Opinion Announcement | Opinion announcement |
| Holding | |
| False statements made during the naturalization process can lead to the revocation of citizenship only if they played some role in the citizen's naturalization. | |
| Court membership | |
| Case opinions | |
| Majority | Kagan, joined by Roberts, Kennedy, Ginsburg, Breyer, Sotomayor |
| Concurrence | Gorsuch (in part), joined by Thomas |
| Concurrence | Alito (in judgment) |
| Laws applied | |
| 18 U.S.C. § 1425(a) | |
Maslenjak v. United States was a 2017 case heard by the Supreme Court of the United States. The Court decided that the government cannot take away a person's citizenship if they made a false statement that wasn't important to them becoming a citizen. This means a lie must have actually helped them get citizenship for it to be taken away.
Contents
The Story Behind the Case
Divna Maslenjak was born in an area of Bosnia. In 1998, she met with a United States immigration officer. She was trying to get refugee status for her family.
Under oath, Maslenjak said that her husband had avoided serving in a war by leaving the country. She claimed that because of this, her family was in danger. Based on these statements, Maslenjak and her family were granted refugee status. They moved to the United States in 2000.
Years later, officials found records showing that Maslenjak's husband had actually served in the war. In 2006, he was arrested for lying on a government document. A week after his arrest, Maslenjak applied to become a U.S. citizen. On her application, she falsely stated that she had never lied to any U.S. government official. She became a U.S. citizen in August 2007.
Later, Maslenjak admitted that she had lied about her husband's war service to get refugee status. Because of this, she was charged with getting her citizenship illegally. The jury was told that her lies did not need to have influenced her citizenship if she had simply broken a rule about lying to the government.
In 2014, a jury found Divna Maslenjak guilty. A judge then approved the government's request to take away her citizenship. In 2016, a higher court, the United States Court of Appeals for the Sixth Circuit, agreed with the jury's decision. This court's decision was different from what other similar courts had decided in the past. This difference is called a "circuit split."
The Supreme Court's Decision
The case went to the Supreme Court. During the arguments in April 2017, some justices questioned the government's broad view of the law.
The Court's Main Opinion
On June 22, 2017, the Supreme Court ruled in favor of Divna Maslenjak. All nine justices agreed to send the case back to a lower court. Justice Elena Kagan wrote the main opinion for the Court.
The Court said that for citizenship to be taken away, there must be a clear link between the lie and getting citizenship. In other words, the lie must have played a part in the person becoming a citizen.
To figure this out, the Court said juries must ask:
- Did the lie concern something that would have stopped the person from becoming a citizen?
- Was the lie important enough that an immigration official would have investigated it further?
- Would that investigation have clearly shown that the person did not qualify for citizenship?
The Court also said that the person accused could argue that they actually qualified for citizenship anyway. The case was sent back to the lower court to see if the jury instructions had harmed Maslenjak's case.
Justice Gorsuch's View
Justice Neil Gorsuch, joined by Justice Clarence Thomas, agreed with most of the Court's decision. He agreed that a lie must be linked to getting citizenship. However, he did not fully agree with the new tests the Court created. He thought lower courts should have been given time to develop these rules first.
Justice Alito's View
Justice Samuel Alito agreed with the final decision but for a different reason. He believed that the lie had to be "material," meaning it had to be important. He thought something could be important even if it didn't change the final outcome.
What Happened Next
After the Supreme Court sent the case back, the Sixth Circuit Court of Appeals heard new arguments in October 2018. On November 21, 2019, this court decided to cancel Maslenjak's convictions. They sent the case back to the district court for a new trial.
