Aaron Schnitzler v. United States
411 U.S. App. D.C. 412
| D.C. Cir. | 2014Background
- Aaron Schnitzler, a South Dakota state prisoner, sought to renounce U.S. citizenship under 8 U.S.C. § 1481(a)(5) and (6) but was unable to complete the procedures while incarcerated.
- USCIS and the State Department repeatedly redirected Schnitzler among agencies and told him renunciation generally requires an in-person appearance at a U.S. consulate abroad (§ 1481(a)(5)); USCIS later said § 1481(a)(6) renunciations require an in-person interview at a domestic USCIS field office.
- Schnitzler filed a pro se civil-rights style complaint seeking (a) agency action to allow renunciation while in prison or an exception to the in-person requirement, and (b) declaratory relief that the statutory or policy requirements violated due process and equal protection.
- The government moved to dismiss for lack of jurisdiction; it appended a December 2011 USCIS letter stating Schnitzler’s request would be held in abeyance until he could appear in person, and argued this mooted the case and that Schnitzler lacked standing.
- The district court dismissed for lack of jurisdiction, finding the letter provided the relief sought (mootness) and that Schnitzler lacked Article III standing to pursue constitutional claims.
- The D.C. Circuit reversed and remanded: it held the case was not moot because Schnitzler sought an effective, practical means to renounce and official recognition of his renunciation, and he had standing to pursue constitutional and APA claims challenging the statute and agency policy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness: Has plaintiff obtained all relief sought? | Schnitzler: He seeks an effective way to renounce while incarcerated and official recognition, not merely a letter holding his file in abeyance. | Gov’t: The December 2011 letter shows USCIS acted on his application and thus fulfilled his request. | Reversed: Not moot — letter holding application in abeyance does not give the practical means or acknowledgement Schnitzler seeks. |
| Proper characterization of claim (mandamus vs. APA / constitutional) | Schnitzler: Filed as a § 1983/pro se civil-rights complaint; sought relief under APA and constitutional law; did not intend a mandamus-only claim. | Gov’t/District Ct: Treated claim as mandamus, so relief limited to ministerial duties. | Reversed: Complaint should be read liberally; claims include APA causes of action and constitutional challenges, not just mandamus. |
| Standing: Is continued status as a U.S. citizen an Article III injury? | Schnitzler: Being forced to remain a citizen against his will is a concrete injury and implicates constitutional rights to renounce. | Gov’t: Citizenship confers benefits; inability to renounce is not a cognizable injury; also argued causation/redress problems. | Reversed: Allegation that he is forced to remain a citizen suffices as injury in fact for standing; causation and redressability are satisfied given the claims challenge statutes/policies causing the barrier. |
| Reviewability under APA: Is agency action/arbitrariness appropriately before the court? | Schnitzler/Amicus: Government offered shifting, unexplained rationales; § 706(1) and § 706(2) claims are viable and merits questions to be decided on remand. | Gov’t: Various justifications offered (national defense, voluntariness); also argued prior dicta or agency practice forecloses relief. | Remanded: APA review and constitutional merits are questions for further proceedings; jurisdictional dismissal was improper. |
Key Cases Cited
- Kaufman v. Mukasey, 524 F.3d 1334 (D.C. Cir.) (discussing agency obligations when prisoners seek to renounce citizenship)
- Defenders of Wildlife v. Lujan, 504 U.S. 555 (standing requires injury in fact; courts assume merits arguendo when assessing standing)
- Chafin v. Chafin, 133 S. Ct. 1017 (prospects of success on the merits are not pertinent to mootness inquiry)
- Trudeau v. FTC, 456 F.3d 178 (merits questions about agency reasonableness are distinct from jurisdictional issues)
- Fox v. Clinton, 684 F.3d 67 (agency denial was arbitrary and capricious where decision lacked reasoned explanation)