Hong Huang v. Secretary U.S. Department of Homeland Security, 468 F. App'x 932

Huang, a Chinese national, has resided in the United States since 1998 and became a permanent resident in 2004; she filed an N-400 naturalization application in 2009.
In 2010, USCIS denied Huang’s naturalization application and simultaneously initiated removal proceedings; her appeal remains undecided.
Huang sued in district court against Janet Napolitano and Michael Aytes seeking de novo review, claiming exhaustion under INA § 318 and other relief.
The government moved to dismiss for lack of subject matter jurisdiction under § 1421(c) (exhaustion required) and for failure to state a claim under § 1429; it argued no exception to exhaustion could be read into the statute.
The district court dismissed for lack of jurisdiction under § 1421(c), denied related APA/Declaratory Judgment Act claims, and Huang’s motion for reconsideration; the Eleventh Circuit affirms, holding jurisdiction lacking absent an immigration hearing.
The court reasoned that § 1421(c) provides a statutory exhaustion requirement tied to an immigration hearing under § 1447(a), and futility or other exceptions may not be read into the statute; exhaustion is a prerequisite to district court review of a naturalization denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does §1421(c) grant district court jurisdiction without an immigration hearing?	Huang contends no hearing was available, so exhaustion not required.	Government argues exhaustion is mandatory and no judicially creatable exceptions apply.	No jurisdiction absent an immigration hearing; exhaustion cannot be bypassed.
Can futility excuse exhaustion under §1421(c)?	Exhaustion would be futile since removal proceedings prevent review.	Courts cannot read futility into statutory exhaustion requirements.	Futility-based exceptions to §1421(c) exhaustion are not permitted.
May the district court review the naturalization denial during ongoing removal under §1429, or address APA/Declaratory claims?	District court could review denial and consider related claims.	Review during removal is barred by §1429 and exhaustion rules; APA/Declaratory claims were improper.	Court did not reach merits because it correctly dismissed for lack of jurisdiction under §1421(c).

Booth v. Churner, 532 U.S. 731 (U.S. Supreme Court 2001) (no frivolous futility exceptions to exhaustion statute)
Sinaltrainal v. Coca-Cola Co., 578 F.3d 1252 (11th Cir. 2009) (de novo review standards and jurisdiction reviewed de novo)
Equity Inv. Partners, LP v. Lenz, 594 F.3d 1338 (11th Cir. 2010) (abuse of discretion standard for reconsideration)