Mahamud v. Department of Homeland Security, 0:16-cv-02609

Plaintiff Mahamud, a naturalized U.S. citizen, received a 2010 Certificate of Naturalization listing her birth year as 1977; she later learned (via her mother) she was born in 1986.
She applied to USCIS to correct the birthdate on her certificate; USCIS denied the request under 8 C.F.R. § 338.5(e), concluding she had given a different birthdate on her naturalization application.
Plaintiff obtained a state-court order correcting her Minnesota birth record but could not compel federal amendment of her naturalization certificate.
A subsequent administrative request to the Nebraska Service Center was again denied (April 11, 2014) for the same regulatory reason.
Plaintiff sued in federal court seeking an order requiring DHS/USCIS to correct her naturalization certificate; Defendants moved to dismiss under Rule 12(b)(6).
The magistrate judge recommended granting the motion, concluding the federal courts lack authority to amend post‑1991 USCIS-issued certificates and that 8 C.F.R. § 338.5 is not arbitrary or capricious.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the federal court has authority to amend or order amendment of a USCIS‑issued naturalization certificate issued after 1991	Court can amend certificate (citing district precedents)	Congress removed district courts’ naturalization authority in 1990; post‑1991 USCIS certificates are administrative and not subject to judicial amendment	Court: no jurisdiction to amend post‑1991 USCIS‑issued naturalization certificates; recommends dismissal
Whether 8 C.F.R. § 338.5(e) (precluding amendment when applicant stated a different name/DOB at naturalization) is arbitrary or capricious	Regulation conflicts with 8 U.S.C. § 1449 and is irrational in cases of later‑recognized factual error	Regulation is rational, promotes uniformity and finality, and discourages falsification; consistent with policy	Court: § 338.5 is not arbitrary or capricious; regulation has rational support

Teng v. Dist. Dir., U.S. Citizenship & Immigration Servs., 820 F.3d 1106 (9th Cir. 2016) (held courts lack jurisdiction to modify USCIS‑issued naturalization certificates issued after the statutory transfer of authority)
McKenzie v. U.S. Citizenship & Immigration Servs., Dist. Dir., 761 F.3d 1149 (10th Cir. 2014) (same: no judicial power to amend post‑1991 USCIS naturalization certificates)
Costello v. United States, 365 U.S. 265 (1961) (naturalization requires full and truthful responses; courts emphasize importance of truthfulness)
Schneiderman v. United States, 320 U.S. 118 (1943) (same principle: candor in naturalization proceedings is required)