Maslenjak v. United States
137 S. Ct. 1918
| SCOTUS | 2017Background
- Divna Maslenjak and her family obtained refugee status (1998) and later naturalization (2007) after sworn statements to U.S. immigration officials about her husband’s wartime conduct in Bosnia.
- Maslenjak answered “no” on her N‑400 about having given false information to obtain immigration benefits; later evidence showed those answers were false—her husband had served in the Bosnian Serb Army.
- The Government charged Maslenjak under 18 U.S.C. §1425(a) for "knowingly procur[ing], contrary to law, [her] naturalization," based on alleged violations of 18 U.S.C. §1015(a) (false statements under oath).
- The district court instructed the jury that any false statement in the naturalization process sufficed for conviction under §1425(a), even if immaterial to the naturalization decision; the jury convicted and the Sixth Circuit affirmed.
- The Supreme Court granted certiorari to resolve whether §1425(a) requires that the illegal act have contributed to obtaining citizenship and how that standard applies when the predicate illegality is a false statement.
Issues
| Issue | Maslenjak (Plaintiff) Argument | United States (Defendant) Argument | Held |
|---|---|---|---|
| Whether §1425(a) requires a causal link (illegal act contributed to obtaining citizenship) | §1425(a) requires causation: the illegal act must have contributed to procuring naturalization | §1425(a) punishes any violation of law committed "in the course of" procuring naturalization, even if not material or causally connected | Held: §1425(a) requires a means‑end/causal connection — the illegal act must have played some role in acquisition of citizenship |
| For false‑statement predicates, what showing must the Government make (materiality/influence standard)? | The Government must show the lie was material — it would have influenced denial or led to disqualifying facts | Government urged a lower (chronological) standard: any false oath in the process suffices | Held: For lies, jury must determine whether truth would have affected a reasonable official applying naturalization law — either (1) the misrepresented facts were themselves disqualifying, or (2) the lie would have led reasonable officials to investigate further and such investigation would predictably have disclosed a disqualification; defendant can rebut by proving she actually met eligibility criteria |
| Whether conviction may rest on any false statement without showing influence on the outcome | No — immaterial falsehoods should not sustain a §1425(a) conviction | Yes — any violation of §1015(a) in the naturalization process suffices | Held: District court instruction was erroneous; conviction requires more than proof of any false statement |
| Whether qualification for citizenship is a defense after Government proves the causal/investigation showing | Not directly argued by Maslenjak beyond defense evidence | Government did not accept qualification as a complete defense in all scenarios | Held: Actual qualification for citizenship is a complete defense — if defendant proves she met legal criteria, she cannot be convicted under §1425(a) |
Key Cases Cited
- Kungys v. United States, 485 U.S. 759 (1988) (materiality and investigation‑based causation in denaturalization context)
- Fedorenko v. United States, 449 U.S. 490 (1981) (interpretation of “illegally procured” in denaturalization cases)
- Chaunt v. United States, 364 U.S. 350 (1960) (misrepresentations that lead to discovery of disqualifying facts can justify denial/denaturalization)
- Bigelow v. RKO Radio Pictures, Inc., 327 U.S. 251 (1946) (principle that wrongdoer bears the risk of uncertainty his wrongdoing created)