Mazen Shweika v. Dep't of Homeland Security, 723 F.3d 710

Shweika filed a naturalization application in April 2004 and pursued it before USCIS and the Eastern District of Michigan for nine years.
USCIS denied the application in May 2008 for failure to provide certified arrest documents, harming his good-moral-character showing.
Shweika sought an administrative hearing under 8 U.S.C. § 1447(a); USCIS failed to schedule a hearing within regulations, leading to mandamus proceedings.
USCIS conducted a February 11, 2010 hearing that devolved into a de novo review by the officer, prompting further district-court review.
USCIS denied the application on the merits after the hearing, noting that silence can be inferred against an applicant and that Shweika failed to prosecute the application.
The district court conducted its own review under § 1421(c) and held that Shweika established good moral character, but concluded the case lacked jurisdiction due to exhaustion/administrative-hearing requirements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 1421(c)'s administrative-hearing requirement is jurisdictional	Shweika argues it is a nonjurisdictional claim-processing rule.	Appellees contend the requirement is jurisdictional and conditions review.	Nonjurisdictional; district court erred in dismissal.

Henderson v. Shinseki, 131 S. Ct. 1197 (2011) (bright-line test for jurisdictional vs. nonjurisdictional)
Arbaugh v. Y&H Corp., 546 U.S. 500 (2006) (jurisdictional vs. nonjurisdictional distinctions; threshold limitations)
Reed Elsevier, Inc. v. Muchnick, 559 U.S. 154 (2010) (statutory claim-processing rules; nonjurisdictional treatment of certain restrictions)
Abraitis v. United States, 709 F.3d 641 (2013) (exhaustion and filing-deadline rules treated as nonjurisdictional)
Pruidze v. Holder, 632 F.3d 234 (2011) (regulatory interpretation of jurisdiction; Chevron stepping-stone inapplicable to jurisdiction)