Schnitzler v. United States of America
863 F. Supp. 2d 1
D.D.C.2012Background
- Plaintiff Aaron L. Schnitzler, pro se, is a South Dakota state prisoner serving a 15-year term for sexual contact with a child under 16.
- Plaintiff alleges he renounced U.S. citizenship and seeks to compel renunciation or declare INA § 349 unconstitutional under the 14th Amendment equal protection and/or due process.
- Defendants include United States and its DOJ, DHS, and State; they move to dismiss for lack of subject-matter jurisdiction (mootness/standing).
- USCIS advised on Dec. 12, 2011 that renunciation requires an in-person interview and would be held in abeyance due to plaintiff’s incarceration, with no prejudice to USCIS consideration.
- Court concludes mandamus is moot because DHS had a ministerial duty that has been performed, and plaintiff lacks standing for declaratory relief; complaint dismissed for lack of jurisdiction.
- Sentence and background facts indicate the renunciation process is ongoing only in abeyance pending prisoner’s ability to appear.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus claim is moot. | Schnitzler seeks to compel action on renunciation. | USCIS/defendants completed or must complete the action; ongoing abeyance is not a remedy. | Mandamus claim moot; court lacks jurisdiction to order action. |
| Whether plaintiff has standing for declaratory relief. | Renunciation statute is unconstitutional and injures him as a citizen. | No concrete injury; abeyance protects plaintiff; no standing. | No Article III standing; declaratory relief claim dismissed. |
| Whether the Court has subject-matter jurisdiction over the case. | Renunciation dispute falls within federal mandamus/constitutional review. | Case moot and non-justiciable on standing. | Court lacks jurisdiction; case dismissed as moot with standing lacking. |
Key Cases Cited
- Allied Chemical Corp. v. Daiflon, Inc., 449 U.S. 33 (U.S. 1980) (mandamus is drastic, reserved for extraordinary cases)
- Gulfstream Aerospace Corp. v. Mayacamas Corp., 485 U.S. 271 (U.S. 1988) (mandamus requires clear duty and ministerial action)
- Doe v. Exxon Mobil Corp., 473 F.3d 345 (D.C. Cir. 2007) (mandamus and standing principles in complex cases)
- In re Medicare Reimbursement Litig., 414 F.3d 7 (D.C. Cir. 2005) (mandamus standards and extraordinary-remedy framework)
- Power v. Barnhart, 292 F.3d 781 (D.C. Cir. 2002) (standards for mandamus relief and ministerial duties)
- Lozada Colon v. U.S. Dep't of State, 170 F.3d 191 (D.C. Cir. 1999) (standing and ministerial duties considerations in travel/renunciation context)
- Newdow v. Bush, 391 F. Supp. 2d 95 (D.D.C. 2005) (standing and mootness principles in constitutional challenges to government actions)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (injury-in-fact requirement for Article III standing)