United States v. Hongyan Li, 619 F. App'x 298

Hongyan Li, a naturalized U.S. citizen, pled guilty to enticing prostitution (18 U.S.C. § 2422) and money laundering (18 U.S.C. § 1957) for running an interstate prostitution business and laundering its proceeds.
After her conviction, the government filed a civil denaturalization action seeking to cancel Li’s certificate of naturalization on the ground she lacked the required "good moral character" before naturalization.
Li and the government cross-moved for summary judgment; the district court granted summary judgment for the government and revoked Li’s citizenship. Li appealed.
Li argued (1) the government breached her plea agreement by bringing the civil denaturalization action, (2) the action is barred by the five-year limitations period in 28 U.S.C. § 2462, (3) the government failed to meet the clear, unequivocal, and convincing burden for denaturalization, and (4) the complaint was procedurally defective for citing the wrong regulatory subsection.
The government relied on Li’s guilty plea admissions about operating multiple residences with prostitutes and laundering proceeds to show she lacked good moral character during the statutory period for naturalization.

Issue	Plaintiff's Argument (Li)	Defendant's Argument (Government)	Held
Whether bringing civil denaturalization breached plea agreement	"Prosecution" in plea bars subsequent prosecution — so denaturalization is barred	"Prosecution" means criminal prosecution; agreement explicitly allows civil/administrative actions	No breach; plea unambiguously permits civil actions
Whether 28 U.S.C. § 2462 five-year limitations period bars denaturalization	§ 2462 limits enforcement actions to five years; denaturalization is subject to it	§ 2462 applies only to punitive penalties/forfeitures; denaturalization is remedial/restorative and not punitive	§ 2462 does not apply; denaturalization is remedial and not time-barred
Whether government met the heavy burden for denaturalization	Government failed to show clear, unequivocal, and convincing evidence of lack of good moral character	Li’s guilty plea admissions and convictions establish lack of required moral character under immigration law	Government met its burden; summary judgment for government affirmed
Whether the complaint was procedurally defective for citing a different regulatory subsection	Complaint allegedly sought relief under the wrong regulatory subsection, making it defective	Complaint alleged statutory grounds (8 U.S.C. § 1101(f)) and placed prostitution conduct at issue	Complaint was sufficient; procedural challenge rejected

United States v. Cantu, 185 F.3d 298 (5th Cir. 1999) (plea-agreement interpretation uses contract-law principles)
Bickham Lincoln-Mercury Inc. v. United States, 168 F.3d 790 (5th Cir. 1999) ("prosecution" in plea agreements typically refers to criminal proceedings)
Meeker v. Lehigh Valley Ry. Co., 236 U.S. 412 (1915) (statute excluding actions for penalties/forfeitures covers punitive, not remedial, measures)
Fedorenko v. United States, 449 U.S. 490 (1981) (standard for denaturalization and effect of illegal procurement of citizenship)
Badaracco v. C.I.R., 464 U.S. 386 (1984) (statutes of limitations construed strictly in favor of the government)
Coughlan v. Nat’l Transp. Safety Bd., 470 F.3d 1300 (11th Cir. 2006) (revocation of a certificate is remedial, not punitive, for § 2462 purposes)