United States v. Mubarak Hamed, 976 F.3d 825

Hamed, a Sudanese national, ran the Islamic American Relief Agency, which funneled funds to Khalid Al-Sudanee and into Iraq, violating U.S. sanctions.
Hamed applied for naturalization in 1999–2000 and answered “no” when asked whether he had ever knowingly committed a crime for which he had not been arrested.
In 2004 the Treasury designated Al-Sudanee and Hamed’s organization as terrorists; in 2010 Hamed pleaded guilty to conspiracy and violations of Iraq sanctions and to corruptly impeding IRS functions and failing to disclose material tax information dating back to the 1990s and early 2000s.
The government filed to revoke Hamed’s naturalization in 2018 under 8 U.S.C. § 1451(a), alleging willful misrepresentation and concealment in his naturalization proceedings.
The district court granted judgment on the pleadings for the government, concluding Hamed’s guilty-plea admissions precluded his lack-of-knowledge defense; the court also rejected laches. The Eighth Circuit affirmed, applying judicial estoppel (and noting collateral estoppel principles) and holding laches unavailable against the United States in denaturalization.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hamed can assert he was unaware his conduct was illegal despite guilty-plea admissions	Hamed: he lacked knowledge at the time and therefore did not willfully misrepresent	Government: plea admissions established he "knowingly and willfully" committed the offenses; estoppel bars the contrary position	Court: Judicial estoppel (and collateral-estoppel principles) apply; Hamed barred from asserting lack of knowledge
Whether the guilty-plea record (plea colloquy, plea agreement) suffices to preclude relitigation in civil denaturalization	Hamed: pleas have less preclusive effect than trial verdicts; factual-basis standard is lower	Government: plea includes explicit admissions and factual basis; convictions and admissions have preclusive effect	Court: Admissions in plea and acceptance by criminal court are binding; estoppel and prior conviction support revocation
Whether laches bars the government's 2018 denaturalization suit given delay after the 2010 plea	Hamed: eight-year wait prejudiced him; suit is untimely under equitable principles	Government: laches does not apply against the sovereign asserting denaturalization	Court: Laches unavailable against the United States in sovereign denaturalization actions; claim not barred

New Hampshire v. Maine, 532 U.S. 742 (2001) (articulates judicial estoppel factors)
Stallings v. Hussmann Corp., 447 F.3d 1041 (8th Cir. 2006) (applies New Hampshire estoppel factors)
Clemons v. Crawford, 585 F.3d 1119 (8th Cir. 2009) (standard for judgment on the pleadings)
United States v. Aleff, 772 F.3d 508 (8th Cir. 2014) (collateral estoppel applies to convictions based on guilty pleas)
Lowery v. Stovall, 92 F.3d 219 (4th Cir. 1996) (plea admissions can give rise to judicial estoppel)
Mirando v. U.S. Dep’t of Treasury, 766 F.3d 540 (6th Cir. 2014) (same: plea admissions preclude contrary civil positions)
United States v. Marks, 38 F.3d 1009 (8th Cir. 1994) (factual-basis requirement for guilty pleas)
United States v. Mandycz, 447 F.3d 951 (6th Cir. 2006) (denaturalization is a sovereign act; laches unavailable)
United States v. Miller, 28 F.2d 846 (8th Cir. 1928) (denaturalization as exercise of sovereign power; laches inapplicable)
Hirani v. United States, 824 F.3d 741 (8th Cir. 2016) (willful misrepresentation in naturalization context)