Maslenjak v. U.S.

To convict under 18 U. S. C. §1425(a), the finder of fact must determine that the defendant committed an illegal act to influence his application for citizenship, the illegal act was a legal basis to disqualify the defendant’s admission, and the defendant did not prove they were qualified for citizenship.

Six years after gaining refugee status in the U.S., Petitioner applied for naturalized citizenship. During the naturalization application process, the government discovered that Petitioner made false statements during her refugee status interview, and charged Petitioner with violating 18 U. S. C. §1425(a), by “procur[ing], contrary to law, [her] naturalization.” Petitioner stated, under oath, on her naturalization application that she did not provide false information during prior immigration proceedings. The jury determined that Petitioner provided a false statement during her refugee status interview, because she claimed her family was in hiding for five years to evade her husband’s military service, when in-fact he openly served in the military during that time, and he actively participated in a civilian massacre. At trial, the federal district court instructed the jury to convict Petitioner if she made a false statement to the government in her naturalization application, even if the statement was not “material” to the citizenship process. The Sixth Circuit affirmed the conviction. On appeal, the U.S. Supreme Court reviewed the legislative intent of §1425(a). The Court held that the statutory text and context demonstrated that the illegal act must be carried out to influence the citizenship process, and the act, if proven, must provide a legal basis to disqualify the applicant from admission. The Court also recognized that §1425(a) provides a “total defense” if the defendant proves they are qualified for citizenship, despite the illegal act. As such, the Court concluded that the jury instructions did not accurately state the law and were not sufficient to sustain the conviction. REVERSED and REMANDED.