Maslenjak v. United States

In Maslenjak v. United States, the U.S. Supreme Court reviewed the standard for revoking citizenship from a naturalized citizen based on false statements. Divna Maslenjak, a Bosnian Serb refugee, obtained U.S. citizenship in 2000 after claiming her family fled ethnic persecution. It later emerged that her husband had served in a Bosnian Serb military brigade implicated in war crimes, and that she had knowingly concealed this during her naturalization interview. The government stripped her citizenship and a court convicted her of illegal procurement. Maslenjak appealed, contending that her misrepresentations were not material to her eligibility. The Supreme Court, in a unanimous decision authored by Justice Kagan, held that the law requires the government to prove the false statement materially influenced the naturalization decision. The judgment vacated the lower court’s ruling and remanded the case, establishing that immaterial lies alone cannot justify denaturalization.

The U.S. Supreme Court ruled unanimously (9-0) to reverse the Sixth Circuit’s decision. It held that the statute requires a causal link showing the misrepresentation played a material role in the naturalization process, vacated Maslenjak’s conviction, and remanded the case for further proceedings consistent with this standard.

Whether the government must prove that a naturalized citizen’s false statement was material—i.e., capable of affecting the decision to grant citizenship—in order to revoke citizenship for illegal procurement under 18 U.S.C. § 1425(a).

The ruling significantly raised the evidentiary threshold for denaturalization, making it harder for the government to revoke citizenship based on minor or immaterial falsehoods. It reinforced due process protections for naturalized citizens, affirming that citizenship once granted should not be easily taken away absent proof of a fundamental deception. The decision was widely seen as a safeguard against overzealous immigration enforcement and provided clearer judicial guidance on the limits of the denaturalization power.