## Facts

- Faras (Faris) Shahid, about 59 years old, was born in Zahle, Syria (then within the Ottoman Empire) and was a Christian.
- He had lived in the United States for about 11 years and completed the formal statutory steps required to reach a final naturalization hearing.
- He could sign his name in Arabic but could not read or write English and spoke and understood English poorly.
- In court questioning conducted in English, he did not demonstrate understanding of American government or the responsibilities of citizenship.
- When asked whether he was a polygamist or a disbeliever in organized government, he answered “yes,” which the court attributed to his inability to understand the questions in English.
- His wife and most of his children remained in Syria; he sought naturalization largely to bring his family to the United States.

## Issues

1. Whether a Syrian of Asiatic birth and descent qualifies as a “free white person” eligible for naturalization under the then-governing federal naturalization statute.
2. If eligible, whether the applicant proved he was a fit subject for naturalization, including good moral character and attachment to the principles of the U.S. Constitution.

## Decision

- The court held that Syrians such as Shahid fell within the statutory category of “free white persons” and were not categorically barred from naturalization on racial grounds.
- The court nonetheless denied Shahid’s petition, concluding he failed to establish the qualifications required for citizenship, particularly meaningful attachment to constitutional principles and adequate comprehension of civic responsibilities.
- The court treated the applicant’s affirmative answers about polygamy and disbelief in organized government, even if likely due to language misunderstanding, as unresolved on the record.

## Legal Principles

- Under the then-current federal statute, naturalization eligibility extended to “free white persons” (and separately to persons of African nativity or African descent), requiring courts to determine whether a given applicant fell within an eligible class.
- Even when an applicant is within an eligible class, naturalization is not automatic; the applicant bears the burden to prove statutory prerequisites, including good moral character and attachment to the principles of the U.S. Constitution and favorable disposition to good order.
- Courts may deny naturalization where the applicant cannot adequately communicate in English or demonstrate sufficient understanding of governmental structure and civic obligations to support a finding of genuine constitutional attachment.
- Material ambiguity in the applicant’s responses to disqualifying inquiries may justify denial when not cured by clear, reliable proof.

## Conclusion

The court concluded that Syrians were eligible to naturalize as “free white persons,” but denied Shahid’s application because his limited English, lack of demonstrated understanding of American government, and unresolved answers to disqualifying questions prevented a finding that he met the statutory standards for citizenship.


Ex parte Shahid, 205 F. 812 (E.D.S.C. 1913)