## Facts

- Divna Maslenjak, a Bosnian Serb, obtained refugee status and later became a naturalized U.S. citizen.
- During the refugee process, she swore that her husband had evaded service in the Bosnian Serb Army; in fact, he had served as an officer in a unit later associated with war crimes.
- In her naturalization application, she swore that she had never given false or misleading information to a U.S. official to obtain an immigration benefit.
- After authorities discovered her husband’s wartime service, Maslenjak testified in related proceedings and admitted she had lied during the refugee process.
- The government indicted her under 18 U.S.C. § 1425(a) for knowingly procuring naturalization “contrary to law,” premised on her false statements under oath.

## Issues

1. Whether 18 U.S.C. § 1425(a) requires the government to prove that the defendant’s illegal act had a material, causal effect on the grant of citizenship.
2. Whether a conviction under § 1425(a) may rest on any knowing false statement in the naturalization process, even if the statement was immaterial to eligibility for citizenship.
3. Whether jury instructions that allow conviction without finding a causal connection between the lie and the conferral of citizenship are legally erroneous.

## Decision

- The Supreme Court unanimously vacated the judgment and remanded.
- The Court held that § 1425(a) requires proof that the defendant’s illegal act played a role in obtaining citizenship; a mere violation of another law during the process is insufficient.
- When the alleged illegality is a false statement, the jury must determine whether the lie influenced the naturalization decision.
- The jury instructions were erroneous because they permitted conviction even if the false statement did not affect the decision to grant naturalization.
- The Court left to the lower courts whether the instructional error was harmless.

## Legal Principles

- A conviction under 18 U.S.C. § 1425(a) requires a material, causal link between the unlawful act and procurement of naturalization.
- In false-statement cases, the government must show (1) the misrepresented fact was sufficiently relevant to naturalization criteria that reasonable officials would have pursued it, and (2) truthful disclosure would predictably have led to lawful denial of citizenship.
- Even if the government makes that showing, the defendant may rebut by proving she in fact satisfied all statutory requirements and would have obtained citizenship anyway.
- Section 1425(a) targets unlawful acquisition of citizenship, not falsehoods lacking a connection to statutory eligibility.

## Conclusion

The Court required the government, in criminal denaturalization prosecutions under § 1425(a), to prove that a defendant’s illegal act—such as a lie under oath—materially affected the acquisition of citizenship, and it vacated Maslenjak’s conviction because the jury was not instructed to find that causal connection.


Maslenjak v. United States, 582 U.S. 335 (2017)