## Facts

- John Eric Price, a native of England and citizen of the United Kingdom, became a lawful permanent resident in 1960 and lived and worked in the United States.
- In 1984, Price applied for naturalization using the standard application form.
- Price answered all questions except the item requiring him to list all present and past memberships or affiliations with any organization, association, fund, foundation, party, club, society, or similar group, as well as any foreign military service.
- Instead of listing organizations, Price attached a written legal argument asserting that the disclosure requirement violated his First Amendment right of association.
- Price separately denied Communist Party membership and related involvement when asked in another question.
- The immigration agency treated the refusal to answer the organizational-affiliation question as rendering the application incomplete and recommended denial.
- A federal district court denied Price’s petition for naturalization on the ground that the Attorney General could require the information and that Price’s refusal warranted denial.

## Issues

1. Whether the Immigration and Nationality Act authorizes the Attorney General (through the immigration agency) to require naturalization applicants to disclose all present and past organizational affiliations.
2. Whether requiring disclosure of all organizational affiliations as a condition of naturalization violates the First Amendment right of association.

## Decision

- The court held the Attorney General has statutory authority to require disclosure of organizational affiliations in the naturalization process.
- The court held the disclosure requirement does not violate the First Amendment as applied through the naturalization application question.
- The court rejected claims that the question was unconstitutionally overbroad or vague.
- The court affirmed the denial of naturalization because Price refused to provide the requested information.

## Legal Principles

- The Attorney General may adopt forms and procedures reasonably related to investigating statutory naturalization criteria, including good moral character and attachment to constitutional principles.
- Organizational affiliations may be relevant to statutory eligibility determinations and potential grounds for ineligibility; the government may seek that information in screening naturalization applicants.
- Compelled disclosure in the naturalization application context can be upheld when the government’s interest in the integrity of the naturalization process outweighs the asserted associational-privacy burden.
- A naturalization applicant may decline to answer, but the government may deny the application as incomplete when the refused information is lawfully required and materially related to eligibility.
- A broadly framed request for affiliations is not invalid merely because it extends beyond specifically named disqualifying groups, and common terms describing types of groups are not necessarily unconstitutionally vague.

## Conclusion

The court upheld the government’s authority to require comprehensive disclosure of organizational affiliations from naturalization applicants and affirmed that refusal to answer a lawful, eligibility-related question permits denial of naturalization without violating the First Amendment.


Price v. I.N.S., 962 F.2d 836 (9th Cir. 1992)