## Facts

- Dimas Campos-Serrano, a resident alien, was apprehended while possessing a counterfeit alien registration receipt card.
- Alien registration receipt cards are small identification cards containing a photo and basic identifying information.
- The cards are issued after an alien has entered the United States and taken up residence to implement a resident-alien registration requirement.
- The cards have no role in facilitating initial entry into the United States.
- A 1952 immigration regulation permitted resident aliens to use the registration card as a substitute for specialized documents when re-entering the United States after temporary travel abroad.
- Campos-Serrano was convicted in federal district court under 18 U.S.C. § 1546 for possession of a counterfeit alien registration receipt card.
- The court of appeals reversed; the Supreme Court reviewed and affirmed the reversal on statutory, not constitutional, grounds.

## Issues

1. Whether a counterfeit alien registration receipt card qualifies as an “immigrant or nonimmigrant visa, permit, or other document required for entry into the United States” under 18 U.S.C. § 1546.
2. Whether the Court should resolve the case on statutory interpretation grounds rather than reach a constitutional question concerning admission of the card at trial.

## Decision

- The Supreme Court affirmed the judgment setting aside the conviction.
- The Court held that possession of a counterfeit alien registration receipt card is not punishable under 18 U.S.C. § 1546.
- The Court declined to reach the constitutional question because the case could be decided on a discrete statutory ground.
- Dissenting Justices would have construed § 1546 to include the card because regulations allowed it to function as an entry-related document for re-entry.

## Legal Principles

- Criminal statutes are construed narrowly; conduct is not covered absent clear statutory text, structure, or history supporting coverage.
- “Other document required for entry” in 18 U.S.C. § 1546 is directed to documents whose purpose is to regulate admission into the United States, not domestic registration/identification documents that are merely permitted substitutes for re-entry by regulation.
- A regulation allowing a document to be used for re-entry does not, by itself, expand the scope of a criminal statute to treat that document as “required for entry.”
- When a separate, specific statute protects the integrity of a particular document, that specificity can indicate Congress did not intend the same document to be covered by more general language in another criminal provision.
- Courts avoid deciding constitutional questions when a case can be resolved on non-constitutional grounds.

## Conclusion

The Court ruled that counterfeit alien registration receipt cards fall outside 18 U.S.C. § 1546’s prohibition on possession of counterfeit entry documents, emphasizing the card’s post-entry registration purpose, the limits of using regulations to broaden criminal liability, and Congress’s separate statutory treatment of registration cards.


United States v. Campos-Serrano, 404 U.S. 293 (1971)