On May 29, 1967, the U.S. Supreme Court held that Congress has no power under the U.S. Constitution to strip native-born U.S. citizens of their citizenship. The law similarly protects those who acquire U.S. citizenship through naturalization except when a person obtains their citizenship “contrary to law.” Almost 50 years after Afroyim, the Supreme Court resolved a circuit split and issued its decision in Maslenjak v. United States, 137 S. Ct. 1918 (2017). The Supreme Court held “that the Government must establish that an illegal act by the defendant played some role in her acquisition of citizenship,” thus establishing a causation element.
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