Kungys v. United States
Supreme Court of the United States
485 U.S. 759 (1988)
Kungys (plaintiff), who emigrated from Germany in 1947 and gained U.S. citizenship in 1954, faced denaturalization proceedings the government initiated in 1982 on three grounds: alleged participation in executing Lithuanian citizens in 1941 (which the district court found insufficiently supported by unreliable Soviet depositions), false statements in his naturalization petition about his birth date, birthplace, wartime occupation, and residence (which the district court found made but not material under the Chaunt standard), and lack of good moral character under §§ 316(a) and 101(f)(6) due to those same false statements (which the district court also found not covered because not material). The government appealed only the latter two grounds; the Third Circuit reversed on materiality of the misrepresentation and agreed a materiality showing was needed for the good moral character analysis, and Kungys appealed to the Supreme Court.
Whether (1) establishing that a misrepresentation is "material" for purposes of § 340(a) of the Immigration and Nationality Act requires the misrepresentation to have a natural tendency to produce the conclusion that the applicant was qualified for citizenship, and (2) § 101(f)(6) of the Immigration and Nationality Act contains a materiality requirement for false testimony.