Maslenjak v. United States

Divna Maslenjak (defendant), an ethnic Serb who fled Bosnia's civil war, obtained U.S. refugee status in 1998 by falsely swearing she feared persecution from Serbs because her husband had evaded military service, when in fact he had served as an army officer involved in massacring Bosnian Muslim civilians. She later lied again on her 2004 naturalization petition, denying she had ever lied to immigration officials, and became a naturalized citizen. After officials discovered the truth, she was prosecuted under 18 U.S.C. § 1425(a) for knowingly and illegally procuring citizenship; the trial judge instructed the jury it could convict without proof her false answers materially influenced her petition's approval, and the jury convicted her, leading the judge to revoke her citizenship. The Sixth Circuit affirmed, and the Supreme Court granted certiorari to resolve a circuit split.