United States v. Stelmokas
United States Court of Appeals for the Third Circuit
100 F.3d 302 (3d Cir. 1996), cert. denied, 520 U.S. 1241 (1997)
Jonas Stelmokas faced revocation of his U.S. citizenship over allegations he had voluntarily served with Nazi-allied Lithuanian forces that helped murder Jews, and later served in the German Luftwaffe. The government relied on documents from former Soviet archives and German archives (including one showing Stelmokas was hospitalized in Germany while in the Luftwaffe) and presented Holocaust expert witnesses who testified to the documents' authenticity. Stelmokas appealed his citizenship revocation, arguing these documents were never properly authenticated.
Whether an ancient document is properly authenticated where it is in a condition creating no suspicion as to authenticity, was found where such a document would likely be, and has existed for 20 years or more.