United States v. Hirani, No. 15-1583 (8th Cir. 2016)
Annotate this CaseThe United States filed suit against appellant under 8 U.S.C. 1451(a), seeking revocation of appellant's citizenship and cancellation of his certificate of naturalization. The United States alleged that appellant procured his naturalization illegally, or alternatively, that appellant procured naturalization by material misrepresentation or concealment. The court granted the United States summary judgment. The court concluded that, because circumstantial evidence is compatible with the evidentiary standard applicable to denaturalization proceedings, the district court did not err by considering circumstantial evidence to find appellant had willfully concealed or misrepresented material facts; the district court did not err by considering appellant’s prior use of the names Rakeshkumar Patel and Rakesh Hirani outside the naturalization context; the undisputed facts established clear, unequivocal, and convincing evidence to revoke appellant’s citizenship and to cancel appellant’s certificate of naturalization on the basis of representation or concealment of a material fact; and the court declined to consider a collateral challenge to the 1995 deportation order. Accordingly, the court affirmed the judgment.
Court Description: Gritzner, Author, with Smith and Colloton, Circuit Judges] Civil case - Revocation of Citizenship. The government established beyond a reasonable doubt that Hirani procured his naturalization by misrepresentation or concealment of information regarding his true name and identity and the court did not err in cancelling his naturalization and revoking his citizenship; Hirani could not use this proceeding to collaterally attack a 1995 deportation order as he failed to exhaust his administrative remedies with respect to that order.
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