No one was surprised by the Supreme Court’s unanimous decision in Maslenjak v. United States, which held that the government cannot revoke citizenship based on an immaterial false statement in a naturalization application. Indeed, the lower court’s decision was so obviously wrong that commentators speculated about why the government chose to defend it rather than concede error. Maslenjak is significant not for its result, but rather because all nine members of the Court assumed that Congress would not revoke citizenship lightly. Before relegating Maslenjak to the dust bin of Supreme Court history, we should take a moment to remember that for much of the Twentieth Century, the opposite was true—and that it took the U.S. Supreme Court to change not only the law, but also the public’s perception of the value of citizenship. In short, Maslenjak is the quiet culmination of a Supreme Court revolution.

Amanda Frost, Maslenjak v. United States: Immigration, Expatriation, and the Plenary Power Doctrine, 2016-2017 ACS Supreme Court Review, 49–77 (2017).