Cancellation of Certificates of Citizenship BIA Case


On June 2, the Board of Immigration Appeals (BIA) issued an interesting decision in Matter of Bright Idada Falodun. The decision can be found here:


In this case, Falodun was born in Nigeria in 1981. Falodun claimed to have derived U.S. citizenship from the naturalization of his custodial adoptive father in 1995. In 1998, after filing an N-600, Falodun was issued a Certificate of Citizenship. In 2003, INS (the predecessor to USCIS) concluded that Falodun’s Certificate of Citizenship had been obtained by fraud. INS determined that Falodun’s alleged adoptive father was actually his biological brother, and that Falodun had submitted a fraudulent adoption certificate. Therefore, INS concluded that Falodun did not derive U.S. citizenship, and cancelled his Certificate of Citizenship.


This case is important for all of us because it is a good reminder that a Certificate of Citizenship, which is obtained by filing an N-600, is not the same as a Certificate of Naturalization, which is obtained by filing an N-400. A Certificate of Citizenship does not confer citizenship; it is merely evidence of citizenship. A Certificate of Citizenship can therefore be cancelled without a judicial determination of the individual’s citizenship status. A Certificate of Naturalization, however, does confer citizenship and therefore cannot be cancelled without the person’s citizenship being revoked through judicial proceedings in federal court.

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