3.1 Precedents Cited

A. Naturalization burdens and “strict compliance”

• Berenyi v. Dist. Dir., Immigr. & Naturalization Serv.: The Court invoked Berenyi for two foundational propositions in naturalization law: (1) the applicant bears the burden to prove eligibility “in every respect,” and (2) doubts are resolved “in favor of the United States and against the claimant.” This frames the case as one where Savane must affirmatively prove lawful admission; the Government need not prove ineligibility beyond doubt.
• Koszelnik v. Sec'y of Dep't of Homeland Sec.: The Court relied heavily on Koszelnik for the Third Circuit’s approach to “lawfully admitted for permanent residence”: lawful admission requires substantive compliance with immigration law, not “mere procedural regularity.” Koszelnik also supplied the key bridge between naturalization eligibility and misstatements on the DS-230, treating compliance with 8 C.F.R. § 103.2(a)(2) as a substantive prerequisite to lawful admission.
• Gallimore v. Att'y Gen. of United States: Cited through Koszelnik to reinforce that an LPR grant is not “lawful” if the person “was not legally entitled to it for any reason.”

B. The Third Circuit’s definition of immigration “materiality”

• Mwongera v. Immigration & Naturalization Services: This case supplied the controlling two-prong materiality test for immigration forms: (1) excludable on the true facts, or (2) the misrepresentation “tends to shut off a line of inquiry” relevant to eligibility that “might well” have led to exclusion. Savane attempted to collapse materiality into prong (1); the Court reaffirmed prong (2) as independently sufficient.
• Kungys v. United States: The Court used Kungys to align the Third Circuit’s “shut off a line of inquiry” formulation with the Supreme Court’s “natural tendency to influence” standard, and to confirm materiality is not a “but for” inquiry. Kungys also supported applying a consistent materiality concept across INA contexts.
• Saliba v. Att'y Gen. of United States: Used to explain how Mwongera and Kungys “work hand in glove,” and as the source (quoted by the district court) for the “tends to shut off a line of inquiry” formulation.
• United States v. Stelmokas: Cited to justify applying the Kungys materiality framework across different INA processes (e.g., visa applications vs. citizenship-related questions), emphasizing procedural differences do not fragment the materiality definition.

C. The regulation-focused path: DS-230 certification and omission-based materiality

• Injeti v. U.S. Citizenship & Immigr. Servs.: The majority drew from Injeti the idea that under 8 C.F.R. § 103.2(a)(2), omission of material information violates the “true and correct” certification requirement “regardless of whether the misrepresentation … was willful.” The Third Circuit adopted that approach as consistent with its own Koszelnik analysis.

D. Procedure and appellate posture

• Alcoa, Inc. v. United States and Stratechuk v. Bd. of Educ., S. Orange-Maplewood Sch. Dist.: Standard de novo review of summary judgment and viewing facts in the nonmovant’s favor.
• Laurel Gardens, LLC v. Mckenna: Cited for the appellate principle that the Court may affirm on any ground supported by the record—used here to pivot away from the district court’s reliance on State Department guidance and instead ground materiality in the public-charge statute.

E. Administrative-law backdrop raised by the parties

• Loper Bright Enterprises v. Raimondo: Savane argued that reliance on regulations and guidance improperly expanded statutory requirements. The Court held Loper Bright was inapplicable because it was not interpreting an ambiguous statute in a way that would require deference; the decision was driven by materiality under statutory factors (public charge), not deference to agency interpretations.

F. Concurrence-only authorities

• TRW Inc. v. Andrews and Duncan v. Walker: The concurrence invoked the canon against surplusage to stress Congress’s inclusion of a willfulness element in 8 U.S.C. § 1182(a)(6)(C)(i).
• United States v. Dunnigan and 18 U.S.C. § 1621: The concurrence suggested the regulation’s “penalty of perjury” language naturally connotes willfulness and questioned reading willfulness out of the scheme.
• In re Wettach: Cited for forfeiture principles; used to explain why willfulness was not decided because Savane did not develop the argument on appeal.

3.2 Legal Reasoning

A. The eligibility hinge: “lawfully admitted for permanent residence”

The opinion treats “lawful admission” as a substantive condition. Even if the Government once granted LPR status, the status is not “lawful” for naturalization purposes if it was obtained without compliance with substantive legal requirements. This is the doctrinal move that allows USCIS to deny naturalization years later based on defects in the underlying visa process.

B. The operative legal requirement: truth-and-correct certification

The Court grounded the analysis in 8 C.F.R. § 103.2(a)(2), which requires that by signing a “benefit request” the applicant certifies, under penalty of perjury, that the request and supporting evidence are “true and correct.” Via Koszelnik v. Sec'y of Dep't of Homeland Sec., the Court treated this as a “substantive legal requirement” whose violation means the person was never lawfully admitted.

C. Materiality: not a “but for” test

Savane argued that omission is material only if truthful disclosure would have changed the consular decision. The Court rejected that as inconsistent with Mwongera v. Immigration & Naturalization Services and aligned with Kungys v. United States. The key point is structural: immigration systems depend on truthful disclosure to permit inquiry; materiality is satisfied when the omission forecloses relevant inquiry that might well have led to exclusion, even if the reviewing court cannot reconstruct what would have happened.

D. Why the omission of children was material in this case

The Court affirmed materiality because the omission prevented inquiry into statutory admissibility—specifically, public-charge inadmissibility under 8 U.S.C. § 1182(a)(4)(A). The statute requires consideration of “family status” and financial resources under 8 U.S.C. § 1182(a)(4)(B). Children are directly relevant to:

• whether the applicant has dependents requiring financial support;
• whether the applicant remits funds abroad, affecting available resources;
• the applicant’s overall household and financial obligations at the time of entry.

The Court emphasized that the uncertainty created by the passage of time cannot redound to the applicant’s benefit because the applicant’s omission caused the uncertainty by depriving the consular officer of a chance to investigate.

E. The Court’s treatment of agency materials and Loper Bright

The district court had relied in part on State Department regulations and the Foreign Affairs Manual, including policies about discrepancies between the eDV and the DS-230. On appeal, the Third Circuit chose a narrower and sturdier ground: it affirmed on statutory public-charge materiality. That move diminished the need to resolve whether agency guidance could “add” requirements, and it allowed the Court to dispose of Savane’s Loper Bright Enterprises v. Raimondo argument by stating that no deference-based statutory interpretation was at issue.

F. The concurrence: a live doctrinal tension left unresolved

Judge Freeman agreed the misrepresentation was material but questioned the majority’s reliance on 8 C.F.R. § 103.2(a)(2) to bypass the INA’s willfulness element in 8 U.S.C. § 1182(a)(6)(C)(i). The concurrence signaled that (i) Congress expressly required “fraud or willfully misrepresenting a material fact” for inadmissibility on this ground, and (ii) a regulation should not be read to negate statutory elements, especially outside adjustment-of-status contexts where the INA delegates broad regulatory discretion. But because Savane did not develop a willfulness argument, the concurrence treated the point as forfeited and joined the judgment.

3.3 Impact

• Stronger “line of inquiry” materiality for omission cases in the Third Circuit. The Court crystallized a rule that an omission is material when it prevents investigation into a relevant aspect of eligibility, even if the missing information might not have changed the outcome. This is an omission-friendly articulation for the Government and an evidentiary challenge for applicants seeking to prove lawful admission years later.
• Public-charge inquiry as a broad relevance hook. By anchoring materiality in 8 U.S.C. § 1182(a)(4)(A) and “family status” under 8 U.S.C. § 1182(a)(4)(B), the opinion makes family-related omissions (children, dependents, household obligations) especially perilous, because they predictably affect the financial picture the statute requires officials to assess.
• Naturalization denials can function as retroactive legality audits. The decision reinforces that naturalization adjudication—and district court review under 8 U.S.C. § 1421(c)—may revisit the legality of the original admission. Practically, applicants with historical application discrepancies face heightened risk of denial regardless of long residence.
• Regulation-versus-statute “willfulness” question remains open in future cases. Although the majority applied 8 C.F.R. § 103.2(a)(2) without requiring willfulness, the concurrence frames a serious future litigation issue: whether the INA’s willfulness requirement in 8 U.S.C. § 1182(a)(6)(C)(i) should control in contexts like diversity-visa admissions. Litigants who properly preserve willfulness arguments may press for en banc review or Supreme Court attention.