Chaunt v. United States (1960)
- Docket
- 22
- Decided
- 1960-01-01
- Category
- General
Summary
Question: Did the Government meet its standard of proof required under the Immigration and Nationality Act to revoke an order of naturalization? Conclusion: No. Justice William O. Douglas delivered the opinion for the 6-3 majority. The Court held that the Government failed to show by “clear, unequivocal and convincing” evidence that Chaunt either concealed facts warranting a denial of citizenship or that their disclosure would have led to the discovery of other facts warranting a denial of citizenship. The arrests did not justify revocation of Chaunt’s citizenship because each arrest occurred outside the statutory requirement of demonstrated good moral character for five years prior to a petition for naturalization, and the charges did not involve moral turpitude. Noting Chaunt’s disclosure of his employment with the International Workers’ Order, an organization purportedly controlled by Communists, the Court declined to find that disclosure of the arrests might have led the INS to discover that Chaunt once served as a district organizer of the Communist Party in Connecticut. Justice Tom C. Clark wrote a dissent in which he argued that the Immigration and Nationality Act only requires that the Government prove that Chaunt’s conduct blocked an investigation that might have resulted in the rejection of his application. He argued that the Government satisfied this test by showing that Chaunt intentionally concealed his arrest record because the INS could have rejected his application if it had discovered this misconduct prior to the court’s naturalization order. Justice Charles E. Whittaker and Justice Potter Stewart joined in the dissent.