Third Circuit: Krzyszof Koszelnik v. Secretary

Immigration, Administrative, Statute of Limitations

When deportation proceedings against alien were initiated, the agency lost jurisdiction over the subsequent naturalization proceedings, which were void from the beginning.

Statute of limitations shields the present status of the alien, but does not create an entitlement to the next step to citizenship.

Given past misrepresentations, no equitable claim against harshness of citizenship bar.


Krzyszof Koszelnik v. Secretary