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Administrative Law Keyed to Breyer
United States v. Mendoza
Citation:
464 U.S. 154 (1984)Facts
Sergio Mendoza served as a doctor in the Philippine Commonwealth Army from 1941 until 1946. He sought naturalization under the Nationality Act of 1940, which provided special naturalization privileges for noncitizens who served in the U.S. Armed Forces during World War II. The Act required applications to be filed by December 31, 1946. Due to Japanese occupation and diplomatic concerns raised by the Philippine government, the U.S. halted naturalizations in the Philippines for a nine-month period from late 1945 to August 1946. Mendoza claimed this gap in naturalization services violated his due process rights. The government opposed his petition, but the lower courts held that the government was collaterally estopped from litigating the constitutional issue because it had lost on the same issue in a prior case (68 Filipinos) that it chose not to appeal.
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