CA6 on Natz. Exhaustion, Jurisdiction: Shweika v. DHS

"For the past nine years, Mazen Shweika (“Shweika”) has prosecuted a single application for naturalization before both the United States Citizenship and Immigration Services (“USCIS”) and the U.S. District Court for the Eastern District of Michigan. This ongoing process now raises a narrow question: Does the administrative-hearing requirement in 8 U.S.C. § 1421(c) establish a jurisdictional limitation on judicial review of the denial of an application for naturalization? We answer the question in the negative and conclude that the district court erred in determining that it lacked subject-matter jurisdiction. Accordingly, we VACATE the district court’s judgment and REMAND for proceedings consistent with this opinion." - Shweika v. DHS, July 25, 2013.

[Hats off to Michael R. Dezsi!]