Valadez Moran v. Mayorkas

Background

Adrian Valadez Moran sought a declaration under 8 U.S.C. § 1503 and 28 U.S.C. § 2201 that he is a United States citizen. He was born in Durango, Mexico, on January 10, 1994. He claimed citizenship through his mother, Juana Maria Moran Maldonado, based on her alleged birth in Elsa, Texas.

The defendants—Alejandro Mayorkas, Ur Mendoza Jaddou, and Leslie Tritten—were sued in their official capacities as heads of federal agencies or offices involved in administering the immigration and naturalization system. The case was tried before the court on December 18, 2023. Adrian Valadez Moran presented fifteen exhibits and two live witnesses, including himself and his mother. The defendants presented five exhibits and no live testimony.

Findings about Ms. Moran

The court found that Ms. Moran was more likely than not born in Elsa, Texas, on April 27, 1975. Evidence supporting that finding included Mexican and Texas birth records identifying Elsa as her birthplace, school and medical records, affidavits from her parents, testimony from Ms. Moran and her son, and a 2008 U.S. passport issued to Ms. Moran.

The defendants relied in part on a statement Ms. Moran’s mother signed during a 2009 interview at a U.S. consulate. In that statement, she said Ms. Moran had actually been born in Durango, Mexico. The court found that statement not credible because it conflicted with her earlier sworn statement, the consistent statements of Ms. Moran’s father, other family testimony, and the Department of State’s conduct after the interview. The court also credited Ms. Moran’s testimony that consular interviewers pressured her to sign a statement about her citizenship.

The court further found that Ms. Moran was physically present in the United States continuously from 1987 to 1992, for at least five years before Adrian Valadez Moran’s birth, and that she was older than fourteen for at least two of those years. The defendants did not present evidence about her whereabouts during that period.

Legal conclusions

The court determined that it had jurisdiction under 8 U.S.C. § 1503(a) because Adrian Valadez Moran filed the case within five years after the final administrative denial of his citizenship application, and the case was not connected to removal proceedings.

Under the law in effect on January 10, 1994, 8 U.S.C. § 1401(g) provided citizenship at birth to a person born outside the United States if a parent was a U.S. citizen who had been physically present in the United States for at least five years before the child’s birth, including at least two years after the parent turned fourteen. The court concluded that Ms. Moran was a U.S. citizen because she was born in Texas and that she satisfied the physical-presence requirement. It therefore found that Adrian Valadez Moran met the requirements for U.S. citizenship by birth.

The parties disputed the required standard of proof. The defendants argued that Adrian Valadez Moran had to prove citizenship by a preponderance of the evidence. He argued that he needed only to make an initial showing of citizenship, after which the defendants would have to prove his lack of entitlement by clear and convincing evidence. The court did not decide which standard applied because it found that he prevailed under either standard.

Rulings

The court declared that Adrian Valadez Moran is a citizen of the United States and is entitled to the rights and privileges of that status. It ordered that judgment be entered accordingly.

The court also ruled on three defense motions in limine, which are requests to exclude evidence before or during trial:

- The motion to exclude Mr. Santos Moran’s affidavit about birth facts was denied as moot after the defendants withdrew it. - The motion to exclude the affidavits of Ms. Moran and Mr. Moran was denied. - The motion to exclude documents related to Ms. Moran’s polygraph examination was denied.

Finally, the court granted Adrian Valadez Moran’s request under 8 U.S.C. § 1503(a) for a declaratory judgment that he is a U.S. citizen based on 8 U.S.C. § 1401(g) (1994).