Maurice Evans sought court declaration of U.S. citizenship after agency denial of his application
PHILADELPHIA, PA – A federal judge has dismissed a lawsuit filed by Maurice Evans, who claimed to be a U.S. citizen and sought judicial review after the U.S. Citizenship and Immigration Services (USCIS) denied his application for a certificate of citizenship. The court ruled that Evans failed to complete the required administrative appeal before filing suit, depriving it of jurisdiction to hear the case.
Key Points
- Judge Joseph F. Leeson Jr. granted the federal government’s motion to dismiss the case.
- The court ruled Evans failed to exhaust administrative remedies by not appealing the denial to the Administrative Appeals Office.
- The decision found that the Declaratory Judgment Act does not provide an independent basis for jurisdiction.
Citizenship claim denied after failed N-600 application
Evans filed an Application for Certificate of Citizenship (Form N-600) with USCIS seeking official recognition as a U.S. citizen. When the agency denied the application on May 7, 2025, Evans filed an amended complaint in federal court, arguing that the decision violated his rights under federal law.
He requested that the court conduct a de novo review under 8 U.S.C. § 1503, which allows individuals to seek a declaration of citizenship following a final administrative denial. Evans also cited the Declaratory Judgment Act and the Administrative Procedure Act, alleging that USCIS’s handling of his case was unlawful.
Court: appeal to agency required before judicial review
Judge Leeson agreed with government attorneys that Evans’s lawsuit was premature because he did not first appeal the USCIS denial to the Administrative Appeals Office (AAO)—a required step under federal immigration regulations.
“The failure to appeal the denial of that decision to the Administrative Appeals Unit … is a jurisdictional prerequisite of 8 U.S.C. § 1503(a), the failure of which deprives this Court of subject matter jurisdiction,” Leeson wrote in the opinion issued February 24, 2026.
The court rejected Evans’s argument that the Declaratory Judgment Act gave it authority to hear the case, explaining that the Act “does not create an independent basis for jurisdiction.”
Case dismissed for lack of jurisdiction
Because Evans did not pursue the appeal within the prescribed timeframe, the court dismissed his case under Federal Rule of Civil Procedure 12(b)(1) for lack of subject matter jurisdiction.
The judge also denied Evans’s request for oral argument, finding the issues were adequately addressed in the written filings.
The case, Evans v. United States Citizenship and Immigration Services et al., No. 5:24-cv-6593, was heard in the U.S. District Court for the Eastern District of Pennsylvania.
Tags: Philadelphia, USCIS, citizenship
