In Kungys v. United States (1987), the Supreme Court considered whether Juozas Kungys, a naturalized U.S. citizen originally from Lithuania, should be denaturalized due to false statements he made during his immigration and naturalization process about his birth date and place of residence during World War II. The government argued that these falsehoods were material because they could have influenced the decision-making process of immigration officials. However, Kungys contended that his misrepresentations were not material as they did not affect the final outcome of obtaining citizenship status. The court held in a 5-4 decision that while Kungys had indeed lied on both occasions, this was insufficient grounds for revoking his citizenship since there was no evidence proving these lies significantly influenced the decisions regarding his immigration or naturalization status - thus establishing "materiality" as an essential element in such cases. Furthermore, it ruled out any direct involvement by him in Nazi war crimes despite allegations against him being part of a mobile killing unit responsible for mass murder of Jews during WWII; stating lack of clear proof beyond reasonable doubt required under criminal law standards.

In the dissenting opinion for Kungys v. United States, Justice Stevens argued that the majority's decision to revoke citizenship based on false statements made during naturalization proceedings was too harsh and inconsistent with previous rulings. He contended that not all lies should be grounds for denaturalization, only those directly related to statutory requirements of citizenship. In this case, he believed that Kungys' misrepresentations about his date and place of birth were irrelevant to his eligibility for U.S. citizenship as they did not pertain to any statutory requirement or conceal disqualifying facts such as criminal history or affiliation with prohibited organizations. Moreover, Stevens criticized the majority's interpretation of "materiality," arguing it could potentially lead to unjust outcomes where minor falsehoods result in severe penalties like loss of nationality.