In the case of Maslenjak v. United States, Divna Maslenjak, a Bosnian Serb refugee who was granted U.S. citizenship in 2007, faced denaturalization after it was discovered that she had made false statements during her naturalization process. She had lied about her husband's service in the Bosnian Serb military during the Yugoslav Wars to gain refugee status and later citizenship for herself and her family. The Supreme Court ruled unanimously in favor of Maslenjak on June 22nd, 2017 stating that simply making false statements is not enough to revoke someone’s citizenship unless those lies are proven to have materially influenced the decision-making process of their admission into the country as a citizen.

In the dissenting opinion for MASLENJAK v. UNITED STATES, Justice Gorsuch, joined by Justice Thomas, argued that the majority's interpretation of the law was too broad and could potentially criminalize minor infractions or innocent mistakes made during naturalization proceedings. They contended that a lie told in the naturalization process should lead to denaturalization only if it played some role in gaining citizenship. The dissenters expressed concern about giving prosecutors too much power over citizens' rights and believed that any falsehoods must be material to affect an individual’s eligibility for citizenship before leading to denaturalization.