Third Circuit Clarifies Passport As Proof of Citizenship Rule

By | Virgin Islands Law Blog | October 9, 2013
Third Circuit Clarifies Passport As Proof of Citizenship Rule

In the recent case of Edwards v. Bryson (2013 WL 4504783 (C.A.3 (Pa.) Aug. 26, 2013), the United States Court of Appeals, Third Circuit reaffirmed its prior decision in United States v. Moreno (3d Cir. July 3, 2013), in which the court held that a passport will serve as conclusive proof of United States citizenship only if “its holder was actually a citizen of the United States when the passport was issued.”