William Anthony Richards v. Secretary of State, Department of State, United States of America

William Anthony Richards was issued a Certificate of Loss of Nationality by the Department of State (“the Department”) on June 22, 1978. The Department found that he had expatriated himself on February 23, 1971, when he became a citizen of Canada and, in doing so, took an oath of allegiance to the Queen of England and expressly renounced allegiance to any other sovereign. Richards brought this suit seeking a declaration that the procedures the Department used in issuing the Certificate violated the due process, equal protection, and bill of attainder clauses of the Constitution. U.S. Const, amend. V; U.S. Const, art. I, § 9, cl. 3. He also sought a declaration that he is a citizen of the United States. The district court declined to reach the constitutional claims, finding that a de novo trial to determine whether or not he is a United States citizen would provide him full relief. The district court conducted such a trial and concluded that Richards is not a United States citizen. Richards appeals. We affirm.

FACTS

William Anthony Richards acquired United States citizenship when he was bom in San Luis Obispo, California, on September 13, 1938. He received a Bachelor of Arts…