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Justia Daily Opinion Summaries

US Court of Appeals for the First Circuit
April 6, 2020

Table of Contents

Perrier-Bilbo v. United States

Civil Rights, Constitutional Law, Immigration Law

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US Court of Appeals for the First Circuit Opinions

Perrier-Bilbo v. United States

Docket: 18-2085

Opinion Date: April 3, 2020

Judge: Torruella

Areas of Law: Civil Rights, Constitutional Law, Immigration Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of the United States and the Director of the United States Citizenship and Immigration Services (collectively, the Government) on Plaintiff's claims that the inclusion of the phrase "so help me God" at the end of the both of allegiance administered at United States naturalization ceremonies is unlawful and unconstitutional, holding that the district court correctly denied Plaintiff's claims. In her complaint, Plaintiff argued that the inclusion of "so help me God" as a means of completing the naturalization oath violates the First and Fifth Amendments and the Religious Freedom Restoration Act, 42 U.S.C. 2000bb-2000bb-4 (RFRA). The district court granted summary judgment on all claims. The First Circuit affirmed, holding that the phrase "so help me God" in the oath does not violate the Establishment Clause, the Free Exercise Clause, the RFRA, Equal Protection, or the Due Process Clause.

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