Whether the plurality decision in Kungys v. United States has caused confusion and varied interpretations by lower courts

QUESTIONS PRESENTED 1. Whether the plurality decision in Kungys v. United States, 485 U.S. 759, 108 S. Ct. 1537, 99 L. Ed. 839 (1988) addressing the procurement element of a claim based on 8 U.S.C. § 1451(a) has caused such confusion and varied and conflicting interpretations by lower courts as to merit a reexamination of the legal test for the proof of procurement. 2. Whether the courts below failed to require that the United States prove, by clear, unequivocal and convincing evidence that Petitioner illegally procured naturalized citizenship by the willful concealment of information during the naturalization process, as required by Kungys, 485 U.S. 759, 108 S. Ct. 1537, 99 L. Ed. 839 (1988) and as addressed in Maslenjak v. United States, 582 U.S. __, 187 S. Ct. 1918, 198 L. Ed. 2d 460 (2017).