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.”
Gilberto Ernesto Edwards was born in Panama in 1965 and was admitted to the US as a lawful permanent resident in 1977. In 1982, Edwards was mother naturalized as a US citizen. At that time, Edwards was 17 years old and lived with his mother. Although living separately, Edwards’ father naturalized as a United States citizen, and in 1985, his parents divorced. Edwards applied for and received a United States passport in 1991, submitting his parents’ naturalization certificates and his own birth certificate as support.