Due to a serious of government missteps, the petitioner never became a U.S. citizen.  The former INS lost his mother's original naturalization application, delaying her naturalization until two months after the petitioner's 18th birthday, and thus, preventing him from deriving citizenship.  When the petitioner applied for naturalization shortly thereafter, the examiner incorrectly told him that he did not need to naturalize because he had derived citizenship through his parents.  The Ninth Circuit previously transferred the petitioner's case to determine if the government officials had acted with deliberate indifference to the petitioner's right to apply for citizenship.  The District Court determined that there was no evidence of deliberate indifference.  The Ninth Circuit affirmed, finding no evidence that any government official was aware that their actions were jeopardizing the petitioner's right to apply for citizenship or that any government policymaker formulated policy that was indifferent to the rights of the petitioner and similarly situated individuals.

The full text of Brown v. Holder can be found here: