Jaen was born on May 12, 1972 in Panama. At the time of Jaen’s birth, his mother, Leticia Rogers Boreland, was married to U.S.-citizen named Jorge Boreland. Jaen’s Panamanian birth certificate, however, lists Liberato Jaen as his father, a man with whom Leticia had an extramarital relationship during her marriage to Jorge. the sole question presented in this appeal is whether Jorge Boreland was Jaen’s “parent” for the purposes of having acquired United States citizenship at birth under former INA § 301(a)(7). The court held that the INA incorporates the common law meaning of “parent” into former Section 1401(a)(7), such that a child born into a lawful marriage is the lawful child of those parents, regardless of the existence or nonexistence of any biological link.
The full text of Jaen v. Sessions can be found here: