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Section 340(a) of the Immigration and Nationality Act of 1952 provides that a naturalized citizen can be denaturalized" if naturalization was "illegally procured or. . . procured by concealment of a material fact or by willful misrepresentation." 2 In recent years, courts have disagreed as to the precise standard of materiality appropriate in proceedings under this section.3 There is no doubt that a suppressed fact is material if it would have justified denial of naturalization. 4 In some cases, however, a concealed fact, although not sufficient in itself to justify denial of naturalization in the initial proceeding, might have led to the discovery of other facts that would have justified denial. The currentdispute concerns the precise meaning of "material fact" in this context. Courts taking divergent positions on this issue have relied on Chaunt v. United States,5 a 1960 Supreme Court decision construing "material fact" in a somewhat different

Concealment of Facts Forestalling an Investigation in Denaturalization Proceedings