Calixto, et al. v. United States Department of the Army, et al., Civil Action No. 18-1551
Court certification of a class and approval of the Settlement Agreement: Through a September 22, 2022 Order (Calixto Docket 257), the Court granted the parties’ Joint Motion for Certification of Class, Appointment of Class Counsel, and Approval of Settlement Agreement (Calixto Docket 253) and thus approved the Settlement Agreement and U.S. Army Certification (Calixto Docket 253-1).
What this means for MAVNI soldiers: The Settlement Agreement removes the last known military service-related impediments to naturalization for MAVNI soldiers and for already-naturalized MAVNI soldiers will remove any risk of de-naturalization based on the nature of their U.S. Army service or any past or future “uncharacterized” discharge.
The Calixto class definition: Calixto class members include all soldiers who enlisted in the U.S. Army (including Selected Reserve of the Ready Reserve/Delayed Training Program (“DTP”) and Regular Army/Delayed Entry Program (“DEP”) soldiers) through the Military Accessions Vital to the National Interest (“MAVNI”) program, and did so on or prior to September 30, 2017, and either:
- have not been discharged, or
- have been discharged by the U.S. Army (including the U.S. Army Recruiting Command and/or the U.S. Army Reserve Command, collectively, the “Army”), where such discharge or separation was not characterized as Honorable, General (under honorable conditions), Under Other Than Honorable Conditions, Bad Conduct, or Dishonorable.
Instructions for Calixto Class Members seeking a Certified N-426: If you (i) are a Calixto class member, (ii) have not been naturalized as a U.S. citizen, and (iii) are pursuing or seek to pursue naturalization on the basis of U.S. military service under INA 329, you should request a certified Form N-426 (Request For Certification of Military or Naval Service). Pursuant to the Settlement Agreement in the Calixto action, you are entitled to receive a certified N-426 for naturalization purposes even if you have not been shipped to Basic Combat Training (“BCT”).
To request the Army’s certification on an N-426, please send an email (with the attachments listed below) using the subject line “MAVNI Settlement – [Insert Your Name]” to this email address: [email protected]. Please include Calixto class counsel on your email by copying this email address: [email protected].
Attach both of the following to your email:
- An N-426 with your sections completed.
- Please use the most current Form N-426 provided by USCIS, which should be available on the USCIS website. As of September 2022, the current version was available at https://www.uscis.gov/sites/default/files/document/forms/n-426.pdf. Do not use a form that includes a past-dated expiration date or that is not currently available on the USCIS website.
- At the top of the first page of the N-426 form, above the words “Request for Certification” insert the following: “Pursuant to Calixto Settlement Agreement.”
- Complete the Requestor’s sections of the N-426 form, which request information about you, your enlistment information, your contact information, and your signature/date of signature. It is important that you complete those sections fully and legibly and include your FULL name, personal email address (not military email address unless you use it regularly), physical mailing address, and personal phone number. Please note the following:
- It is important to include your military service number if you have one. However, many Regular Army or Delayed Entry Program (“DEP”) MAVNI soldiers will not have a military service number, and if that is the case for you, you should leave that part of the form blank.
- Some MAVNI soldiers may be uncertain about what to insert as their “Service End Date,” including because they do not know if the Army considers them to be discharged from service. If you have any uncertainty, you may leave that field blank and allow the Army to complete and initial it.
- In the “Type of Service” field, you also may leave that blank as the Army will make the appropriate selection and initial that selection.
- It is important that you insert a handwritten signature (do not use a typed or digital signature).
- A copy of your enlistment contract (DD Form 4).
- If your contract itself is not available for any reason, you may send ANY proof that you entered into a contract to serve in the Army.
- If you cannot locate any of these documents, you may still send your N-426 request to the Army, but it may take longer to complete the certification process.
Once you send this email and attachments, the Army will review them and will email you (copying class counsel) if further information is needed. Once the Army verifies that you are a Calixto class member, it will send you a certified N-426 by email to the same email address you used to submit your request, with a copy to class counsel. You may then, pursuant to INA 329, provide that N-426 to USCIS in support of an existing naturalization application or with an initial N-400 submission.
Key documents from the Calixto action can be found through these links:
- Calixto Docket 19 – August 3, 2018 Amended Complaint
- Calixto Docket 21 – August 3, 2018 Motion for Class Certification
- Calixto Docket 33 – October 1, 2018 Plaintiffs’ (1) Response to Defendants’ Stay Motion (Dkt. 31) and (2) Request for Briefing Schedule and Other Relief
- Calixto Docket 39 – October 5, 2018 Order re: Defendants’ motion for leave to file ex parte and in camera
- Calixto Docket 44 – October 12, 2015 Plaintiffs’ Reply in Support of Motion to Lift Stay
- Calixto Docket 45– October 15, 2018 Defendants’ Status Report
- Calixto Docket 50 – October 31, 2018 Department of the Army October 26, 2018 Memorandum
- Calixto Docket 55 – November 15, 2018 Court Order
- Calixto Docket 61 – January 2, 2019 Second Amended Class Action Complaint
- Calixto Docket 62 – January 2, 2019 Plaintiffs’ Renewed Motion for Class Certification
- Calixto Docket 64 – January 7, 2019 Defendants’ Status Report
- Calixto Docket 71 – February 5, 2019 Status Report
- Calixto Docket 73 – February 8, 2019 Reply Memorandum in Support of Plaintiffs’ Renewed Motion for Class Certification and Appointment of Counsel
- Calixto Docket 74 – February 8, 2019 Plaintiffs’ Opposition to Defendants’ Motion to Dismiss
- Calixto Docket 75 – February 15, 2019 Defendants’ Reply Memorandum in Further Support of Motion to Dismiss for Lack of Subject Matter Jurisdiction
- Calixto Docket 76 – February 19, 2019 Status Report
- Calixto Docket 77 – February 25, 2019 Plaintiffs’ Notice of Supplemental Authority
- Calixto Docket 85 – April 15, 2019 Status Report
- Calixto Docket 90 – April 29, 2019 Status Report
- Calixto Docket 91 – May 1, 2019 Defendants’ Answer to Second Amended Class Action Compliant and Affirmative Defenses
- Calixto Docket 92 – May 7, 2019 Reply Memorandum in Support of Plaintiffs’ Renewed Motion for Class Certification and Appointment of Class Counsel
- Calixto Docket 95 – May 16, 2019 Court’s Opinion Denying Defendants’ Motion to Dismiss
- Calixto Docket 97 – May 28, 2019 Defendants’ Status Report
- Calixto Docket 98 – May 30, 2019 Plaintiffs’ Notice Concerning Defendants’ May 28, 2019 Status Report
- Calixto Docket 101 – June 9, 2019 Defendants’ Sur-Reply in Opposition to Plaintiffs’ Motion for Class Certification
- Calixto Docket 102 – June 10, 2019 Defendants’ Status Report
- Calixto Docket 103 – June 17, 2019 Defendants’ Response to Plaintiffs’ Notice Concerning Defendants’ May 28, 2019 Status Report
- Calixto Docket 104 – June 18, 2019 Plaintiffs’ Response to Defendants’ Sur-Reply in Opposition to Plaintiffs’ Motion for Class Certification
- Calixto Docket 105 – June 24, 2019 Plaintiffs’ Notice Concerning Defendants’ June 17, 2019 Response
- Calixto Docket 106 – June 24, 2019 Defendants’ Status Report
- Calixto Docket 107 – June 25, 2019 Order Resetting Status Conference for July 31, 2019 at 2pm and Describing Filing Deadlines
- Calixto Docket 108 – July 3, 2019 Defendants’ Status Report
- Calixto Docket 109 – July 8, 2019 Plaintiffs’ Supplemental Brief in Support of Class Certification
- Calixto Docket 110 – July 8, 2019 Defendants’ Status Report
- Calixto Docket 111 – July 11, 2019 Defendants’ Status Report
- Calixto Docket 115 – July 22, Defendants’ Reply to Plaintiffs’ Supplemental Brief in Support of Class Certification
- Calixto Docket 116 – July 22, 2019 Defendants’ Status Report
- Calixto Docket 119 – July 23, Order Setting Filing Deadlines
- Calixto Docket 120 – July 26, 2019 Status Report Regarding Needed Class Discovery, Class Certification Proposal, and Results of Review of 13 Files
- Calixto Docket 121 – July 29, 2019 Defendants’ Response to the Court’s July 23, 2019 Order
- Calixto Docket 126 – August 19, 2019 Defendants’ Status Report
- Calixto Docket 127 – August 23, 2019 Defendants’ Status Report
- Calixto Docket 129 – August 23, 2019 Defendants’ Supplemental Status Report
- Calixto Docket 130 – August 29, 2019 Plaintiffs’ Motion to Modify Court-Ordered Deadlines
- Calixto Docket 132 – September 3, 2019 Defendants’ Status Report
- Calixto Docket 136 – September 9, 2019 Defendants’ Status Report
- Calixto Docket 141 – September 16, 2019 Defendants’ Status Report
- Calixto Docket 143 – September 30, 2019 Defendants’ Status Report
- Calixto Docket 144 – October 15, 2019 Defendants’ Status Report
- Calixto Docket 145 – October 22, 2019 Court Order
- Calixto Docket 146 – October 28, 2019 Defendants’ Status Report
- Calixto Docket 147 – November 4, 2019 Defendants’ Response to the Court’s October 22, 2019 Order
- Calixto Docket 149 – November 20, 2019 Defendants’ Status Report
- Calixto Docket 150 – November 25, 2019 Defendants’ Status Report
- Calixto Docket 151 – December 9, 2019 Defendants’ Status Report
- Calixto Docket 153 – January 6, 2020 Defendants’ Status Report
- Calixto Docket 155 – January 21, 2020 Court Order
- Calixto Docket 158 – February 4, 2020 Defendants’ Status Report
- Calixto Docket 160 – February 18, 2020 Defendants’ Response to the Court’s January 21, 2020 Order
- Calixto Docket 161 – March 2, 2020 Defendants’ Status Report
- Calixto Docket 162 – March 9, 2020 Court Order
- Calixto Docket 163 – March 23, 2020 Defendants’ Status Report
- Calixto Docket 164 – April 14, 2020 Defendants’ Status Report
- Calixto Docket 166 – May 27, 2020 Defendants’ Status Report
- Calixto Docket 167 – June 08, 2020 Court Order
- Calixto Docket 169 – July 27, 2020 Defendants’ Status Report
- Calixto Docket 170 – July 29, 2020 Court Order
- Calixto Docket 196 – June 3, 2021 Opinion Granting Plaintiffs’ Motion for Leave to File Third Amended Complaint
- Calixto Docket 201 – July 9, 2021 Joint Status Report
- Calixto Docket 202 – July 23, 2021 Joint Status Report and Motion for Extension
- Calixto Docket 205 – August 24, 2021 Third Amended Class Action Complaint
- Calixto Docket 210 – November 5, 2021 Defendants’ Answer
- Calixto Docket 211 – November 11, 2021 Order
- Calixto Docket 213 – November 22, 2021 Plaintiffs’ Renewed Motion for Class Certification and Appointment of Class Counsel
- Calixto Docket 223 – January 25, 2022 Defendants’ Opposition to Plaintiffs’ Motion for Class Certification
- Calixto Docket 229 – February 15, 2022 Joint Report
- Calixto Docket 233 – March 8, 2022 Order
- Calixto Docket 235 – April 8, 2022 Joint Status Report Regarding Mediation
- Calixto Docket 253 — September 7, 2022 Joint Motion for Certification of Class and Approval of Settlement
- Calixto Docket 257 — September 22, 2022 Order Certifying Class and Approving Settlement Agreement
Please check back periodically as class counsel for the Kirwa, Nio, and Calixto classes will be adding and updating documents and information found on this Site.
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