A Filipino man who was accepted as a U.S. citizen 16 years ago but left the country without taking the oath of allegiance in “the familiar public ceremony” has lost his court bid for a certificate of naturalization.

Holding Jaime Escaler failed to exhaust his administrative remedies before turning to the courts, the 2nd U.S. Circuit Court of Appeals ruled it was without jurisdiction to review his claim that immigration officials were wrong to deny him citizenship because he failed to take the oath as required by law.

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