United States v. Karnail Singh

── United States v. Karnail Singh ── Court: Court of Appeals for the Sixth Circuit Date: May 05, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0130p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ UNITED STATES OF AMERICA, │ Plaintiff-Appellee, │ > No. 25-1523 │ v. │ │ KARNAIL SINGH, │ Defendant-Appellant. │ ┘ Appeal from the United States District Court for the Eastern District of Michigan at Detroit. No. 2:13-cr-20551-1—David M. Lawson, District Judge. Decided and Filed: May 5, 2026 Before: GRIFFIN, THAPAR, and NALBANDIAN, Circuit Judges. _________________ COUNSEL ON BRIEF: Firooz T. Namei, MCKINNEY & NAMEI CO., L.P.A., Cincinnati, Ohio, for Appellant. Jessica V. Currie, UNITED STATES ATTORNEY’S OFFICE, Detroit, Michigan, for Appellee. THAPAR, J., delivered the opinion of the court in which NALBANDIAN, J., joined, and GRIFFIN, J., joined in the judgment. GRIFFIN, J. (pp. 11–12), delivered a separate concurring opinion concurring in the judgment only. _________________ OPINION _________________ THAPAR, Circuit Judge. Karnail Singh, a naturalized U.S. citizen, pled guilty to using a passport that he fraudulently obtained. He now seeks to set aside that conviction, claiming he received ineffective assistance of counsel. Singh argues that his attorney should have explained  No. 25-1523 United States v. Singh Page 2 that his guilty plea could lead to denaturalization. But the Sixth Amendment doesn’t require attorneys to advise naturalized citizens that a guilty plea may carry the risk of denaturalization and eventual deportation. So we affirm. I. Karnail Singh, a native of India, illegally entered the United States decades ago and then applied for asylum. The government denied that application and ordered him deported. But that didn’t deter Singh. Instead of leaving the country, he submitted another asylum application listing a different name, birth date, place of birth, and parents. None of this new information was true. Singh then married an American citizen and applied for permanent-resident status, using the same false information listed on his second asylum application. On that residency application, Singh claimed that he had never been denied an immigration benefit and had never provided false information on an immigration form before. Of course, neither statement was true. But based on these misrepresentations, the government granted Singh permanent-resident status. A few years later, Singh became a naturalized U.S. citizen. As a new citizen, Singh obtained a U.S. passport. Following a trip abroad, he attempted to reenter the United States using that passport. Officers at the border crossing asked Singh if he had ever used any other names or birth dates. Singh replied that he hadn’t. But that, once again, wasn’t true. So the government charged him with using a fraudulently obtained passport and making a false statement to federal agents. Singh eventually pl