Alice Kriegel v. Kristi Noem, Secretary of the Department of Homeland Security; Kevin Riddle, Chicago Field Office Director, U.S. Citizenship and Immigration Service; and U.S. Citizenship and Immigration Service

CourtDistrict Court, N.D. Illinois
DecidedMarch 23, 2026
Docket1:24-cv-00467
StatusUnknown

This text of Alice Kriegel v. Kristi Noem, Secretary of the Department of Homeland Security; Kevin Riddle, Chicago Field Office Director, U.S. Citizenship and Immigration Service; and U.S. Citizenship and Immigration Service (Alice Kriegel v. Kristi Noem, Secretary of the Department of Homeland Security; Kevin Riddle, Chicago Field Office Director, U.S. Citizenship and Immigration Service; and U.S. Citizenship and Immigration Service) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alice Kriegel v. Kristi Noem, Secretary of the Department of Homeland Security; Kevin Riddle, Chicago Field Office Director, U.S. Citizenship and Immigration Service; and U.S. Citizenship and Immigration Service, (N.D. Ill. 2026).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

ALICE KRIEGEL, ) ) Plaintiff, ) No. 24 C 467 v. ) ) Chief Judge Virginia M. Kendall KRISTI NOEM, Secretary of the Department of ) Homeland Security; KEVIN RIDDLE, Chicago ) Field Office Direction, U.S. Citizenship and ) Immigration Service; and ) U.S. CITIZENSHIP AND IMMIGRATION ) SERVICE, ) ) Defendants.

MEMORANDUM OPINION AND ORDER Plaintiff Alice Kriegel seeks review of the denial of her application for naturalization by Defendants Kristi Noem1, Kevin Riddle, and the United States Citizenship and Immigration Services (collectively, “Defendants”) pursuant to 8 U.S.C. § 1421(c). Before the Court are the Parties’ cross-motions for summary judgment. For the reasons set forth below, Kriegel’s Motion for Summary Judgment [33] is denied and Defendants’ Motion for Summary Judgment [32] is granted. BACKGROUND I. Compliance with Local Rule 56.1 Local Rule 56.1 sets out a procedure for presenting facts pertinent to a party’s request for summary judgment. LR 56.1 (N.D. Ill.). Local Rule 56.1 requires the party moving for summary judgment to submit a statement of material facts and a supporting memorandum of law. LR

1 Defendant Kristi Noem was substituted for Alejandro Mayorkas, former Secretary of the Department of Homeland Security. (Dkt. 32-2 ¶ 2); (Dkt. 33-2 ¶ 4). 56.1(a)(1), (2) (N.D. Ill.). Kriegel attached several exhibits to her Response to Defendants’ Local Rule 56.1 Statement of Facts—a chart purporting to show the travel history of Kriegel’s husband, a copy of the Articles of Incorporation for the business co-owned by Kriegel and her husband, and a copy of that business’s “Employer’s and Contribution and Wage Report” from 2017 to 2024.

(Dkts. 39-2. 39-3, 39-4, 39-5). Kriegel also submitted a declaration from her counsel describing the exhibits. (Dkt. 39-2). Defendants ask the Court to strike the exhibits because they do not comply with Local Rule 56.1 and are inadmissible. (Dkt. 1-2). Local Rule 56.1(b)(3) provides that the party opposing summary judgment must file a response to the movant’s statement of facts that contains, in part, a statement of any additional facts with references to supporting evidence. LR 56.1(b)(3) (N.D. Ill.). Kriegel only attached exhibits to her Response, she did not file a statement of additional facts referring to any of the additional evidence. (Dkt. 39). This does not comply with Local Rule 56.1. Moreover, the exhibits are inadmissible. Evidence offered at summary judgment must be admissible to the same extent as at trial. Baines v. Walgreen Co., 863 F.3d 656, 662 (7th Cir. 2017);

Fed. R. Civ. P. 56(c)(2). To be admissible, “[d]ocuments must be authenticated by an affidavit that lays a proper foundation for their admissibility, even at the summary judgment stage.” Steffek v. Client Servs., Inc., 948 F.3d 761, 769 (7th Cir. 2020). None of the documents attached to Kriegel’s response have been properly authenticated because the affidavit is from Kriegel’s counsel, not from Kriegel or her husband. See, e.g., Mechling v. Operator of Website Muaythaifactory.com, 2021 WL 3910752, at *2 (N.D. Ill. Sept. 1, 2021) (an attorney affidavit is not the proper vehicle to authenticate documents where it is not clear whether the attorney has firsthand knowledge of the information therein); Milo Enters., Inc. v. Bird-X, Inc., 2022 WL 874625, at *2 (N.D. Ill. Mar. 24, 2022) (finding declaration from plaintiff’s counsel to be insufficient supporting evidence at summary judgment). Accordingly, the Court will not consider these exhibits. II. Facts The following facts are undisputed unless otherwise indicated. A. Kriegel’s Background

Kriegel is a citizen of Germany. (Dkt. 32-2 ¶ 1); (Dkt. 33-2 ¶ 3). She has been a lawful permanent resident of the United States since January 19, 2010. (Dkt. 33-2 ¶ 12). Kriegel married John Gus Manaves, a U.S. citizen, on January 9, 2009. (Dkt. 32-2 ¶ 2); (Dkt. 33-2 ¶ 12). Together, they have two daughters, both U.S. citizens, ages 15 and 12. (Dkt. 32-2 ¶ 2); (Dkt. 33-2 ¶ 40). Kriegel and Manaves currently own a town home in Chicago, Illinois. (Dep. of Alice Kriegel, Ex. A, Dkt. 33-4 at 18:21-19:4); (Dkt. 33-2 ¶ 29). Kriegel testified that she and her family have lived in this home since 2022. (Dkt. 33-4 at 17:20-18:6, 19:5-7). From 2013 to 2022, Kriegel and her husband owned a condominium in Chicago, Illinois. (Dkt. 33-2 ¶ 26). Kriegel testified that she and her family lived there during that time. (Dkt. 33-4 at 18:9-20, 19:8-10). Kriegel and Manaves are co-owners of Mana, Inc. (“Mana”), an architecture firm. (Dkt.

32-2 ¶ 18); (Dkt. 33-2 ¶ 31). They started Mana in 2012. (Dkt. 33-2 ¶ 31). Manaves also owns Scalaplus, Inc. (“Scalaplus”). (Dkt. 32-2 ¶ 22); (Dkt. 33-2 ¶ 34). Mana and Scalaplus share a main office in Chicago, Illinois and an office in Kiel, Germany. (Dkt. 32-2 ¶¶ 19, 22); (Dkt. 33-2 ¶¶ 31, 34, 38). Kriegel has worked at Scalaplus since 2016. (Dkt. 33-2 ¶ 36). Mana and Scalaplus are connected; Mana does design work, and Scalaplus consults on larger projects. (Dkt. 33-2 ¶ 35). Through the two companies, Kriegel and Manaves work on architecture projects together. (Dkt. 32-2 ¶ 24). Kriegel works at the Chicago office two-to-three days per week when she is in the United States, and she works remotely when she is in Germany. (Dkt. 33-2 ¶ 37). Manaves works from the Kiel office when he is in Germany. (Dkt. 33-4 at 41:24- 42:7). Kriegel is licensed as an architect in Germany, but not in the United States. (Dkt. 32-2 ¶ 25); (Dkt. 33-2 ¶ 30). For projects in the United States, Kriegel drafts designs, and Manaves, who is a licensed architect in Illinois, stamps the final drawings. (Dkt. 33-2 ¶ 30). This is a common

practice in the architecture industry. (Dkt. 33-4 at 96:21-97:3). Mana has never had any projects outside of the United States, while Scalaplus has had several projects in Germany. (Dkt. 33-2 ¶ 38). Since January 2017, Kriegel has never been employed in Germany. (Dkt. 33-2 ¶ 39). Kriegel’s mother, father, and brother live in Germany. (Dkt. 33-2 ¶¶ 44, 46). In June 2016, Kriegel’s mother broke her wrists and nose in a series of falls. (Dkt. 32-2 ¶ 7); (Dkt. 33-2 ¶ 45). Kriegel went to Germany in 2016 for two-to-three months to care for her mother after her injuries. (Dkt. 32-2 ¶ 8); (Dkt. 33-2 ¶ 48). Kriegel returned to Germany on June 17, 2017, and stayed there for 201 days to care for her mother. (Dkt. 32-2 ¶ 9); (Dkt. 33-2 ¶ 49); (Dkt. 33-4 at 54:22-55:1). Kriegel also went to Germany at this time because she had enrolled in a doctorate program at the Christian-Albrecht University in Kiel, Germany to pursue a Ph.D. in historical architecture, and

because Manaves was participating in a program in Holland and Germany. (Dkt. 32-2 ¶¶ 15-16); (Dkt. 33-2 ¶¶ 51-53); (Dkt. 33-4 at 54:22-55:1). The doctorate program required Kriegel to spend extended periods of time in Kiel to conduct research, meet with her professor, and study archival work. (Dkt. 32-2 ¶ 17); (Dkt. 33-2 ¶ 54). Kriegel testified that she did not work during this period because she started her Ph.D. (Dkt. 33-4 at 60:19-61:2). Kriegel’s daughters came with her, and Manaves visited on most weekends from his program. (Dkt. 32-2 ¶¶ 11, 14-15); (Dkt. 33-2 ¶ 41); (Dkt. 33-4 at 59:7-13). Kriegel and her family returned to the United States on January 5, 2018 after spending the holidays with Kriegel’s parents. (Dkt. 32-2 ¶ 6); (Dkt. 33-2 ¶ 49).

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Alice Kriegel v. Kristi Noem, Secretary of the Department of Homeland Security; Kevin Riddle, Chicago Field Office Director, U.S. Citizenship and Immigration Service; and U.S. Citizenship and Immigration Service, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alice-kriegel-v-kristi-noem-secretary-of-the-department-of-homeland-ilnd-2026.