Honorary citizenship of the United States by proclamation. What rights and privileges honorary citizenship bestows, if any, is unclear. According to State Department documents, it does not grant eligibility for United States passports. Despite widespread belief that Lafayette received honorary citizenship of the United States before Churchill, he did not receive honorary citizenship until 2002. Lafayette did become a natural-born citizen during his lifetime. On 28 December 1784, the Maryland General Assembly passed a resolution stating that Lafayette and his male heirs "forever shall be...natural born Citizens" of the state. This made him a natural-born citizen of the United States under the Articles of Confederation and
First Amendment to the United States Constitution claiming entitlement to military awards that a person did not in fact earn. In "United States v. Alvarez" (2012), the Supreme Court struck down the Act, ruling that the First Amendment bars the government from punishing people for making false claims regarding military service or honors where the false claim was not "made to effect a fraud or secure moneys or other valuable considerations." The decision was a 6–3 ruling, but the six justices in the majority could not agree on a single rationale for it. The Supreme Court has determined that the First Amendment also protects citizens from being