A Philippines native who was accepted as a U.S. citizen 16 years ago but who 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 that Jaime Escaler had failed to exhaust his administrative remedies before turning to the courts, the U.S. Court of Appeals for the Second Circuit ruled it was without jurisdiction to review Mr. Escaler’s claim that immigration officials were wrong to deny him citizenship because he failed to take the oath as required by law.