Jahed v. Acri, 468 F.3d 230 (4th Cir. Nov. 13, 2006) (affirming removal order against claim of derivative citizenship after parents' divorce and father's naturalization, for failure to demonstrate that parents were legally separated for purposes of U.S. immigration law).
http://caselaw.lp.findlaw.com/data2/circs/4th/056489p.pdf