On January 13, 2015, the European Court of Human Rights held in Petropavlovskis v. Latvia that Latvia’s refusal to grant an activist citizenship through naturalization did not prevent him from expressing his opinion or participating in meetings and that he had no arguable complaint under the European Convention on Human Rights (the Convention).  The applicant, who had been an activist in regard to education reform in Latvia, argued that he was denied citizenship because of his criticism of the government’s position on education and that this violated Articles 10 (freedom of expression) and 11 (freedom of association) of the Convention.  According to the press release, the Court found that he had been free to disagree with governmental policies in Latvia and “that this was an entirely different matter from the issue of the criteria set for naturalisation and its procedure as determined by domestic law in Latvia.”  The Court determined that “requiring an individual seeking to obtain Latvian citizenship through naturalisation to demonstrate a genuine connection to the State, which includes a certain level of loyalty, could not be considered a punitive measure which interfered with freedom of expression and assembly.”