In a pair of companion cases, the Ninth Circuit held that federal courts have jurisdiction to amend naturalization certificates issued by a federal court before the Immigration Act of 1990 came into effect on October 1, 1991. However, the federal courts lack jurisdiction to amend naturalization certificates issued by an administrative agency.
The decision in Collins v. USCIS can found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2016/05/04/13-55290.pdf
The decision in Teng v. District director can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2016/05/04/14-55558.pdf