The civil litigation machine
The Trump administration has elevated denaturalization to a top-five Department of Justice enforcement priority and identified 384 foreign-born U.S. citizens whose citizenship it wants to revoke, more than three times the 120 denaturalizations completed between 2017 and late 2025 [2][5]. The cases will be processed through 39 regional civil litigation offices rather than criminal courts, a procedural choice that lowers the burden of proof, eliminates the right to government-furnished attorneys, and allows faster resolution [2][5].
Assistant Attorney General Brett A. Shumate wrote in a June 11 memo that denaturalization will be among the DOJ's top five enforcement priorities for the civil division [2]. That same memo gave U.S. attorneys wider discretion on when to pursue denaturalization tactics and listed broad categories of people to be stripped of citizenship status, including those with a "nexus to terrorism" or gang and cartel members [2][5]. Civil litigators in the 39 regional offices would be assigned to file denaturalization cases [5].
The infrastructure supporting this expansion extends beyond the litigation offices. The reconciliation law signed by President Trump in July provided $170 billion for immigration enforcement activities, including $45 billion to DHS for expansion of immigration detention centers. A top Justice Department official, Francey Hakes, said the 384 people represent "the first wave of cases" the administration intends to pursue [5].
How civil proceedings change the equation
Under the Immigration and Nationality Act, a naturalized U.S. citizen's citizenship may be revoked if naturalization was illegally procured or procured by concealment of material facts or willful misrepresentation [1]. But the government has two paths to enforce this: criminal prosecution or civil denaturalization proceedings. The administration chose civil [2].
In civil denaturalization proceedings, individuals are not entitled to a government-furnished attorney [2]. Civil proceedings have a lower burden of proof for the government and are faster to conclude than criminal proceedings [2]. The government must prove that a person is not of "good moral character" before a judge to justify denaturalization [5], a standard that gives prosecutors significant interpretive latitude when paired with the memo's vague categories.
The Department of Justice filed denaturalization actions against 12 individuals in the initial announcement, accused of providing material support to terrorist groups, committing war crimes, and sexually abusing minors [1]. Acting Attorney General Todd Blanche stated that individuals implicated in fraud, heinous crimes, or expressing support for terrorism should never have been naturalized [1]. But the cases themselves reveal how the civil process operates across a spectrum of conduct.
Ali Yousif Ahmed Al-Nouri from Iraq entered the United States in 2009 claiming he and his family were attacked by Al-Qaeda terrorists, and illegally procured his naturalization in 2015 by lying under oath about his criminal and family history [1]. In 2019, the Republic of Iraq requested his extradition to face charges for the premeditated murder of two Iraqi police officers in 2006 [1]. Oscar Alberto Pelaez from Colombia pleaded guilty to and was convicted of thirteen counts of sexual assault against a child in 2002, then lied about his crimes in connection with his naturalization application [1]. Khalid Ouazzani from Morocco naturalized in 2006, and by 2007 sent Al-Qaeda tens of thousands of dollars in fraudulently obtained financial support [1].
Elliott Duke, a U.K.-born American military veteran, was denaturalized on June 13 after being convicted of distributing child sexual abuse material, which he admitted to distributing prior to becoming a U.S. citizen [2]. The case demonstrates that military service does not insulate naturalized citizens from denaturalization proceedings when the government determines they lacked "good moral character" at the time of naturalization.
The historical pattern
Denaturalization was heavily used during the McCarthy era of the late 1940s and early 1950s [2]. Throughout the 20th century, journalists, activists, and labor leaders were often targeted for denaturalization, accused of being anarchists and communists [5]. The Supreme Court ruled in the late 1960s that denaturalization could only occur if someone committed fraud or "willful misrepresentation" [5].
After that ruling, denaturalization focused mostly on former war criminals, including Nazis, who lied in their records to gain U.S. citizenship [5]. Denaturalization was expanded during the Obama administration and grew further during President Trump's first term [2]. But the scale remained limited: between 2017 and late 2025, the U.S. stripped just over 120 naturalized citizens of their citizenship [5].
The current expansion represents a different order of magnitude. The 384 identified cases are explicitly described as a "first wave," suggesting the administration intends to build denaturalization capacity that extends well beyond these initial targets [5]. The June 11 memo's broad categories, "nexus to terrorism," gang and cartel members, echo the vague language that enabled McCarthy-era overreach, when political affiliation rather than criminal conduct often determined who faced denaturalization.
Two classes of citizenship
According to 2023 data, close to 25 million immigrants were naturalized citizens in the United States [2]. A White House spokesperson stated the denaturalization push is "federal law" rather than a White House initiative [5]. The law has always existed. What changed is the decision to make denaturalization a top-five DOJ priority, to route cases through civil rather than criminal courts, to activate 39 regional offices for simultaneous processing, and to give U.S. attorneys "wider discretion" on targeting.
The procedural architecture matters because it determines what citizenship means in practice. When citizenship can be litigated away in civil court based on "good moral character" determinations made years or decades after naturalization, with broad targeting categories and no right to government counsel, the 25 million naturalized citizens live under a different legal reality than the native-born. The administration has not created a new law. It has reconfigured the system that enforces an old one, transforming citizenship from a permanent status into a provisional one subject to ongoing review, not through criminal conviction, but through civil litigation with a lower bar and fewer protections.
