The Trump administration has embarked on a robust campaign to strip a record number of immigrants of their U.S. citizenship, shifting resources within the government to achieve the quotas it has imposed on federal prosecutors. While the process of denaturalization is as old as naturalization itself, albeit historically rarely invoked, the administration is seeking to use its authority in greater and different ways. Once reserved largely for Nazis, communists, and security threats, denaturalization now could be used by the Trump administration for a broad set of criminal acts and cases deemed “sufficiently important to pursue,” which some fear could mean naturalized citizens accused of engaging in disfavored speech or political activity.

The administration’s ability to meet its ambitions is uncertain, given the legal protections related to citizenship that have evolved over the years. When Congress brought naturalization under exclusive federal authority in 1906, it saw denaturalization as a measure of last resort. Although hundreds of immigrants were stripped of their U.S. citizenship annually on average in subsequent decades—many of them perceived enemies of the state, anarchists, or nationals of wartime adversaries—the Supreme Court sharply curtailed use of denaturalization after 1967. Between 1990 and 2017, an average of 11 denaturalization cases were filed per year.

The Trump administration tried to buck the trend during its first term, setting a lofty goal of 1,600 denaturalization referrals for the long-running Operation Janus, which was investigating fingerprint records that had not been digitized. But its results fell far short; the average of about 25 civil cases filed per year was a significant increase from the past, though far below rates of the pre-1967 era and well below the goal. (Given that denaturalization is a lengthy and deliberative process, it is unclear how many of these cases ended in individuals being stripped of U.S. citizenship). So far during the second Trump term, the administration had reportedly identified 384 potential denaturalization cases as of April 2026. As of this writing, it had filed charges against at least 39 individuals in 2026.

Whether the latest campaign leads to denaturalization numbers on par with those of a century ago or not, it will likely have the effect of stoking fear among immigrants—even those who had assumed that becoming a U.S. citizen was the final and irreversible act of integration into U.S. society. The administration’s rhetoric and actions have injected doubt in that long-held assumption for some, potentially permanently altering perceptions about the value of acquiring U.S. citizenship.

This article provides an overview of the process for removing U.S. citizenship from immigrants, historical trends, and how the Trump administration has sought to increase denaturalizations and the legal barriers it faces.

How U.S. Citizenship Can Be Lost

The process of denaturalization has evolved considerably over time. Congress sets the conditions under which immigrants can gain U.S. citizenship, which has specific and strict guidelines. Effectively, someone can be denaturalized only if authorities prove they fraudulently or illegally procured citizenship, with a heavy burden of proof on the government.

Generally, there are three ways a person can be denaturalized. One is if they obtained citizenship without meeting the qualifications for naturalization, which include a duration of physical presence in the United States, evidence of attachment to the Constitution, and “good moral character.” Specific actions could negate a finding of good moral character, such as participating in persecution of others, but there is also significant room for discretion. In August 2025, the Trump administration issued a policy memo substantially raising the bar for a positive finding of good moral character, placing greater emphasis on factors including compliance with tax obligations, educational attainment, and community involvement. Adverse actions either before or after naturalization can be cause for losing citizenship.

The second way someone can be denaturalized is if they concealed a fact or made a willful misrepresentation that would have affected their grant of naturalization. This can include, for example, concealing their affiliation with a totalitarian government or a terrorist organization.

The third path to denaturalization is if someone gained citizenship through service in the U.S. armed forces but was discharged in “other than honorable conditions” before a total of five years of service.

Denaturalizations can be either criminal or civil, but a federal judge is the ultimate arbiter in both. To carry out a denaturalization, U.S. Citizenship and Immigration Services (USCIS) first recommends to the Justice Department that an individual’s status be revoked either on criminal or civil grounds; prosecutors then formally file that complaint in federal court. Denaturalization cases often take many years and may extend across presidential administrations.

Criminal cases carry a ten-year statute of limitations, and the burden of proof is quite high: beyond a reasonable doubt. Those in criminal denaturalization proceedings have the right to counsel, the right to a jury trial, and could face additional penalties along with the loss of citizenship, such as prison or fines.

Historically, most denaturalization cases have been civil proceedings which have no statute of limitations and a lower burden of proof for the government: “clear, convincing, and unequivocal evidence which does not leave the issue in doubt.” In civil proceedings, defendants do not have the right to government-appointed counsel, though they can procure one at their own expense. Civil denaturalizations do not carry additional penalties beyond the loss of citizenship. Because civil denaturalizations are more common, most available data focus only on those cases.

After denaturalization, a person reverts back to the U.S. immigration status they held prior to naturalization and could be subject to deportation.

The Current Push for Denaturalization

The January 2025 executive order, “Protecting the United States from Foreign Terrorists and Other National Security and Public Safety Threats,” set the stage for a June 2025 Justice Department memo prioritizing denaturalizations, among other issues. The memo outlined ten categories of civil denaturalization cases for department focus, including individuals who committed fraud or misrepresentation and who pose national security threats for reasons including an affiliation with drug cartels. Some legal scholars have argued that the memo’s targeting guidelines are outside the scope of the law, grant the executive branch broad discretionary powers, and could violate First Amendment rights.

While denaturalization prosecutions historically have focused on war criminals and national security threats, the Trump administration is casting a wider net. For example, in September 2025 authorities brought denaturalization charges against Fernando Adrian Moio Bartolini, a native of Argentina who gained U.S. citizenship after allegedly procuring fake Cuban documents to get a green card under the Cuban Adjustment Act, eventually gaining citizenship. In December 2025, prosecutors filed charges against Nicholas Eshun, a native of Ghana who served in the U.S. military but was court martialed and dishonorably discharged after less than five years of service. And in March 2026, denaturalization charges were filed against Emmanuel Oluwatosin Kazeem, a Nigerian native convicted of fraud whose sentence was commuted by President Joe Biden in 2024.

USCIS has been instructed to meet a quota of 100 to 200 case referrals each month, with staff reassigned to identify cases for denaturalization. Justice Department attorneys have also been instructed to focus on denaturalization cases. To increase capacity, line prosecutors have also been pulled into working on denaturalization cases that previously were handled by the Justice Department’s Office of Immigration Litigation. This has led to concerns about the workload of understaffed U.S. attorney’s offices already confronted with an overwhelming habeas caseload due to the administration’s mandatory detention policy for noncitizens arrested and placed into removal proceedings. The administration reportedly plans to file 250 denaturalization cases by October.

Separately, in early June, denaturalization was the topic of a Senate hearing where Republican senators promoted two bills: the Stop Citizenship Abuse and Misrepresentation (SCAM) Act, and the Fraud Accountability Act. The SCAM Act would include a naturalized citizen’s affiliation with a terrorist organization or commission of fraud or an aggravated felony within ten years of naturalization as retroactive evidence that the good moral character standard was not met at the time of naturalization. The Fraud Accountability Act would allow a judge in any criminal fraud trial to add denaturalization as an automatic punishment, negating the need for a separate denaturalization trial.

These bills were introduced after a fraud scheme was uncovered in Minnesota implicating some Somali immigrants; the Trump administration has cited this case to demand more aggressive denaturalization. As of this writing, both bills likely faced steep barriers to enactment. They do convey, though, that the push for expanding denaturalization has appeal beyond the Trump administration. Notably, the GOP bills differ from previous legislation on denaturalization; in the last 20 years, the few congressional proposals aimed at denaturalization have predominately focused on people with ties to terrorist organizations, such as the Terrorist Expatriation Act of 2010 and the Terrorist Denaturalization and Passport Revocation Act of 2014 and 2015.

Early Denaturalization as an Ideological Weapon

In some ways, the Trump administration seeks a return to an earlier era, when the practice of denaturalization, specifically for ideological differences, was much more common.

At first, citizenship was not a matter for the federal government. In the Naturalization Act of 1790, Congress gave authority to “any common law court of record” to grant citizenship, and nearly all early naturalizations happened in state, county, and municipal courts. Amid a lack of standardization and concerns about fraud, Congress in 1906, during the Theodore Roosevelt administration, passed the Basic Naturalization Act. This law brought all naturalizations under exclusive federal jurisdiction and created a denaturalization process on grounds of fraud, racial ineligibility (Asian immigrants were largely prohibited from obtaining U.S. citizenship at the time), and a lack of good moral character, establishing the rule that citizenship required more than simple residency. In 1909, the Justice Department set priorities for denaturalization, requiring it be used only if “some substantial results are to be achieved thereby in the way of betterment of the citizenship of the country.”

Despite that guidance arguing for rare usage, in the early 20th century denaturalization was often wielded against immigrants whose actions were considered inimical to the U.S. political environment. As such, it became a relatively common tool: Between 1907 and 1967, there were more than 22,000 denaturalizations, an average of about 367 per year.

Initially, the Roosevelt administration targeted anarchists, amid broader government hostility following the 1901 assassination of President William McKinley by anarchist Leon Czolgosz. In 1903, Congress made anarchists ineligible for immigration, deportable, and eligible for denaturalization. One of the highest profile targets of this era was activist Emma Goldman, who lost her citizenship when her former husband was denaturalized, causing her eventual deportation.

Later, during the two world wars, many German, Italian, and Japanese immigrants were stripped of their citizenship, as were those believed to be affiliated with the Nazi Party during and after World War II. This tendency continued during the Cold War, when alleged communists such Harry Bridges, an Australian-born union leader who led prominent worker strikes, were targeted. Ultimately, however, Bridges’s denaturalization was blocked twice by the Supreme Court.

The Supreme Court Shaped Modern Denaturalization

The period of significant denaturalization was largely ended by the U.S. Supreme Court, which since the issue’s earliest days had deemed the issue a matter for the federal government and became more proscriptive over time. In 1912, in Johannessen v. United States, the court upheld a retroactive application of the 1906 law, ruling the government could revoke fraudulently gained citizenship, for reasons including not meeting the requirements. The Luria v. United States ruling in 1913 found that the citizenship of George Luria could be revoked because he moved to South Africa immediately after becoming a U.S. citizen, which the government cited as evidence that he never intended to reside permanently.

After citizenship stripping became more common, several cases between 1940 and 1960 reined in and narrowed its use, curtailing the government’s ability to carry out denaturalization based on certain political beliefs. For example, in 1943, in Schneiderman v. United States, the government sought to denaturalize a Russian immigrant for his affiliation with the Communist Party; the court rejected the idea that political beliefs alone could be the basis for denaturalization and enshrined the high evidentiary standard for civil denaturalization, establishing that the onus was on the government to provide “clear, unequivocal, and convincing” evidence. The 1946 decision in Knauer v. United States reaffirmed that naturalization is not a “second-class citizenship,” and as such naturalized individuals have the right of free speech, including to criticize the government.

The 1967 decision in Afroyim v. Rusk remains seminal. The case involved Beys Afroyim, a Polish immigrant who faced denaturalization for voting in an Israeli election, which the U.S. government argued was contrary to the Naturalization Act of 1906. In its decision, the Supreme Court ruled that the 14th Amendment prevents Congress from stripping citizenship except for instances of fraud. The Afroyim decision marked a turning point to a much more limited use of denaturalization. Following a period of hundreds of denaturalizations per year, fewer than 150 people in total were denaturalized between 1967 and 2017, a roughly 99 percent annual decline from the pre-1967 era.

The Supreme Court also played a significant role in laying out the process for denaturalization. In Fedorenko v. United States, for example, the high court ruled in 1981 that concealed facts can be considered grounds for denaturalization only if they touch on a statutory bar to the naturalization in the first place, and also placed limits on the use of coercion as a defense for not disclosing certain information. The case involved Feodor Fedorenko, a Soviet immigrant who obtained a U.S. visa under the Displaced Persons Act without disclosing that he had been an armed guard at a Nazi camp. This case set the standard for subsequent denaturalization cases involving Nazis: Not disclosing this pertinent information will automatically lead to a ruling that the citizenship was illegally procured.

The court’s 1988 ruling in Kungys v. United States established a four-part test for civil denaturalization cases to prove if citizenship was gained unlawfully:

1. Did the naturalized citizen misrepresent or conceal a fact?
2. If so, was the misrepresentation or concealment willful?
3. Was the misrepresented or concealed fact material to the outcome of the case?
4. Had the person been naturalized as a result of the willfully misrepresented or concealed fact?

The most recent Supreme Court decision on denaturalization was in 2017, in Maslenjak v. United States. In that case, the court ruled unanimously that misrepresentation or omission cannot be the sole grounds for denaturalization, and that, if known, it would have contributed to denial of their citizenship application.

Post-9/11 Evolution: Digitization and Denaturalization

In the aftermath of the September 11, 2001 terrorist attacks, the George W. Bush administration ramped up civil denaturalization cases, though they still remained well below the pre-1967 rate. The average of 7.8 cases filed annually under the Clinton administration increased to 18.9 under Bush and then declined slightly to 15.8 under the Obama administration. While many cases continued to involve suspected war criminals, some focused on alleged ties to terrorism. The Obama administration also focused on naturalized citizens who could present a national security threat, including those with security clearances.

The Bush administration also set into motion a review that continues to resonate today. After 9/11, the government reorganized and expanded its data-collection and data-sharing capabilities, including increasing the digitization of fingerprints that had previously been collected on paper. In 2008, U.S. Customs and Border Protection (CBP) discovered that some individuals with final deportation orders had obtained permanent residency or citizenship, leading to the launch of Operation Targeting Groups of Inadmissible Subjects, which the Obama administration subsequently renamed Operation Janus. In total, Operation Janus found that the fingerprint records of 315,000 immigrants had not been digitized. Of those, 858 individuals who had been ordered removed had gained U.S. citizenship using a different identity and did not have digitized fingerprints.

During first Trump term, Operation Janus was renamed Operation Second Look, and the administration vastly expanded the scope from a narrow group of individuals to a review of all 315,000 fingerprint records that had not been digitized as well as more than 700,000 naturalization cases. This led to the denaturalization of Baljinder Singh, the first case stemming from Operation Janus. Singh, an Indian immigrant, was denaturalized and targeted for deportation in 2018 because as a teenager he was ordered removed in absentia when his deportation order arrived at an address where he no longer lived.

That same year, USCIS diverted resources to focus on denaturalization, intending to refer 1,600 cases to the Justice Department. In 2020, the department’s Civil Division created a Denaturalization Section, a first-of-its-kind office. The significant investment of resources concerned critics, given that most immigrants targeted for denaturalization were from specific countries (including Mexico, Haiti, and Nigeria) and that the administration diverted to its denaturalization work money that had been collected by USCIS for other purposes. The ambition was largely unsuccessful: On average 25 denaturalization cases per year were filed during the first Trump term, an increase over previous administrations but far short of its goals.

The pace of denaturalization decreased during the Biden administration, to an average of four cases filed per year. The administration sought to institute guardrails. For example, a 2021 executive order included a directive to review denaturalization policies and ensure they are not used “excessively or inappropriately.” And a 2022 Justice Department policy memo limited its use to threats to national security, war criminals, or people who did not disclose egregious crimes. However, much to the chagrin of advocacy organizations, the Biden administration kept in place the pre-existing infrastructure to carry out denaturalizations, allowing the Trump administration to pick up where it left off.

Stoking Fear

The use of denaturalization has evolved over the years in inconsistent ways. Initially conceived as a tool of last resort, ideological animosity and perceived national security threats proved to be critical motivators for stripping citizenship during the world wars and into the Cold War. After a decline in use following the civil rights era, denaturalization regained popularity after 9/11, although to a lesser degree. With better tools for collecting and analyzing data, authorities’ emphasis shifted to denaturalizing immigrants who had gamed the system and fraudulently procured citizenship.

The Trump administration’s second-term approach on denaturalization aligns with much of the rest of its immigration policy agenda: more enforcement, less legal immigration, and harder-to-access citizenship. Because denaturalization cases often take years to complete, however, critics argue the more immediate goal may be to instill uncertainty and anxiety among immigrants. Creating a climate of hostility is much more achievable than large-scale denaturalizations, as history has shown.

The authors thank Andres Ayala for his research assistance.

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