The Department of Justice has issued new internal guidance advising its attorneys to pursue denaturalization revoking U.S. citizenship for individuals who were naturalized but may have committed certain offenses or provided incomplete information during the process.
The memo, dated June 11 and directed to the Civil Division, outlines several grounds under which attorneys are encouraged to initiate denaturalization proceedings. These include cases involving national security concerns, links to terrorism, or prior felony convictions that were not disclosed during the naturalization process. It also includes cases where individuals are facing unresolved criminal charges, even in the absence of a conviction.
Attorneys are advised to focus on cases involving those who “pose a potential danger to national security,” those who “committed felonies that were not disclosed,” or anyone who made “material misrepresentations” during their application for citizenship.
The guidance makes clear that its scope is broad, stating that attorneys are not limited to the outlined categories and can pursue “any other cases referred to the Civil Division” that are deemed sufficiently important.
Legal experts and civil rights advocates have raised concerns over the wide latitude the memo appears to grant. Joyce Vance, a former U.S. attorney and current law professor, questioned the potential implications in a blog post, warning that the vague language could open the door to broader interpretations. She pointed out that even actions unrelated to the naturalization process could be viewed as grounds for denaturalization under this framework.
Vance expressed concern that the guidance, in the hands of a government willing to act first and address legal concerns later, could place a wide range of individuals at risk including naturalized journalists, academics, doctors, or legal professionals based on subjective assessments of their past actions or beliefs.
The memo signals a more aggressive stance on citizenship enforcement, drawing renewed scrutiny over how naturalized citizens may be treated under evolving federal policy.
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