The U.S. Department of Justice (DOJ) has taken a bold and controversial step to aggressively expand denaturalization efforts, aiming to revoke the citizenship of naturalized Americans under a sweeping new directive issued on June 11, 2025. This internal memo, signed by Assistant Attorney General Brett A. Shumate, instructs DOJ attorneys to "maximally pursue denaturalization proceedings in all cases permitted by law and supported by the evidence," signaling a dramatic shift in immigration enforcement policy under President Donald Trump’s administration.
Denaturalization, the legal process of stripping U.S. citizenship from naturalized individuals, has historically been a rare and narrowly applied tool. Traditionally reserved for cases involving fraud during naturalization or egregious crimes such as Nazi war crimes or serious human rights violations, the DOJ’s new guidance broadens the scope significantly. It targets a wide range of cases, including individuals accused of terrorism, gang activity, financial and medical fraud, sex offenses, and even those with pending criminal charges. The memo also empowers attorneys to pursue "any other case" deemed "sufficiently important," granting broad discretion to expand efforts beyond the enumerated categories.
At the heart of this initiative is the roughly 25 million U.S. citizens who were born abroad and later naturalized, representing a substantial portion of the American population. According to the Migration Policy Institute, over 40% of these naturalized citizens obtained citizenship within the last 15 years, underscoring the vast potential reach of this policy.
Unlike criminal proceedings, denaturalization cases are civil in nature. This distinction carries significant legal implications: defendants in these cases are not entitled to government-appointed attorneys, the government faces a lower burden of proof, and the process can move more swiftly than criminal trials. Such procedural differences have sparked serious concerns among legal experts and immigrant advocates who warn that these civil proceedings could erode due process protections guaranteed by the 14th Amendment.
"To see that this administration is plotting out how they're going to expand its use in ways that we have not seen before is very shocking and very concerning," said Sameera Hafiz, policy director of the Immigration Legal Resource Center. She described the policy as an attempt to create "a second class of U.S. citizens," where naturalized Americans face heightened vulnerability to losing their citizenship rights.
The memo’s timing and scope recall historical precedents. During the McCarthy era of the late 1940s and early 1950s, denaturalization was used aggressively, with around 20,000 cases filed annually, often targeting individuals accused of communist ties. However, a 1967 Supreme Court ruling curtailed these efforts, deeming denaturalization inconsistent with American democratic values due to its creation of unequal citizenship classes. After that, denaturalization cases dwindled to just a handful per year until the Obama administration revived interest with initiatives like Operation Janus, targeting immigration fraud linked to national security concerns.
Under Trump’s first administration, denaturalization efforts expanded further, and the current directive signals an intent to "turbocharge" these efforts in 2025, as promised by Trump aide Stephen Miller in 2023. The memo also aligns with other aggressive immigration policies, including lawsuits against sanctuary cities, investigations into gender-affirming care as alleged healthcare fraud, and challenges to diversity, equity, and inclusion (DEI) initiatives within federal contractors.
One of the first high-profile cases under the new policy involved Elliott Duke, a U.S. military veteran originally from the United Kingdom. On June 13, 2025, a federal judge in Louisiana revoked Duke’s citizenship after he was convicted in 2014 for distributing child sexual abuse material—a crime he failed to disclose during his naturalization process. Duke, who uses they/them pronouns, became effectively stateless following the revocation. Despite seeking legal representation, Duke was unable to secure an attorney or attend court proceedings, highlighting the procedural challenges faced by individuals in denaturalization cases.
Legal scholars have expressed concern about the broad and vague criteria outlined in the memo. Steve Lubet, professor emeritus at Northwestern University Pritzker School of Law, noted that the categories are so wide-ranging that they grant the government "wide discretion" to pursue cases that may not necessarily involve fraud during naturalization but rather post-naturalization conduct. This raises troubling questions about the stability of citizenship for naturalized Americans and the potential ripple effects on their families, including children who derive citizenship through their parents.
Hans von Spakovsky, a senior legal fellow at the conservative Heritage Foundation, defended the DOJ’s approach, framing naturalization as a "great privilege" that should be revoked if abused. He emphasized that individuals are free to hire their own lawyers in civil cases and argued that the government is not obligated to provide counsel, maintaining that this does not violate due process.
However, critics argue that the civil nature of denaturalization proceedings strips away fundamental protections. Cassandra Robertson, a law professor at Case Western Reserve University, asserted that revoking citizenship through civil litigation violates due process and infringes on constitutional rights. The lower burden of proof and absence of guaranteed legal representation create a perilous environment for naturalized citizens, especially given the broad discretion afforded to prosecutors.
The policy has also become a political weapon in partisan disputes. For instance, Representative Andy Ogles, a Republican from Tennessee, called on Attorney General Pam Bondi to revoke the citizenship of Zohran Mamdani, a Democratic nominee for New York City mayor, citing rap lyrics from 2017 that allegedly praised supporters of Hamas, a group designated as terrorist by the U.S. Mamdani, born in Uganda and naturalized in 2018, has not been formally charged or denaturalized, but the incident underscores how denaturalization threats are increasingly wielded against political opponents.
Beyond citizenship revocation, the DOJ memo is part of a wider agenda to reshape immigration enforcement and civil rights priorities. The Civil Rights Division, traditionally focused on combating discrimination, has seen significant upheaval, with about 70% of its attorneys reportedly leaving between January and May 2025. The division now faces new mandates to challenge DEI programs, gender-affirming care, and sanctuary jurisdictions.
Additionally, the Department of Justice has recently sued 15 district attorneys in Maryland over policies that limit the immediate deportation of migrants, reflecting a broader federal push to assert supremacy over state and local immigration policies.
As denaturalization efforts escalate, the implications for millions of naturalized citizens are profound. The prospect of losing citizenship based on civil proceedings with limited protections threatens to unsettle the lives of countless families and raises fundamental questions about the nature of American citizenship in the 21st century.
Whether this aggressive approach will withstand legal challenges or provoke legislative pushback remains to be seen. What is clear is that the Trump administration’s DOJ is determined to use denaturalization as a key tool in its immigration enforcement arsenal, marking a significant and contentious chapter in the nation’s ongoing debate over citizenship, identity, and the rule of law.
