Has U.S. case law or State Department policy targeted dual nationals for denaturalization more often?
Executive summary
U.S. denaturalization has historically been rare and legally constrained, used mainly for fraud, war crimes, and national-security cases; DOJ filed about 305 cases from 1990–2017 (roughly 11/year) and courts strictly limit when citizenship can be revoked [1] [2]. Since June 2025, the Department of Justice has issued a memo elevating denaturalization as a Civil Division priority and expanding categories (fraud, national security, violent crime, human‑rights abuses), prompting advocates to warn of a broader enforcement posture [3] [4] [5].
1. The legal baseline: denaturalization is narrow, judicial, and historically limited
For decades U.S. law has allowed denaturalization only in narrowly defined circumstances—procurement of citizenship by fraud or willful misrepresentation, certain affiliations close to the time of naturalization, and extreme crimes such as war crimes—and revocation requires judicial proceedings in federal court [6] [5] [7]. The Supreme Court has repeatedly reinforced strict limits on when citizenship can be stripped, leaving political or post‑naturalization conduct largely outside the denaturalization toolbox [2].
2. Empirical context: denaturalization was uncommon until recent policy shifts
Historically the government pursued relatively few denaturalization suits: one review counted about 305 DOJ filings between 1990 and 2017—roughly 11 cases per year—illustrating that denaturalization was a narrow enforcement instrument rather than a broad deportation tool [1]. Immigration advocates and legal groups note the federal government traditionally concentrated resources on the most extreme cases, like war criminals and serious national‑security threats [5] [8].
3. The 2025 policy turning point: DOJ memo elevates denaturalization as a priority
On June 11, 2025, Assistant Attorney General Brett Shumate circulated a Civil Division memorandum directing denaturalization be “prioritized and maximally pursued,” and it listed expanded priority categories including fraud, violent crime, human‑rights violations, and national‑security threats [3] [9]. Multiple law firms, immigrant‑rights groups, and practitioner pages document that this memo represents a formal broadening of the cases DOJ will consider for denaturalization [3] [4] [9].
4. Who might be targeted: expanded categories, but legal and resource checks remain
DOJ’s newly emphasized categories encompass a wider range of conduct than earlier, narrower practice, which raises the prospect that more naturalized citizens could face investigation for past misstatements or alleged crimes [3] [4]. Yet legal experts and some practitioners stress constitutional safeguards, high evidentiary burdens, and limited federal resources as obstacles to mass denaturalization—even as the policy shift makes more cases legally plausible [3] [2].
5. Political context and competing narratives
The denaturalization push is tied to broader political priorities: reporting connects the effort to the Trump administration’s enforcement agenda, Project 2025 planning documents, and public political statements promising aggressive immigration enforcement and revocations of benefits for “noncitizens” [10] [1] [11]. Advocates frame the memo as a politically motivated expansion that risks chilling immigrant communities and overburdening courts; proponents portray it as necessary to remove those who “illegally procured” citizenship or threaten security [3] [9].
6. Dual nationals: what the sources say — limited direct evidence of targeting
Available sources document an uptick in denaturalization emphasis but do not provide systematic data showing DOJ or State Department policy has targeted dual nationals specifically more often than other naturalized citizens. Reporting and policy summaries emphasize categories of conduct (fraud, national security, crimes) rather than dual‑national status itself, and sources note that the United States “does not officially recognize” dual nationality but also lacks authority to stop other countries from treating someone as a citizen [6] [5]. Therefore, available sources do not mention a clear pattern of targeting people because they hold dual nationality alone [6] [3] [4].
7. Practical implications and likely trajectories
If DOJ follows the 2025 memo aggressively, practitioners expect more investigations and selective suits in the expanded categories; still, courts and evidentiary standards will constrain wholesale revocations [3] [2]. Immigration advocates and law firms recommend that naturalized citizens review their records and seek counsel if they have past discrepancies or serious offenses, reflecting the practical worry that broader priorities translate into more referrals and prosecutions even if mass denaturalization remains unlikely [9] [12].
Limitations: sources provided focus on policy memos, advocacy and legal commentary, and past case counts; they do not supply comprehensive DOJ case‑level data through 2025 disaggregated by dual‑national status, nor do they cite any State Department directive that explicitly singles out dual nationals for denaturalization (available sources do not mention State Department policy targeting dual nationals specifically) [6] [3] [4].