Are there modern cases where the US government stripped citizenship for fraud or treason?
Executive summary
Yes — in modern times the U.S. government has stripped citizenship from naturalized Americans, but those cases have been relatively rare and legally constrained: many successful denaturalizations involved wartime perpetrators and documented fraud, while courts and constitutional law place high burdens on broader denaturalization efforts [1] [2] [3].
1. What “modern” denaturalization looks like: who has actually been stripped of citizenship
In the post-World War II and contemporary era, denaturalization has most visibly targeted people accused of war crimes or persecution, with the Justice Department’s Office of Special Investigations and related efforts accounting for scores of revocations and deportations — the DOJ reported more than 300 Nazi persecutors blocked, deported or stripped of citizenship since the OSI’s creation, and other war criminals from conflicts like the Yugoslav Wars have also been denaturalized [1] [4]. More broadly, between 1990 and 2017 the government filed about 305 denaturalization cases — roughly 11 per year — illustrating that while the tool exists it has been used sparingly until periods of enforcement focus increased [2] [5].
2. The legal standard: fraud and narrow statutory grounds, plus high judicial guardrails
Federal law allows denaturalization only by judicial order, typically for fraud in the naturalization process or other narrow statutory bases, and can proceed as civil revocation or criminal prosecution under statutes like 18 U.S.C. §1425; the government bears a heavy burden — clear and convincing evidence in civil cases or beyond a reasonable doubt in criminal cases — and courts have injected materiality and willfulness requirements that substantially limit broad application [2] [3] [6]. The Supreme Court’s post‑McCarthy decisions and subsequent jurisprudence require proof that misrepresentations were material to eligibility and, in politically charged contexts, that any disqualifying beliefs or associations were willfully adopted, creating significant constraints on denaturalization campaigns [3].
3. Recent enforcement shifts and political agendas — more cases sought, but obstacles remain
The Justice Department and executive agencies have periodically reorganized to prioritize denaturalization — earlier Trump administration initiatives and the creation of denaturalization offices are precedents — and internal guidance reported in December 2025 instructed USCIS field offices to refer dramatically more cases, even setting a target of “100–200 denaturalization cases per month” for fiscal 2026, signaling a political appetite to expand use of the tool [7] [8]. Civil‑liberties groups, immigration attorneys, and academic critics warn that quotas and broad directives risk politicizing denaturalization, sweeping up minor errors or politically unpopular individuals, while DOJ and enforcement advocates frame the push as closing a “fraud” loophole and pursuing dangerous individuals [9] [8] [4].
4. Practical reality: rare successes, resource‑intensive litigation, and limits on scope
Even with renewed emphasis, denaturalization remains difficult and resource‑intensive; commentators and practitioners note that success typically requires clear links between misrepresentation and eligibility (Maslenjak jurisprudence is commonly cited), and that many referrals do not translate into revoked status because courts apply demanding evidentiary and constitutional safeguards [10] [3] [6]. Historical averages, DOJ reporting and scholarly work all indicate that the absolute number of people actually stripped of citizenship in recent decades is small relative to the population of naturalized citizens, despite spikes when enforcement offices prioritize such cases [2] [1] [4].
5. Bottom line — direct answer to the question
Modern cases do exist: the U.S. has stripped some naturalized citizens of citizenship for fraud, material misrepresentation, or involvement in war crimes, and those prosecutions continue today in focused pockets; however, denaturalization is legally constrained, procedurally demanding, and — until recently — pursued at low annual rates, even as recent policy memos and goals suggest an administration‑level push to increase referrals and litigation [1] [2] [7] [3].