SAN FRANCISCO — A newly issued U.S. Department of Justice (DOJ) memo under the Trump administration directs federal attorneys to prioritize denaturalization proceedings in cases involving fraud, national security threats, or other disqualifying factors—a shift that could have major implications for California, home to the country’s largest population of naturalized citizens.
The June 11, 2025, memo from DOJ Civil Division chief Brett Shumate instructs government lawyers to “prioritize and maximally pursue denaturalization proceedings in all cases permitted by law and supported by the evidence.” This includes civil and criminal cases involving alleged misrepresentation during the naturalization process, terrorism-related offenses, gang affiliation, and war crimes.
California has approximately 5.6 million naturalized citizens, according to the most recent American Community Survey conducted by the U.S. Census Bureau.
Under federal law, denaturalization requires a formal court process—either civil or criminal—and the government must prove that the individual obtained citizenship illegally or through willful misrepresentation of material facts. The standard of proof in civil denaturalization cases is “clear, convincing, and unequivocal evidence.”
In Maslenjak v. United States (2017), the U.S. Supreme Court ruled that a naturalized citizen cannot be stripped of citizenship for minor or immaterial inaccuracies. The court clarified that only lies or omissions that are material—meaning they would have influenced the original citizenship decision—can be grounds for revocation.
The DOJ previously launched denaturalization efforts through initiatives such as “Operation Janus” and “Operation Second Look,” which were originally expanded in 2018. During Trump’s first term, at least 168 civil denaturalization cases were filed, according to public records and DOJ announcements.
In June 2025, the DOJ secured a civil denaturalization judgment against Elliott Duke, a convicted child sex offender who allegedly concealed his criminal history during his naturalization process. That case marked the first confirmed denaturalization under the new policy directive issued this year.
Legal scholars and immigration attorneys have confirmed that denaturalization, while legally permissible, remains rare due to constitutional protections and the high burden of proof required.
