Primer: Denaturalization
Carlos Noe Gallegos was a U.S. citizen. But before he became one in 2010, he had sexually assaulted a child and concealed his crime during the naturalization process. Several years later, he was convicted and pleaded guilty. On January 22, 2026, the Southern District of Texas, acting with the support of the Attorney General Pam Bondi, issued an order revoking his citizenship.1
Jorge Antonio Graciano Lara was also a U.S. citizen. But in the years before his naturalization, he had repeatedly raped a minor, and concealed his crime during his naturalization process while forcing his victim to remain silent. In 2017, he was convicted, and in November 2024, the Justice Department sued to denaturalize him.2
Elliot Duke became a U.S. citizen on January 18, 2013. Five months later, he was arrested for distributing child pornography both before and after naturalization. On February 19, 2025, the Justice Department filed for denaturalization, and after a judicial process, Duke’s citizenship was revoked last June.3
These cases reveal a growing problem. Many naturalized Americans are guilty of committing serious crimes and concealing the material facts about them during the naturalization process. Had immigration officials known about their conduct, they would not have been accepted as American citizens.
Fortunately, denaturalization is a legal, constitutional process that can handle precisely these kinds of cases. But the lengthy time period between conviction and denaturalization is concerning. In Duke’s case, for example, over a decade passed between his conviction and denaturalization. This gap shows that denaturalization laws have not been consistently enforced. The Department of Justice has a lot of catching up to do, and this backlog should be a matter of bipartisan concern. Indeed, it already is: It was the Biden administration that initiated the suit against Graciano Lara.
It is therefore proper that the Department of Justice is making denaturalization a priority.4 Denaturalization should be enforced widely to counteract fraud and abuse in the visa and citizenship process and to identify those who never intended to naturalize or whose record demonstrates that they lacked the statutorily required good character to become U.S. citizens. The legality and constitutionality of expatriation is also clear: It should be enforced against those whose actions indicate that they have voluntarily renounced their citizenship. The tools that are on the books and have been used already need to be deployed more frequently and consistently in the coming years.
However, the statutory tools of denaturalization and expatriation are not enough. Other Western governments, particularly the United Kingdom, have seen cases of naturalized and even native-born citizens making a mockery of national citizenship, abusing the process, and using their status to attack or incite violence against their country. The United States must learn from these examples, clarifying and strengthening its denaturalization and expatriation laws in order to respond to these threats.
The Legal Scope for Denaturalization and Expatriation
According to the Constitution, Congress has the power to “establish a uniform rule of naturalization.” The statutory requirement is that an applicant for naturalization must show himself or herself to be a person of good moral character who is attached to the principles of the U.S. Constitution and well disposed to the good order and happiness of the United States.5 These stipulations are far-reaching. To establish that the applicant is of good moral character, one does not draw just from the period of the application. The attorney general “may take into consideration as a basis for such determination the applicant’s conduct and acts at any time prior to that period.”6 To establish that one is “attached” to the Constitution requires a conviction that one supports the Constitution: As the policy manual for United States Citizenship and Immigration Services (USCIS) states, “An applicant who is hostile to the basic form of government of the United States, or who does not believe in the principles of the Constitution, is not eligible for naturalization.”7
Denaturalization is the corollary of Congress’s power to establish the rule of naturalization.8 Yet even though it has rarely been invoked, precedent shows that there is considerable lawful and constitutional scope for denaturalization. The Naturalization Act of 1906 was the first to formalize denaturalization for cases in which an applicant did not conform to the statutory requirements. As the Supreme Court later ruled,
No alien has the slightest right to naturalization unless all statutory requirements are complied with; and every certificate of citizenship must be treated as granted upon condition that the government may challenge it . . . and demand its cancellation unless issued in accordance with such requirements. If procured when prescribed qualifications have no existence in fact, it is illegally procured.”9
The court also made it clear that the presentation of false evidence, including omission of evidence, is grounds for denaturalization. “An alien has no moral nor constitutional right to retain the privileges of citizenship,” the judges wrote, “if, by false evidence or the like, an imposition has been practised upon the court, without which the certificate could not and would not have been issued.”10
The statute governing expatriation is much narrower. It is based on identifying actions that are considered to show an intention to relinquish U.S. citizenship. These actions include committing treason, taking an oath of allegiance to a foreign state, working for a foreign state, or entering the armed forces of a foreign state hostile to the United States.11
Naturalized Citizens’ Accountability for Their Actions After Becoming Citizens
Establishing that fraud or illegal procurement has taken place constitutes legitimate grounds to denaturalize a citizen. These provisions should be rigorously enforced. But the Naturalization Act of 1906 set an important precedent: It held naturalized citizens accountable for their actions after they became citizens. If, within five years of receiving citizenship, the naturalized U.S. citizen returned to his or her native country or established a permanent residence in another foreign country, that was considered prima facie evidence that the naturalized citizen never intended to become a permanent citizen of the United States. The particular residency terms were challenged by the Warren Court, but the principle underwriting the act still stands.12 The McCarran Act of 1950 likewise held naturalized citizens accountable for the organizations they joined in the first five years of citizenship, including criminal and political organizations.13
Holding naturalized citizens accountable for actions after they become citizens does not mean that there are two tiers of citizenship. If there were different rights between naturalized citizens and non-naturalized citizens, that discrepancy would violate the Constitution’s Equal Protection Clause. As the Supreme Court specified, this rule “does not in anywise affect or disturb rights acquired through lawful naturalization, but only provides for the orderly cancellation.”14 What is at issue is similar to the situation in contract law or in marriage. The actions of a signatory at a later point can serve to demonstrate that he or she did not grasp the meaning of the contract, did not understand its terms, or failed to meet one of the underlying conditions for signing the contract. The contract is therefore null.
What Naturalized Citizens Believe Matters
The USCIS manual’s insistence on rejecting an applicant who is “hostile to the basic form of government of the United States” or one who “does not believe in the principles of the Constitution” also dispels a common myth about denaturalization: namely, that ideological scrutiny of an applicant is inadmissible on free speech grounds. This myth arose in part because in Schneiderman v. United States (1943), the court ruled that William Schneiderman’s failure to disclose his membership in the Communist Party did not permit the government to denaturalize him. This ruling gave the impression that one’s political beliefs or affiliations were not grounds for denaturalization.
But the court’s ruling was narrower than that. At the time, there was no statutory evaluation of what membership in the Communist Party entailed. Because multiple interpretations of the Communist Party platform existed, the judges concluded that membership in the Communist Party did not in itself qualify as evidence of advocating hostility or harboring violent intentions against the U.S. government. Schneiderman himself had delivered no statement suggesting such sentiments and had never been arrested.15 If the U.S. Communist Party had uniformly advocated violence or if Schneiderman had advocated such views, the case would have been different. One can also wonder whether the court would have taken a different view had the Soviet Union and the United States not been military allies at the time. Denaturalization cases against Nazi sympathizers proceeded apace during the same period and were seen as legitimate as long as due process rights were respected and one could show that a citizen’s support of Hitler pertained to the period after 1933, when Nazis took control of Germany. At that point, one’s political beliefs shifted from advocating for a political party to advocating for a foreign government hostile to the United States.16
There are three key issues here. First, Congress can specify by statute the requirements of naturalization, which organizations are hostile to the principles of the Constitution, and which actions constitute prima facie evidence of a lack of attachment to the Constitution. It provided that statute with the McCarran Act of 1950, designed to target membership with racketeering, criminal, and Communist organizations.17
Second, in assessing an individual for denaturalization, the issue is whether actions, beliefs, or associations give cause to believe that a person has ever advocated hostility against the U.S. government. In Fedorenko v. United States (1981), the court examined the case of a Ukrainian national, Feodor Fedorenko, who had misrepresented his wartime activities on his initial visa application. He had served in the German army in the Second World War as a concentration camp guard. Although he was now a citizen, the court agreed that his prior military service was enough to warrant his denaturalization. Even if he no longer harbored those views, he had concealed material facts, and—more importantly—had served in the armed forces of a country hostile to the United States.
Third, there remains executive discretion to determine which are the most serious crimes that merit enforcing denaturalization. In 1979, the government created an Office of Special Investigation in the Department of Justice tasked with denaturalizing and often deporting naturalized American citizens who had failed to disclose some aspect of their Nazi past. Fedorenko was denaturalized as part of this initiative; his was one of eighty-six cases. In 2004, the office’s purview was expanded to include cases examining those who participated in war crimes, extrajudicial killings, or other acts of genocide around the world. Despite assertions to the contrary in the Warren Court era, naturalization is not absolute. There is an exception for those who have committed the worst kinds of crimes and whose presence on the citizenship roster tarnishes the concept of U.S. citizenship and damages the public good. Courts have not challenged this interpretation.18 The question therefore arises: Eighty years after the Second World War, do the kinds of actions, incitements, or organizations that lead to denaturalization need another update?
The British Precedent for Expanding Denaturalization
The British government has been addressing this question for decades and has revised its denaturalization processes to address new kinds of threats to the public good. The United Kingdom has enforced a denaturalization law since 1915. The British government clarified its nationality laws in 1981 with the British Nationality Act, whose Section 40 stipulated the conditions under which denaturalization could occur. Denaturalization decisions were a matter of executive discretion: If the secretary of state established that the person’s ongoing citizenship was not “conducive to the public good,” citizenship could be removed. Fraud, disloyalty, disaffection, criminal sentencing (of at least twelve months within the first five years of naturalization), and assisting the enemy during wartime were listed as possible reasons for denaturalization.
Recognizing the problem of homegrown terrorism after 9/11, the United Kingdom in 2002 expanded the government’s powers to denaturalize citizens. This reform extended the power to remove citizenship from those who held British citizenship by birth, so it is more accurate to describe the current British process as “deprivation,” which can affect both naturalized citizens and those who hold citizenship by birth. The powers of deprivation were enhanced in 2006 and 2014. From 2010 to 2024, there have been 1,342 deprivation orders for fraud and 223 orders for the “public good.” Most of these involve British citizens who go abroad to join a terrorist organization.19
The British government used Section 40 of the 1981 act to revoke the citizenship of Shamima Begum, a British-born Muslim of Bangladeshi origin who left the United Kingdom to join the Islamic State in 2015. She was deprived of citizenship in February 2019 after it emerged that she was still alive and unrepentant of her decision to join the Islamic State. This deprivation was upheld by the British Supreme Court. Begum’s case became something of a cause célèbre for progressive activists because she was a minor when she left the United Kingdom; but, this very defense reveals the weakness of the case against deprivation. Begum had intentionally joined a terrorist organization and did not regret her actions. Progressives often avoid this incriminating evidence entirely; their case against deprivation rests mostly on the warning that it will have a disproportionate impact on people of color. This is a specious argument, based on the pernicious logic of disparate impact, which is itself rooted in critical race theory. Their argument pays scant attention to the government’s expressed intention nor the genuine problem the government is addressing. The government’s actions concern the individual’s collaboration with a foreign terrorist organization.20
The British government hesitates to use deprivation more often because it is a signatory to international treaties that do not allow a government to leave someone stateless (in Begum’s case, she purportedly qualified for Bangladeshi citizenship; it was not the fault of the British government that Bangladesh said Begum would not be welcome in the country and would face arrest if she entered due to her terrorism-related activities). In any case, the British deprivation law can be applied to dual citizens, stripping them of British citizenship but leaving them with another valid citizenship. This action does not render such an individual stateless.
In 2025, to ensure that deprivation cases could remove someone dangerous or incendiary from the country, the British government specified that deprivation is an exercise of executive discretion subject to judicial review. If a lower court rules that denaturalization was unlawful, the plaintiff does not have his or her citizenship rights immediately restored. He or she remains stripped of citizenship until the government exhausts all appeals against the court. Finally, it should be noted that the changes in Britain’s denaturalization laws over the past few decades have been pursued by multiple British governments of different political parties. They do not represent partisan intrigue but reflect a reading of the new British reality and suggest a baseline understanding of and respect for what it means to be a British citizen.
The British reforms also provide the powers to address a new kind of case: foreign activists who deceive immigration officials about their anti-constitutional activities and views during the naturalization process.
In December 2021, the British government granted citizenship to the Egyptian activist Abd El Fattah. He seemed to check all the right boxes. A critic of the Egyptian government since the 2011 Arab Spring protests, he looked like a model human rights activist. He had ties to the United Kingdom: His mother was born in the United Kingdom. And he had been persecuted by the Egyptian government. Fattah had been in and out of prison for years; tortured by the Egyptians in 2021, they had arrested him again. The British government lobbied for his release, and in 2025, he resettled in the United Kingdom.
Then a search of Fattah’s social media activity revealed his true character. For over fifteen years, he had expressed anti-British, antisemitic, and anti-white sentiments. The British were “dogs and monkeys,” he wrote. Suicide bombings were acceptable if they “end a few Zionists’ lives.” He wanted a drone to “shoot Zionist weddings.” He wrote that “humanity will not b[sic] redeemed until we commit genocide against all white people,” that “the extermination of whites is a desirable thing,” and that the “random shooting of white males” was necessary.21
Fattah had abused the goodwill of a Western nation and its citizenship laws to secure a platform from which to continue his activism. Moreover, he concealed from the British government material facts about his own record and the nature of his political agenda. His citizenship should be revoked. Yet the challenge facing the United Kingdom isn’t that it lacks the legal tools to do so. On the contrary, the British government has for years strengthened its denaturalization laws to prepare for instances such as this one. It just refuses to act.
Denaturalization
The United States doesn’t have to deal with the problem of Islamic terrorism or support for it that Britain does, or at least not on the same scale as Britain. But a proactive strategy is necessary, as these trends will continue to worsen in the future. The objective for the United States is to prepare to address the problems Britain and other Western countries face, within the fullest scope permitted by the U.S. constitutional order, to deter anticonstitutional, anticivilizational agitators who are hostile to the American way of life.
Denaturalization depends on identifying what qualifies as prima facie evidence that an individual lacked “sound moral character,” was “hostile to the basic form of government of the United States,” and did “not believe in the principles of the Constitution” at the time of naturalization. This shows that the naturalized citizen never intended, in good faith, to become a permanent citizen of the United States. Congress can clarify what qualifies as prima facie evidence. Such evidence could include state and federal criminal convictions, membership in criminal organizations, welfare fraud, and incitement to hostile actions. And it must include failing to disclose in writing to immigration authorities a conviction for any crime committed prior to naturalization.
Federal Criminal Convictions
The British government is correct in including serious criminal offenses as a potential reason for deprivation of citizenship. In the United States, the most serious federal crimes are terrorism, fraud, human trafficking, child sexual abuse, espionage, and murder. A naturalized citizen who commits any of these acts violates the most basic responsibilities of citizenship. Committing one of these heinous crimes should qualify as prima facie evidence that the naturalized citizen never understood the terms of citizenship. The crimes that qualify as prima facie evidence should be federal crimes that, in light of their seriousness, meet or exceed the eight-year standard of the statute of limitations.22 If a naturalized citizen is found guilty of such a crime within the first twenty-five years of acquiring citizenship, this should constitute prima facie evidence of denaturalization.
Membership in Foreign Terrorist or Criminal Organizations
The original provisions of congressional naturalization laws specified residency. They captured an important point: One who departs the country after becoming a citizen demonstrates one’s lack of loyalty to the new nation and reveals a preference to preserve old ties to foreign entities—or form new ones. In either case, such actions demonstrate a lack of proper attachment to the United States in the first place.
The examples from the United Kingdom cited above show how citizens can abandon their national loyalties to join or affiliate with transnational organizations (such as the Islamic State, which, despite its pretensions, was not a formally recognized state). Congress should clarify which organizations are hostile to the U.S. government and the principles of the U.S. Constitution. Joining any of these organizations within twenty-five years of the acquisition of citizenship should qualify as prima facie evidence that the naturalized citizen never understood the terms of citizenship. This evidence should include membership or affiliation with foreign terrorist organizations, transnational drug cartels, and other organized crime groups. If a naturalized citizen joins or affiliates with such organizations within the first twenty-five years of acquisition of citizenship, this action should qualify as prima facie evidence for denaturalization.
Welfare Fraud
Citizenship also confers access to entitlement and welfare programs, which means that in many instances, becoming a citizen means being eligible for these kinds of funds. Congress has clarified this eligibility, passing welfare reform that sought to deny illegal aliens benefits for public services or welfare while restricting the access of aliens by deferring the period of eligibility. Even though in the past the executive has not honored this legislation, these laws’ very existence reveal an important reality about the United States: It is a welfare state. Those who become American citizens gain access to considerable material advantages supported by other U.S. citizens.23 It is, therefore, an insult to those citizens and an affront to the body politic when recently naturalized U.S. citizens commit widespread welfare fraud. Such exploitation of the resources of other Americans shows that one likely never understood the responsibilities citizens have toward each other. If a naturalized citizen is found guilty of protracted welfare fraud at the local, state, or federal level within the first twenty-five years of acquiring citizenship, that crime should be taken as prima facie evidence that the person had no intention of complying with the statutory requirements for naturalization.
Incitement to Hostile Action
Actions or speech that incites hostility to “the basic form of government of the United States” or to “the principles of the Constitution” should also be subject to scrutiny by the attorney general. If that action or speech took place before naturalization, it should qualify as prima facie evidence that one never intended naturalization. This reform will ensure that agitators such as Abd El Fattah are not able to exploit the U.S. citizenship process and that those who have done so are subject to denaturalization. This is not to say that such speech should be treated as a criminal act. But the First Amendment does not require turning foreign agitators into citizens or preserving their naturalization status if material facts emerge about their past activities, deeds, or speech that they failed to disclose at the time of naturalization.
Residence Outside the United States
Congress should revisit Schneider v. Rusk (1964), which restricts Congress’s powers to set residency requirements for naturalization. This reform is particularly important to reestablish in an era of mass migration, where it is easy to set up residence abroad. Congress doesn’t need to remove citizenship for naturalized American citizens who are married to foreigners and who live abroad—the issue at the core of Schneider. But it can set residency requirements for adults who acquire citizenship and then decide to leave the United States and live abroad. These people demonstrate an insufficient attachment to the U.S. Constitution. The original 1906 standard helped ensure the worth of citizenship in a similar era of mass mobility, when many migrants to the United States decided to return to their country of origin. The 1906 standard should be restored. If, within five years of receiving citizenship, the naturalized U.S. citizen returns to his or her native country or goes to another foreign country and establishes a permanent residence there—and this is not done because the U.S. citizen married a foreigner after naturalization and moves to follow the foreigner to his or her country—that should be considered prima facie evidence that the naturalized citizen never intended to become a permanent citizen of the United States.
Expatriation
The United States should also reform its rules governing expatriation, which in their current form presume interstate conflict. This is why they stress the presumption that an adult acting on behalf of a foreign state indicates intentional expatriation. The likelihood of dealing with a rise in homegrown terrorism or Americans leaving to join a foreign conflict on behalf of a terrorist organization indicates that this framework needs to be modified. These kinds of people can be charged with treason, imprisoned, or even sentenced to death. But when the death penalty is not available, the preference should be for expatriation.
As with denaturalization, expatriation rules should be extended to include acting on behalf of foreign terrorist organizations, transnational drug cartels, and other transnational criminal organizations. Intentionally joining these organizations, which behave as if they were states hostile to the United States, should qualify for expatriation.
Afroyim v. Rusk (1967) must also be revisited to restore a larger scope for Congress to clarify which actions constitute expatriation. These actions should include a decision to live outside of the United States. A natural-born U.S. citizen who has one citizen and noncitizen parent inside or outside the United States must show five-year continuous residency in the United States between the ages of fourteen and twenty-four.24 Failure to do so should be considered voluntary renunciation of citizenship. Moreover, a natural-born U.S. citizen with two noncitizen parents legally residing in the United States must have taken up residence in the United States prior to the age of fourteen and show five-year continuous residency in the United States before the age of twenty-four. Failure to do so should be considered voluntary renunciation of citizenship.
These proposed reforms are critical to address the growing problem of birth tourism. For years, parents have taken advantage of loopholes in current U.S. jurisprudence to give their children U.S. citizenship without intending to reside permanently in the United States. Not only is this a cynical exploitation of American law; it also poses risks to national security, allowing foreign powers to gain leverage and influence over the U.S. electoral process.25
The executive branch’s efforts to close these loopholes must be followed by statutory clarification. Parents, acting on behalf of their child, must show that they intend to reside in the United States after the child is born. Once the child becomes an adult, he or she must demonstrate through a five-year residency that the United States is the country to which he or she belongs. Failure to take up residency in the United States should be considered an indication that he or she does not wish to remain a U.S. citizen.
Restoring the Value of Citizenship
When Abraham Lincoln’s valet William Johnson died, Lincoln ordered that his tombstone bear the nation’s highest honorific: “Citizen.”
We are a long way from Lincoln’s world now. That title has been coarsened and cheapened by abusers, fraudsters, and hustlers. Citizenship is a depleted, devalued currency. But the country can change course. The government can use the currently existing legal tools to investigate those granted citizenship in the last few decades to see whether they concealed their real actions, misled the government, and took advantage of the citizenship process. And it should go further. Updating laws can clarify the proper use of the tools available and strengthen the case for denaturalizing those who failed to meet the statutory requirements. Other Western states are following the same path. Denaturalization removes the agitators, criminals, and terrorists who travel with the papers of the United States. Most important, however, is the opportunity to restore the value of citizenship. The law is a teacher. Statutes clarifying the conditions of denaturalization and expatriation convey to all Americans—whether they are born into citizenship or acquire it later in life—the duties and responsibilities they owe to each other. It helps remove the tarnish on the nation’s highest honorific and restore its worth in our eyes and the eyes of the world.
Endnotes
1. “The Southern District of Texas Denaturalizes Child Sex Offender,” Office of Public Affairs, U.S. Department of Justice, January 26, 2026, https://www.justice.gov/opa/pr/southern-district-texas-denaturalizes-child-sex-offender.
2. “Justice Department Secures Denaturalization of Maryland Man Who Repeatedly Raped Minor Victim,” Office of Public Affairs, U.S. Department of Justice, September 16, 2025, https://www.justice.gov/opa/pr/justice-department-secures-denaturalization-maryland-man-who-repeatedly-raped-minor-victim.
3. “Justice Department Secures Denaturalization of Convicted Distributor of Child Sexual Abuse Material Who Fraudulently Obtained U.S. Citizenship,” Office of Public Affairs, U.S. Department of Justice, June 20, 2025, https://www.justice.gov/opa/pr/justice-department-secures-denaturalization-convicted-distributor-child-sexual-abuse.
4. Victor Nava, “DOJ Memo Outlines Plans for ‘Prioritizing Denaturalization’—aka Yanking US Citizenship—of Individuals Charged with Certain Crimes,” New York Post, July 1, 2025, https://nypost.com/2025/07/01/us-news/doj-memo-outlines-plans-for-prioritizing-denaturalization-for-certain-crimes/.
5. See Immigration and Nationality Act, § 316 (8 U.S.C. § 1427).
6. Immigration and Nationality Act, § 316(e) (8 U.S.C. § 1427).
7. “Chapter 7: Attachment to the Constitution,” U.S. Citizenship and Immigration Services, accessed January 15, 2026, https://www.uscis.gov/policy-manual/volume-12-part-d-chapter-7. See also
8. See Immigration and Nationality Act, § 340 (8 U.S.C. § 1451).
9. United States v. Ginsberg, 243 U.S. 472, 475 (1917).
10. Johannessen v. United States, 225 U.S. 227, 241 (1912).
11. See Immigration and Nationality Act, § 349 (8 U.S.C. § 1481).
12. Schneider v. Rusk, 377 U.S. 163 (1964). See also Perez v. Brownell, 356 U.S. 44 (1958), which deferred to Congress’s statutory authority to clarify the terms of denaturalization.
13. See Luria v. United States, 231 U.S. 25 (1913); Patrick Weil, The Sovereign Citizen: Denaturalization and the Origins of the American Republic (University of Pennsylvania Press, 2013), 136.
14. Luria v. United States.
15. Schneiderman v. United States, 320 U.S. 134 (1943): “According to the record, he has never been arrested or connected with any disorder, and not a single written or spoken statement of his, during the relevant period from 1922 to 1927 or thereafter, advocating violent overthrow of the Government, or indeed even a statement, apart from his testimony in this proceeding, that he desired any change in the Constitution has been produced.”
16. This is the issue in Baumgartner v. United States, 322 U.S. 665 (1944).
17. Weil, The Sovereign Citizen, 136.
18. Weil, The Sovereign Citizen, 178–79.
19. CJ McKinney, Melanie Gower, and Terry McGuinness, “Deprivation of British Citizenship and Withdrawal of Passports,” research briefing, House of Commons Library, UK Parliament, December 18, 2025, https://commonslibrary.parliament.uk/research-briefings/sn06820/.
20. See Stripped: The Citizenship Divide, Runnymede, December 2025, https://www.runnymedetrust.org/publications/stripped-the-citizenship-divide.
21. Michael Knowles, “Alaa Abd El-Fattah Claims Tweets Were ‘twisted’ as He Breaks Silence,” Express, December 29, 2025, https://www.express.co.uk/news/politics/2151201/alaa-abd-el-fattah-Labour-Keir-Starmer-egypt-human-rights-tories-citizenship.
22. At the present time, this includes terrorist activities that damage property but do not lead to loss of life. See Charles Doyle, “Statute of Limitation in Federal Criminal Cases: An Overview,” CRS Report RL 31253, November 14, 2017, https://www.congress.gov/crs-product/RL31253.
23. George Fishman, “Undoing Clinton’s Sabotage of Restrictions on Immigrant Welfare Use,” Center for Immigration Studies, September 16, 2025, https://cis.org/Report/Undoing-Clintons-Sabotage-Restrictions-Immigrant-Welfare-Use; T. Elliot Gaiser, “Interpretation of ‘Federal Means-Tested Public Benefit’ in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996,” Office of Legal Counsel, December 16, 2025, https://www.justice.gov/olc/media/1421356/dl.
24. As per Rogers v. Bellei (1971), but expanding the judgement to address not only citizens born abroad but those born in the United States. The statutory proposal imitates Section 301(b) of the Immigration and Nationality Act of 1952, which stated that a child born abroad to a U.S. citizen and an alien will lose his U.S. citizenship unless he comes to the United States prior to the age of twenty-three and is continuously present for five years between the ages of fourteen and twenty-eight. This proposal should not affect the children of American missionaries, military, or other federal government employees who must work abroad.
25. Max Bacall, “China Exploiting ‘Birth Tourism’ to Gain Long-Term Political Influence in US, Author Warns,” Fox News, January 21, 2026,
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