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The Trump administration has vowed to step up revocations of citizenship from some naturalized Americans as part of a broader effort to double down on immigration enforcement.

The messaging has sparked fear among immigrant advocates, legal scholars and naturalized citizens who worry about the potential for abuse and the precedent it sets that naturalized immigrants are in a separate class from U.S.-born Americans.

But the cases filed so far are narrower than this rhetoric suggests, highlighting the legal and practical constraints on using this tool more broadly.

NPR reviewed 34 publicly announced denaturalization cases filed or resolved by the DOJ as of May 19, including 11 revocations of citizenship.

“I’m not seeing a major surge of worrisome denaturalizations. To me, it’s not at the level of an emergency,” said Daniel Kanstroom, professor of law at Boston College who specializes in immigration.

In the last 16 months, the Trump Justice Department says it surpassed the number of cases filed during all four years of the Biden administration — 64, according to available data. The administration is pitching a supercharged denaturalization effort as yet another way to address border security.

“The Department of Justice is laser-focused on rooting out criminal aliens defrauding the naturalization process,” a DOJ spokesman said in a statement. “We are moving at warp speed to ensure fraudsters are held accountable and prosecuted to the fullest extent.”

In a speech at the Border Security Expo in Phoenix in May, acting Attorney General Todd Blanche echoed the sentiment, saying the department was “trying to protect the integrity of the naturalization process.”

“Protect the citizenry”

To supporters of the effort such as Gene Hamilton, president of the nonprofit conservative group America First Legal, this kind of work should have been happening already.

“If you’re a serious government, if you’re a serious nation, one of your foremost duties is to protect the citizenry and protect the meaning and the value of citizenship,” he said.

But the cases brought so far illustrate how difficult it could be for the administration to pursue denaturalization on a mass scale, according to Kanstroom and other immigration law experts. Unlike the administration’s broader deportation agenda, which involves swift and aggressive detentions and deportations, naturalized U.S. citizens have much stronger legal protections.

People wave U.S. flags to celebrate becoming U.S. citizens after taking the oath of allegiance during a naturalization ceremony in the jury assembly room at the John Joseph Moakley United States Courthouse in Boston, Mass., in January 2025.

Joseph Prezioso/AFP via Getty Images

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Joseph Prezioso/AFP via Getty Images

“These are cases in which the law is pretty clear that people are entitled to due process. They’re entitled to be heard by a federal judge, not just an immigration judge. So the protections in place for people facing denaturalization are pretty robust,” Kanstroom said.

Cassandra Robertson, law professor at Case Western Reserve University, largely agrees such cases are harder to bring. But she’s still worried about the implications of using denaturalization more broadly than prior administrations have.

“The denaturalization efforts are an attempt to suppress the political speech of naturalized citizens,” she argued. “Although the cases that have been brought first are maybe people who’ve committed some pretty bad crimes, the government’s rhetoric is certainly not limited to that.”

The DOJ didn’t respond to most of NPR’s questions for this story.

What do these cases tell us?

Denaturalization cases are historically rare and typically target people accused of concealing serious criminal conduct or illegal affiliations with terrorist groups while they’re going through the naturalization process.

The 34 cases reviewed by NPR largely involve allegations of fraud, child sexual abuse, terrorism-related activity, war crimes and drug trafficking. In court filings, the DOJ argues the defendants concealed conduct that would have disqualified them from demonstrating the “good moral character” required for citizenship.

In one recent case, the DOJ revoked the citizenship of Melchor Munoz after arguing he lied and concealed the fact that he was dealing drugs during his naturalization process.

His attorney, Joe Pace, disputes that claim and says the government relied heavily on inaccuracies in an old plea agreement that stated Munoz began dealing drugs before becoming a citizen. Pace says the conduct actually began afterward, meaning his client should not have been subject to denaturalization. He added that Munoz, whose English is limited, was badly advised by his criminal lawyer at the time.

After a two-day trial, a federal judge sided with the DOJ, finding Munoz’s “testimony not credible.” Munoz, who still resides in Florida and is now on a green card, plans to appeal.

Losing sleep about “what it does to the system”

Kanstroom said the denaturalization cases publicly announced so far are on par with cases the U.S. government might have pursued in prior administrations.

He said he’s reassured by the fact that each of these cases have been assigned to judges in federal districts across the country, are going through the regular civil or criminal docket and are overall “happening within the parameters of the law.”

Robertson, of Case Western, said the government appears to be intentionally picking cases with criminal convictions because they are easier to win.

Still, Robertson, who has studied U.S. denaturalization, worries about where the policy could lead, especially because civil denaturalization cases come with fewer protections than criminal proceedings do.

Defendants in civil cases are not entitled to appointed attorneys if they cannot afford them. And civil denaturalization cases generally have no statute of limitations.

“When we’re talking about things that happened 20 or 30 or even more years ago, it is incredibly hard for anybody to be able to find witnesses who knew what was going on at that time, or have any kind of documentary evidence,” leaving defendants vulnerable to flimsy evidence, she said.

Minimal legal representation, court appearances

In many of the cases reviewed by NPR, the defendants lacked legal representation. Several cases resulted in denaturalization with minimal or no court appearance by the defendant.

That included the case of Vladimir Volgaev, a native of Ukraine, who became a U.S. citizen in 2016. In 2020, he was convicted of smuggling gun components from the U.S. to people in Ukraine and Italy. He was also convicted of theft of government money or property by underreporting his assets and income on applications for federal housing benefits, the DOJ says.

In a case filed in September, the DOJ claimed Volgaev concealed and misrepresented his involvement in the smuggling operation during his naturalization process and thus should lose citizenship. A summons was issued but neither Volgaev nor an attorney made a court appearance or filed a response in the case, court records show. Volgaev’s citizenship was revoked on March 23.

Another case of a lack of representation was for Elliott Duke, who the DOJ sued while they were already serving time in federal prison for distributing child pornography during Duke’s time in the U.S. Army. The DOJ filed the case in February 2025 and a federal judge ruled to revoke Duke’s citizenship roughly four months later. Duke, who uses they/them pronouns, previously told NPR they were unable to get a lawyer or travel to attend hearings.

“It’s just a dangerous road to go down for denaturalization. I might not feel sorry for the heinous child abuser who loses their citizenship. I’m not going to lose sleep over that,” said Robertson. “But I am going to lose sleep over what it does to the system. Because once it becomes easy to take somebody’s citizenship away — it becomes easy to take anybody’s citizenship away.”

Assigning U.S. attorneys

As the DOJ faces an exodus of thousands of skilled lawyers, the department has assigned denaturalization cases to U.S. attorneys offices across the country, a person familiar with this information confirmed. The person wasn’t authorized to speak publicly.

The offices of U.S. attorneys are now tasked with handling hundreds of cases of foreign-born Americans the department has identified as potential cases for revoking citizenship.

The DOJ didn’t respond to specific questions about these cases.

Stacey Young, founder of Justice Connection, an organization of former DOJ staffers, said denaturalization cases require “a huge expenditure of time and resources,” helping explain why the DOJ historically filed relatively few of them. Young used to be a DOJ attorney who worked on denaturalization cases.

“The recent plans for escalation are unprecedented and will require an immense amount of time and work by lawyers who are already stretched thin right now,” she said.

Hamilton, with America First Legal, said it’s worth it.

“It is exactly what the government should be doing. And quite frankly, I would like to see even more resources devoted to it as they’re able to do so,” he said.

Fears of politicization

But former DOJ attorneys, including Young, worry that prioritizing denaturalization cases could lead to retaliation against perceived enemies of the administration – something the current Justice Department has already been accused of doing.

Robertson pointed to comments from Trump and others in the administration threatening the citizenship of political opponents — such as New York City Mayor Mamdani and Minnesota Rep. Ilhan Omar — as evidence that there is a real threat that the DOJ would use denaturalization as a tool for “political retribution.”

“The retaliatory nature of this administration and using the law in any type of legal maneuvering to go after its enemies — that is a serious concern of mine,” agreed a former DOJ attorney who worked for nearly a decade in the Office of Immigration Litigation, which handles denaturalization cases. The attorney spoke on the condition of anonymity for fear of retaliation from the federal government.

Previously, attorneys in this office were given discretion to decide what cases to pursue. But things changed under the Trump administration and the mandate became to pursue anyone potentially eligible, even for minor paperwork errors or immaterial discrepancies, this person said.

Leaders at the department pressured lawyers to generate cases quickly, sometimes by combing through news stories or social media posts involving naturalized citizens, according to the former attorney, who left the DOJ last year.

Meanwhile, Kanstroom remains cautiously optimistic that denaturalizations won’t become politicized, since they’re legally and practically harder to pursue, or potentially abused, than other forms of immigration enforcement.

Defendants can still challenge the evidence presented against them and appeal rulings. Federal judges — not immigration judges employed by the DOJ — oversee these cases.

“I certainly don’t see an easy pathway for this administration to fast-track denaturalizations or do end runs around the judiciary,” he said.