A naturalization interview can feel like the finish line after years of immigration filings, long waits, family separation, and uncertainty. For most people who became citizens lawfully and answered the government’s questions truthfully, U.S. citizenship remains secure.
However, naturalization and denaturalization are connected legal concepts.
Naturalization is the legal process through which an eligible lawful permanent resident becomes a U.S. citizen. Denaturalization of U.S. citizenship is the serious legal process through which the federal government seeks to revoke citizenship that it claims was unlawfully obtained.
This distinction has become increasingly important.
On June 11, 2025, the Department of Justice’s Civil Division issued an enforcement memorandum directing federal attorneys to prioritize and “maximally pursue” legally permitted and evidentially supported denaturalization cases. The memorandum identified ten broad enforcement categories involving national security, human-rights violations, organized crime, undisclosed felonies, violent crimes, sexual offenses, government fraud, private financial fraud, immigration fraud, and other cases the Civil Division considers sufficiently important.
The policy has been followed by coordinated federal filings.
In March 2026, DOJ announced that it had obtained two denaturalization judgments and filed a new complaint involving alleged marriage and naturalization fraud. In May 2026, DOJ announced 12 new denaturalization actions. In June 2026, it announced 17 additional complaints. On July 17, 2026, a federal court entered a consent judgment revoking the citizenship of a person accused of concealing his identity and alleged involvement with Bosnian security forces connected to war crimes.
A civil complaint contains allegations that the government must still prove. It is not a judgment of liability. A consent judgment, default judgment, or contested judgment is legally different from the filing of a complaint.
These enforcement developments do not mean every naturalized citizen should live in fear.
Denaturalization is not a general power to cancel citizenship because the government dislikes someone, because political priorities change, or because a naturalized citizen later commits an unrelated offense. The government must invoke an authorized statutory ground and follow the required judicial or criminal process.
The 2025 DOJ memorandum is an enforcement-priority document. It did not create new statutory grounds, eliminate judicial review, or lower the government’s burden of proof. DOJ’s current Justice Manual also emphasizes that denaturalization decisions remain case-specific and that not every referral falling within a priority category should result in litigation.
Still, anyone preparing Form N-400, facing criminal charges, or discovering inconsistencies in an old immigration case should understand how naturalization records may later be reviewed.
What is Naturalization?
Naturalization is the process through which a person who was not born a U.S. citizen becomes one after satisfying the requirements established by Congress.
Most applicants apply after five years as lawful permanent residents. Certain applicants married to U.S. citizens may qualify under a three-year provision when they satisfy the applicable citizenship, residence, physical-presence, and marital-union requirements. Separate rules apply to certain military members, spouses employed abroad, and other specialized categories.
A typical naturalization applicant must establish:
- Lawful admission for permanent residence;
- Continuous residence in the United States;
- The required physical presence;
- Residence within the appropriate state or USCIS district;
- Good moral character during the applicable period;
- Continued eligibility through the administration of the oath;
- Basic English ability, unless an exception applies;
- Knowledge of U.S. history and government;
- Attachment to the principles of the Constitution; and
- Willingness to take the Oath of Allegiance.
Time as a permanent resident is only one part of the analysis.
Federal law permits USCIS to examine conduct occurring before the ordinary three-year or five-year good-moral-character period when older conduct is relevant to the applicant’s current character or claimed rehabilitation. The applicant must also continue to establish good moral character through the date of naturalization.
On August 15, 2025, USCIS issued a memorandum emphasizing a rigorous, holistic, and totality-of-the-circumstances evaluation of good moral character. That policy did not create a new denaturalization ground, but it reflects increased attention to both favorable and unfavorable conduct during naturalization adjudications.
An applicant therefore should not assume that an arrest, immigration issue, tax problem, false statement, or other misconduct becomes irrelevant merely because it occurred more than five years ago.
Naturalization Requires More Than Passing the Interview
A successful naturalization case is based on the applicant’s entire immigration history—not only the information entered on the current Form N-400.
USCIS may compare the application with earlier records, including:
- Visa applications;
- Form I-485 adjustment applications;
- Form I-130 family petitions;
- Asylum or refugee records;
- Consular filings;
- Border and travel records;
- Removal proceedings;
- Criminal records;
- Tax records; and
- Statements made to other government agencies.
An inconsistency does not automatically prove fraud.
People forget dates, misunderstand questions, receive poor translations, or rely on unqualified preparers. A prior form also may contain an innocent clerical error.
However, inconsistencies should be identified and addressed before the oath whenever possible.
An applicant signs Form N-400 under penalty of perjury and ordinarily confirms or updates the answers during the interview under oath. Important developments occurring after filing—including an arrest, separation, extended trip, tax issue, or criminal charge—may need to be disclosed before the applicant takes the oath.
Accuracy matters because the government may later argue that truthful information would have caused USCIS to deny naturalization or conduct an investigation that uncovered a disqualifying fact.
What Is Denaturalization of U.S. Citizenship?
Denaturalization of U.S. citizenship is the revocation of citizenship obtained through naturalization.
It is different from voluntarily renouncing citizenship. It is also different from losing or abandoning lawful permanent resident status.
For most civil cases, the government proceeds under 8 U.S.C. § 1451(a). That statute permits a federal district court to revoke naturalization when citizenship was:
- Illegally procured; or
- Procured through concealment of a material fact or willful misrepresentation.
A civil judgment revoking naturalization is effective as of the original naturalization date. The statute also provides that the defendant generally receives 60 days’ personal notice, unless waived, to answer the government’s action.
USCIS may investigate a case, examine the immigration file, collect evidence, and recommend civil or criminal action. Under the regulations, USCIS may refer a suspected civil case or report facts to the appropriate United States Attorney when criminal prosecution may be warranted.
USCIS generally does not revoke naturalized citizenship through an ordinary administrative letter. Judicial denaturalization ordinarily requires a federal district court proceeding.
Administrative correction or cancellation of an improperly issued certificate should not be confused automatically with judicial revocation of the person’s citizenship status.
Civil and Criminal Denaturalization Are Different
The government can pursue denaturalization through civil litigation or through a criminal naturalization-fraud prosecution.
Civil Denaturalization
In a civil case, the United States files a lawsuit in federal district court under 8 U.S.C. § 1451(a).
The naturalized citizen may:
- Answer the complaint;
- Contest the allegations;
- Seek discovery;
- Challenge the government’s evidence;
- Present affirmative defenses;
- File appropriate motions;
- Proceed to trial; and
- Appeal an adverse judgment.
A prior criminal conviction is not required for a civil denaturalization case.
Criminal Naturalization Fraud
Under 18 U.S.C. § 1425, the government may prosecute a person who knowingly procured or attempted to procure naturalization or citizenship contrary to law.
When a person is convicted under § 1425 for unlawfully procuring their own naturalization, 8 U.S.C. § 1451(e) directs the criminal court to revoke the person’s citizenship and cancel the naturalization certificate.
In Maslenjak v. United States, the Supreme Court held that the government must prove the illegal act played the legally required role in the acquisition of citizenship. A legally irrelevant falsehood does not support a § 1425 conviction merely because it occurred somewhere during the naturalization process.
The civil and criminal routes therefore involve different procedures, elements, and consequences.
What Does “Illegally Procured” Citizenship Mean?
Citizenship is illegally procured when a person failed to satisfy a legal requirement for naturalization when citizenship was granted.
This theory does not always require the government to prove intentional fraud. The central question may be whether the applicant was legally eligible.
Possible allegations include that the person:
- Was not lawfully admitted for permanent residence;
- Obtained a green card through fraud or an invalid petition;
- Failed to satisfy continuous-residence or physical-presence rules;
- Did not qualify under the three-year marital-union provision;
- Lacked good moral character;
- Committed disqualifying conduct during the statutory period;
- Was statutorily barred from naturalization; or
- Failed another congressionally imposed requirement.
The Supreme Court has explained that applicants must strictly comply with the statutory conditions Congress established for naturalization. When a required condition was absent, citizenship may have been illegally procured even if USCIS approved the application.
This is why a careful N-400 review may need to begin with the original green-card case.
If the government proves that the person was never lawfully admitted as a permanent resident, it may argue that the person could not lawfully naturalize later. The issue may arise from an earlier marriage petition, asylum application, employment filing, identity record, waiver, admission, or adjustment application.
Florida and Eleventh Circuit Authority
Florida is within the Eleventh Circuit, which has directly addressed denaturalization based on conduct occurring during the naturalization period.
In United States v. Jean-Baptiste, the Eleventh Circuit upheld denaturalization where a later criminal conviction established that the person had committed serious unlawful conduct during the period in which good moral character was required.
The court focused on when the underlying conduct occurred—not merely the later conviction date. Because the person had committed disqualifying conduct during the statutory period, the court concluded that citizenship had been illegally procured.
The decision illustrates why a criminal case filed after naturalization may still create risk when the admitted conduct began before the oath.
Concealment, Willful Misrepresentation, and Material Facts
The second major civil theory involves citizenship allegedly obtained through concealment of a material fact or willful misrepresentation.
Not every typo, forgotten date, or imperfect answer supports denaturalization of U.S. citizenship.
In a civil case, the government generally must establish that the concealment or misrepresentation was willful and concerned a material fact.
In Kungys v. United States, the Supreme Court explained that a fact is material when it had a natural tendency to influence the naturalization decision. Materiality can exist when truthful disclosure would itself have demonstrated ineligibility or would have led to a relevant investigation that uncovered disqualifying information.
The legal analysis may ask:
- Was the answer actually false?
- Did the person know it was false?
- Was the omission deliberate?
- Was the question understood?
- Did the alleged fact concern eligibility?
- Would truthful disclosure have affected adjudication?
- Would disclosure have prompted an investigation?
- Would that investigation predictably have uncovered a disqualifying fact?
An innocent mistake, reasonable misunderstanding, translation error, or preparer error may be very different from an intentional lie intended to secure approval.
However, blaming a preparer does not automatically resolve the case. The applicant’s knowledge, signature, later interview testimony, and opportunity to correct the information remain relevant.
False Testimony and Good Moral Character
False testimony presents a related but distinct issue.
Under the good-moral-character statute, “false testimony” generally means:
- An oral statement;
- Made under oath;
- Known to be false; and
- Made with the subjective purpose of obtaining an immigration or naturalization benefit.
Under this specific rule, the oral statement does not necessarily have to be material.
A false written answer may still create serious issues involving willful misrepresentation, perjury, credibility, or illegal procurement. However, a written statement is not automatically “false testimony” under the particular good-moral-character provision. Kungys explains the distinction between the false-testimony rule and material misrepresentation.
The context matters.
A written error, an oral answer caused by a translation problem, an uncertain response, and a deliberate statement intended to secure citizenship may have very different legal consequences.
Can a Crime After Naturalization Cause Denaturalization?
A crime committed entirely after naturalization ordinarily does not justify denaturalization merely because it is serious.
The government generally must connect the criminal matter to:
- Eligibility at the time of naturalization;
- Conduct during the good-moral-character period;
- A false answer or omission;
- Fraud in the underlying immigration process; or
- Another authorized statutory ground.
The risk becomes more serious when a later prosecution reveals that:
- The criminal conduct began before naturalization;
- The conduct occurred during the statutory period;
- The applicant denied committing offenses for which there had been no arrest;
- The applicant concealed an investigation, association, or conspiracy;
- The criminal plea contradicts an N-400 answer; or
- Permanent residence and citizenship arose from the same fraudulent scheme.
DOJ’s 2026 complaints include multiple allegations that convictions entered after naturalization proved criminal conduct had occurred during the earlier good-moral-character period. Those allegations remain subject to proof in the pending civil cases.
The date of conviction is therefore not always the controlling date. The government may focus on when the conduct began, what the person knew, and what was said during the naturalization process.
Limited Post-Naturalization Grounds
There are narrow statutory provisions involving specified events after naturalization.
For example, 8 U.S.C. § 1451(c) addresses certain prohibited organizational affiliations within five years after naturalization. Separate military-naturalization provisions may apply when a person naturalized through qualifying military service but later separates under other-than-honorable conditions before completing the required service.
These are limited provisions.
DOJ’s Justice Manual instructs attorneys to apply heightened scrutiny before relying on narrow statutory mechanisms connected to post-naturalization conduct.
Why Criminal Plea Language Matters
A criminal defense strategy can substantially affect a naturalized citizen.
Plea agreements often contain detailed factual admissions, including:
- When a conspiracy began;
- How long the conduct continued;
- Participation in a fraudulent scheme;
- Use of false documents or identities;
- Amounts of financial loss;
- Undisclosed victims;
- Organizational involvement; and
- Conduct occurring before naturalization.
Those admissions may later be offered in a civil denaturalization action.
A plea that appears favorable for sentencing may create serious citizenship consequences if it establishes that the person engaged in disqualifying conduct during the naturalization period or gave inaccurate answers to immigration authorities.
A naturalized citizen facing a serious criminal charge should therefore seek coordinated criminal, immigration, and federal-litigation advice before accepting a plea whenever possible.
The Government Has a Heavy Burden
Citizenship is a fundamental legal status.
In a civil denaturalization case, the government must generally prove its allegations by evidence that is clear, unequivocal, and convincing and that does not leave the issue in doubt.
That standard is more demanding than the ordinary preponderance-of-the-evidence standard used in most civil lawsuits. The Supreme Court has repeatedly emphasized the severe consequences associated with loss of citizenship and has required courts to scrutinize the evidence carefully.
The government’s heavy burden remains an important protection.
A DOJ enforcement memorandum does not alter the statute, eliminate defenses, or reduce the government’s evidentiary obligation.
Civil denaturalization actions also generally have no statute of limitations. A case may be filed decades after naturalization if the government later obtains evidence that it believes establishes illegal procurement or material concealment.
The age of a case may create evidentiary difficulties, unavailable witnesses, missing records, or fairness concerns. Time alone, however, does not necessarily prevent the government from filing a civil action.
Potential Defenses in a Civil Denaturalization Case
A complaint does not establish that citizenship was unlawfully obtained.
Potential defenses may include:
- The person satisfied the disputed naturalization requirement;
- The underlying permanent residence was lawful;
- The challenged statement was true or substantially accurate;
- The alleged omission was unintentional;
- The person reasonably misunderstood the question;
- The answer resulted from a translation or communication error;
- The alleged concealment was not willful;
- The fact was not material under Kungys;
- Truthful disclosure would not have affected eligibility;
- The government cannot establish the required causal connection;
- The relevant conduct occurred outside the statutory period;
- The criminal judgment does not establish the immigration allegation;
- The plea language is narrower than the government claims;
- The evidence is inadmissible, unreliable, or incomplete;
- The government failed to satisfy procedural requirements; or
- The evidence does not meet the heightened burden.
A preparer or translator error may be relevant, but it is not automatically decisive. The court may examine what the person knew, what the person later confirmed under oath, and whether there were opportunities to correct the record.
The defense should separate innocent inconsistencies from deliberate concealment and determine whether the alleged fact actually affected naturalization eligibility.
Common Problems That May Trigger Scrutiny
Fraud in the Underlying Green-Card Case
Naturalization may be vulnerable if permanent residence allegedly was obtained through a sham marriage, fabricated asylum claim, false identity, fraudulent employment petition, or another material misrepresentation.
Undisclosed Criminal Conduct
Form N-400 asks about more than convictions. Questions may cover arrests, citations, charges, and offenses for which the person was never arrested.
A dismissal, diversion program, sealed record, expungement, or withheld adjudication does not necessarily eliminate the duty to answer accurately.
Identity or Biographical Inconsistencies
Different names, dates of birth, countries of nationality, marital histories, entries, or family relationships may lead the government to compare records across multiple immigration proceedings.
False Oral Answers During the Interview
A questionable written answer may become more serious if the applicant knowingly repeats it under oath during the naturalization examination.
Conduct During the Good-Moral-Character Period
A conviction entered after naturalization may reveal conduct occurring before the oath. As Jean-Baptiste demonstrates, the date of conduct can matter more than the date of conviction.
Marriage-Based Three-Year Naturalization
An applicant relying on the three-year provision must satisfy the applicable citizenship, residence, physical-presence, and marital-union requirements. Separation, divorce, or evidence that the original marriage was not genuine may create significant issues.
What Happens After Denaturalization?
A denaturalization judgment generally revokes the original naturalization order and cancels the naturalization certificate effective from the original date.
The court may require surrender of the Certificate of Naturalization. U.S. passports and other documents based on the revoked citizenship may also be affected.
Denaturalization does not itself answer every remaining immigration question.
After citizenship is revoked, the person’s immigration position requires a separate analysis. Relevant questions may include:
- Whether the original permanent residence was lawfully obtained;
- Whether any underlying immigration status remains valid;
- Whether a ground of removability applies;
- Whether the person has a waiver or defense;
- Whether a criminal conviction creates removability; and
- Whether DHS initiates removal proceedings.
When the underlying green card was itself unlawfully obtained, the government may pursue removal on that basis. When the naturalization defect was separate from the original permanent residence, the status analysis may be different.
Denaturalization does not necessarily mean immediate deportation. It removes citizenship and may expose the person to immigration enforcement, but removal requires its own legal basis and process.
Can Denaturalization Affect Family Members?
Section 1451(d) contains provisions affecting certain people whose citizenship was acquired through the naturalization of a parent or spouse whose citizenship was later revoked.
The rule does not apply identically in every case. The outcome may depend on:
- How the relative acquired citizenship;
- Whether citizenship arose solely through the revoked naturalization;
- The statutory ground for revocation; and
- Whether the relative independently acquired citizenship through another provision.
A person born in the United States does not automatically lose birthright citizenship because a parent is denaturalized.
Likewise, a person who independently naturalized or independently acquired citizenship should not be treated as having obtained citizenship solely through the revoked naturalization of another person.
Family consequences therefore require an individualized statutory analysis.
How to Prepare a Naturalization Application Safely
A strong N-400 filing begins with a complete review—not optimistic guessing.
Before filing, an applicant should consider obtaining and comparing:
- The immigration file through a FOIA request;
- Copies of prior petitions and applications;
- Visa and consular filings;
- Certified criminal dispositions;
- Criminal complaints and plea agreements;
- Sentencing and probation records;
- Tax transcripts and payment-plan records;
- Child-support and alimony records;
- Selective Service records;
- Passport and travel records;
- Marriage and divorce documents; and
- Evidence explaining prior names or identity differences.
Do not assume a preparer’s mistake is harmless simply because another person completed the form.
The applicant signs the filing and ordinarily confirms the answers under oath. Intent and knowledge remain important, but the safest approach is to identify and correct inaccurate information before naturalization whenever possible.
A person who suspects a problem with the original green-card process should not file Form N-400 merely to “see what happens.”
Naturalization permits USCIS to examine the complete immigration history. A careful review may show that obtaining records, correcting information, addressing a criminal case, pursuing post-conviction relief, or waiting to file is safer.
What to Do if the Government Questions Your Citizenship
Do not ignore communications from USCIS, DHS, DOJ, a U.S. Attorney’s Office, or a federal court.
A complaint, subpoena, interview request, discovery demand, or court order may carry strict deadlines.
Do not:
- Alter records;
- Destroy evidence;
- Backdate documents;
- Recreate missing records inaccurately;
- Contact witnesses to shape their testimony; or
- Send a rushed explanation based only on memory.
Instead:
- Preserve the complete file;
- Obtain prior immigration records;
- Obtain criminal and court records;
- Identify each allegedly false statement;
- Determine the law in effect at naturalization;
- Review the applicable statutory period;
- Separate errors from intentional misrepresentations;
- Analyze materiality;
- Determine whether the person actually was ineligible;
- Review the criminal plea and factual basis;
- Examine procedural and evidentiary defenses; and
- Coordinate immigration, criminal, and federal litigation counsel.
A person remains a U.S. citizen unless and until citizenship is lawfully revoked. An investigation or civil complaint is serious, but it is not a final judgment.
Frequently Asked Questions About Denaturalization
Is Every Naturalized Citizen at Risk?
No.
The government must establish a legally recognized statutory ground. Citizenship lawfully obtained through truthful and complete information is not canceled merely because administrations or enforcement priorities change.
Can USCIS Take Away Citizenship at an Interview?
USCIS may investigate and refer a case, but civil denaturalization of U.S. citizenship ordinarily requires a federal district court proceeding.
Can a Minor Error Cause Denaturalization?
A harmless or innocent mistake ordinarily should not satisfy the statutory requirements by itself.
Intent, willfulness, materiality, actual eligibility, and causation may matter. However, even a seemingly minor discrepancy should be reviewed in context because it could lead investigators to other records.
Can Citizenship Be Revoked Decades Later?
Yes. Civil denaturalization actions generally have no statute of limitations.
Does a Criminal Conviction Automatically Revoke Citizenship?
No.
A conviction after naturalization ordinarily does not automatically revoke citizenship. The government must connect the matter to an authorized ground, such as pre-naturalization ineligibility, concealment, material misrepresentation, or unlawful procurement.
A conviction under 18 U.S.C. § 1425 is different because revocation follows under 8 U.S.C. § 1451(e).
Will Denaturalization Automatically Cause Deportation?
Not automatically.
After citizenship is revoked, DHS must evaluate the person’s immigration status and determine whether a legal ground for removal exists.
Can Family Members Lose Citizenship Too?
Only in specified circumstances involving citizenship obtained through the revoked naturalization of a parent or spouse. Citizenship acquired independently is a different matter.
Conclusion: Denaturalization Enforcement Raises the Stakes
Naturalization remains one of the most important protections available under U.S. immigration law.
Applicants who qualify and completely disclose their histories should not be discouraged from pursuing citizenship merely because denaturalization enforcement has increased.
However, the June 2025 DOJ directive and the coordinated complaints and judgments announced through July 2026 show that old immigration records, later criminal admissions, identity inconsistencies, and alleged fraud are receiving increased federal attention.
The safest approach is careful preparation.
Review the entire immigration history before filing. Obtain certified records. Address inconsistencies before signing under oath. Coordinate criminal and immigration strategy. Never assume that a sealed case, dismissed charge, old application, prior identity, or preparer’s answer cannot become relevant later.
Denaturalization of U.S. citizenship remains a serious judicial remedy—not an ordinary administrative penalty. The government carries a heavy burden, and naturalized citizens retain the right to contest allegations, challenge evidence, present defenses, and seek appellate review.
Citizenship deserves careful protection. Accurate filings, complete records, and timely legal advice can reduce the risk that a naturalization application becomes a denaturalization case years after the oath.
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Disclaimer: This article provides general information about naturalization, denaturalization of U.S. citizenship, civil denaturalization proceedings, criminal naturalization fraud, good moral character, material misrepresentation, false testimony, criminal pleas, and the potential immigration consequences of citizenship revocation. It does not address every naturalization category, statutory ground for revocation, criminal offense, military provision, organizational-affiliation issue, evidentiary defense, derivative-citizenship question, immigration status, removal ground, or federal-court procedure.
Immigration laws, regulations, forms, agency policies, enforcement priorities, and court decisions may change. This information does not constitute legal advice and does not create an attorney-client relationship. Consult a qualified immigration or federal litigation attorney regarding your particular immigration history, criminal record, naturalization application, prior statements, government investigation, or denaturalization proceedings.
Sources and Suggested Further Reading
DOJ Civil Division Enforcement Priorities Memorandum — June 11, 2025
https://www.justice.gov/civil/media/1404046/dl?inline
DOJ Justice Manual § 4-7.200 — Revocation of Naturalization
https://www.justice.gov/jm/jm-4-7000-immigration-litigation
DOJ — Two Denaturalization Judgments and One New Complaint, March 26, 2026
https://www.justice.gov/opa/pr/justice-department-secures-denaturalization-convicted-gun-trafficker-and-health-care
DOJ — Twelve Denaturalization Actions, May 8, 2026
https://www.justice.gov/opa/pr/justice-department-moves-denaturalize-12-individuals-concealing-terrorist-support-war-crimes
DOJ — Seventeen Denaturalization Actions, June 8, 2026
https://www.justice.gov/opa/pr/justice-department-moves-strip-us-citizenship-17-naturalized-sex-offenders-fraudsters-drug
DOJ — Bosnia War-Crimes Denaturalization Judgment, July 17, 2026
https://www.justice.gov/opa/pr/justice-department-complaint-leads-revocation-naturalized-citizenship-bosnia-war-crimes
DOJ — Civil Denaturalization Cases and Statute of Limitations
https://www.justice.gov/archives/opa/pr/department-justice-creates-section-dedicated-denaturalization-cases
USCIS — Form N-400, Application for Naturalization
https://www.uscis.gov/n-400
USCIS Policy Memoranda — August 15, 2025 Good-Moral-Character Memorandum
https://www.uscis.gov/laws-and-policy/policy-memoranda
USCIS Policy Manual — Volume 12, Part F: Good Moral Character
https://www.uscis.gov/policy-manual/volume-12-part-f
USCIS Policy Manual — Volume 12, Part L: Revocation of Naturalization
https://www.uscis.gov/policy-manual/volume-12-part-l
8 U.S.C. § 1427 — General Naturalization Requirements
https://www.law.cornell.edu/uscode/text/8/1427
8 U.S.C. § 1430 — Naturalization for Certain Spouses of U.S. Citizens
https://www.law.cornell.edu/uscode/text/8/1430
8 U.S.C. § 1451 — Revocation of Naturalization
https://www.law.cornell.edu/uscode/text/8/1451
18 U.S.C. § 1425 — Procurement of Citizenship or Naturalization Unlawfully
https://www.law.cornell.edu/uscode/text/18/1425
8 C.F.R. § 340.2 — USCIS Denaturalization Referrals
https://www.law.cornell.edu/cfr/text/8/340.2
Kungys v. United States, 485 U.S. 759 (1988) — Materiality and False Testimony
https://www.law.cornell.edu/supremecourt/text/485/759
Maslenjak v. United States, 582 U.S. 335 (2017) — Criminal Naturalization Fraud and Causation
https://www.law.cornell.edu/supremecourt/text/16-309
Fedorenko v. United States, 449 U.S. 490 (1981) — Illegal Procurement and Statutory Eligibility
https://www.law.cornell.edu/supremecourt/text/449/490
Costello v. United States, 365 U.S. 265 (1961) — Government’s Burden of Proof
https://www.law.cornell.edu/supremecourt/text/365/265
United States v. Jean-Baptiste, 395 F.3d 1190 (11th Cir. 2005)
https://law.justia.com/cases/federal/appellate-courts/F3/395/1190/642607/