WASHINGTON — The U.S. Department of Justice announced Oct. 5 that it had filed civil lawsuits seeking to revoke the citizenship of 40 naturalized Americans, marking what the department described as its largest number of denaturalization complaints filed during a single period under President Donald Trump’s administration.
The complaints, filed between Aug. 21 and Oct. 2 in federal courts across the country, accuse individuals of concealing criminal activity, misrepresenting their identities or providing false information during immigration and naturalization proceedings.
According to the Justice Department, the cases involve individuals previously convicted of crimes including espionage-related offenses, sexual abuse, fraud and other serious criminal conduct. Federal prosecutors allege that the defendants withheld information that could have affected their eligibility for U.S. citizenship.
However, filing a civil denaturalization complaint does not automatically revoke citizenship. The government must establish that an individual’s naturalization was unlawfully obtained, and the allegations in the newly-filed cases remain subject to judicial review.
The latest actions follow a June 11, 2025, memorandum issued by Assistant Attorney General Brett A. Shumate directing the Justice Department’s Civil Division to prioritize denaturalization proceedings.
The memorandum instructed federal attorneys to pursue denaturalization cases aggressively when supported by evidence and permitted under federal law.
The directive identified several enforcement priorities, including national security threats, terrorism, war crimes, gang activity, violent crimes, financial fraud and material misrepresentations during the naturalization process.
Although the memorandum identified specific categories, it stated that the priorities were not exhaustive and did not restrict the Civil Division’s authority to pursue additional cases.
The resulting enforcement initiative reflects an effort to expand the use of civil litigation to revoke citizenship allegedly obtained through unlawful means.
Under 8 U.S.C. § 1451(a), the federal government may bring civil proceedings to revoke citizenship if naturalization was illegally procured or obtained through concealment of material facts or willful misrepresentation.
The relationship between criminal conduct and unlawful naturalization is central to these proceedings. A criminal conviction alone does not necessarily establish that an individual obtained citizenship illegally.
Instead, the government must demonstrate a legally sufficient basis for revocation related to the individual’s eligibility for naturalization.
Among the cases filed in California is United States v. Norma Patricia Esparza, a civil denaturalization action filed Sept. 22 in the U.S. District Court for the Central District of California.
According to the Justice Department, Esparza was convicted of voluntary manslaughter after becoming a naturalized citizen, although the underlying criminal conduct allegedly occurred before her naturalization.
Federal prosecutors contend that Esparza failed to disclose information about her criminal conduct during the naturalization process and consequently obtained citizenship despite allegedly lacking the legally required good moral character.
Court records show that the government filed a denaturalization complaint accompanied by documents including Esparza’s naturalization application, naturalization certificate and records from the underlying criminal proceedings.
The case was assigned to U.S. District Judge David O. Carter. Court records also identify attorneys Shuting Chen and Lorena Cecilia Castillo Carrillo as representing Esparza.
According to the publicly available docket, Esparza’s response to the government’s complaint is due Nov. 23.
The legal framework governing these proceedings places substantial evidentiary burdens on the government.
In the 2017 Supreme Court decision Maslenjak v. United States, the court held that unlawful conduct must have a meaningful connection to the acquisition of citizenship to support a conviction for unlawful procurement of naturalization under the criminal statute at issue.
The court rejected the proposition that any false statement made during the naturalization process could support a conviction, regardless of whether that statement affected the citizenship determination.
Although Maslenjak involved a criminal prosecution rather than a civil denaturalization complaint, the decision provides guidance concerning the relationship between misconduct, material misrepresentations and the acquisition of citizenship.
The Supreme Court also addressed the importance of material misrepresentations in the 1988 decision Kungys v. United States, which concerned civil denaturalization proceedings.
In that case, the court examined whether false statements made during the naturalization process were material to the government’s citizenship determination, establishing important guidance for evaluating alleged misrepresentations.
The Justice Department has defended its expanded initiative as necessary to protect the integrity of the naturalization system and prevent individuals who allegedly obtained citizenship through deception from retaining that status.
The legal standards governing denaturalization also reflect the significant consequences of revoking citizenship after it has already been granted.
The October announcement follows several earlier enforcement actions in 2026, including groups of 12, 17 and 10 denaturalization cases announced by the Justice Department.
Together, these announcements demonstrate that the administration’s denaturalization initiative has developed into an ongoing federal litigation strategy rather than a series of isolated cases.
As the proceedings move through federal courts, judges will determine whether the government’s evidence satisfies the legal requirements for revoking citizenship.
For the 40 individuals named in the latest complaints, the government’s allegations mark the beginning of that process. Whether their citizenship can legally be revoked will depend on the facts established in each case and the application of federal naturalization law.
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