com/news/av/world-us-canada-37230916/drug-dealerscriminals-rapists-what-trump-thinks-of-mexicans. 165. Stef W. Kight, Report: Trump said Haitian Immigrants “All Have AIDS,” Axios (Dec. 23, 2017), https://www.axios. com/report-trump-said-haitian-immigrants-all-haveaids-1515110820-4d6f7da4-ca7a-4e01-93297f25b49e709c.html. 166. Alex Daugherty, Trump called Haiti a ‘sh--hole’ campaigning in Miami in 2016, Woodward’s book says, Miami Herald (Sept. 11, 2018), https://www.miamiherald. com/news/politics-government/article218202540.html. 167. Michael D. Shear & Julie Hirschfeld Davis, Stoking Fears, Trump Defied Bureaucracy to Advance Immigration Agenda, N.Y Times, Dec. 23 2017, https://www.nytimes. com/2017/12/23/us/politics/trump-immigration.html. 168. Current as of May 2019. 169. Eleven (11) cases were closed or dismissed. 170. In 72 cases against naturalized U.S. citizens, the case was resolved against them. At the time of review, one denaturalization was on hold pending appeal, and in a handful of cases revocation had not yet been ordered. 171. These figures cover only those cases for which the Justice Initiative was able to accurately identify the relevant information from the case materials obtained. Median age was 51 years old, mode of 50, and age range between 24-72 years old (N = 144); median naturalization date was 9-10 years, with a mode of 11 years (N = 131). 172. Bond amounts were calculated based on 60 criminal cases in which bail was ordered. 173. Press Release, Bernadette Rabuy & Daniel Kopf, Detaining the Poor: How Money Bail Perpetuates an Endless Cycle of Poverty and Jail Time, Prison Policy Initiative (May 10, 2016), https://www.prisonpolicy.org/reports/ incomejails.html. 174. Very few case files mentioned Operation Janus or Operation Second Look. Cases in which a fingerprint analysis or failure to disclose a prior removal were mentioned as evidence against the defendant were coded as Operation Janus/Operation Second Look cases. This is likely a conservative estimate. “Fraudulent documents” cases and “immigration issue” cases may also be Operation Janus/Operation Second Look cases, though fingerprinting or a prior removal order were not mentioned. Cases coded as “immigration issue” include allegations such as not disclosing an alias. “Fraudulent document” cases cover, for example, allegations that the defendant used another person’s passport or an alias to procure a document used to enter the U.S., or to apply for a benefit. The Justice Initiative does not have disaggregated data on case types in pre-2017 cases. 175. See Chapter IV, Political Attacks on Citizenship by Birth 170 in the United States. 176. See Immigration Direct, How Difficult is it to Become a US Citizen, https://www.uscitizenship.info/articles/ how-difficult-is-it-to-become-a-us-citizen/ 177. Citizenship acquired by naturalization or by birth may be voluntarily relinquished. 178. Comment, Denaturalization of Nazi War Criminals: Is There Sufficient Justice for Those Who Would Not Dispense Justice, 40 Md. L. Rev. 39, 46-47 (1981). 179. See Gorbach v. Reno, 219 F.3d 1087, 1094 (9th Cir. 2000) (USCIS is permanently enjoined from revoking citizenship status); see also Immigrant Legal Resource Center (ILRC), Practice Advisory: Denaturalization (December 2018), at 9 (“Administrative Denaturalization Enjoined”). 180. Nikki Marquez & Eric Cohen, Denaturalization – Understanding the Process and Recent Increases in Denaturalization Efforts, ILRC (Dec. 2018), https://www.ilrc.org/ sites/default/files/resources/denaturalization_und_prcs_ rcnt_effrts-20181221.pdf. 181. In December 2018, the Justice Initiative requested this specific information through a Freedom of Information Act request, but had not received responsive information at the time of publication. 182. 8 U.S.C. § 1451(a); INA § 340(a). 183. 8 U.S.C. § 1451(e), referencing 18 U.S.C. § 1425. 184. 8 U.S.C. § 1440(c); INA § 329(c). 185. 8 U.S.C. § 1451(a); INA § 340(a). 186. Nikki Marquez & Eric Cohen, Denaturalization – Understanding the Process and Recent Increases in Denaturalization Efforts, ILRC, at 3 (Dec. 2018), https://www.ilrc.org/ sites/default/files/resources/denaturalization_und_prcs_ rcnt_effrts-20181221.pdf. 187. 12 USCIS Policy Manual L.2 § (B)(1), Grounds for Revocation, https://www.uscis.gov/policy-manual/ volume-12-part-l-chapter-2 (emphasis added); 8 U.S.C. § 1451(a). Concealments or misrepresentations can be made orally, for instance, during the naturalization interview, or written in the naturalization application. USCIS also considers omissions to constitute concealments or misrepresentations. 12 USCIS Policy Manual L.2 § (B)(1), Grounds for Revocation, available at https://www.uscis. gov/policy-manual/volume-12-part-l-chapter-2. 188. Kungys v. United States, 485 U.S. 759, 760 (1988). 189. Id. at 761. 190. 12 USCIS Policy Manual L.2 § (B)(1), Grounds for Revocation, https://www.uscis.gov/policy-manual/ volume-12-part-l-chapter-2. UNMAKING AMERICANS