191. Form N-400, Application for Naturalization 14 (2016), https://www.uscis.gov/n-400 (emphasis in original). The provision does not qualify whether the crime to be reported is a crime under U.S. law, or a crime under any jurisdiction, which would implicate, for example, laws against political speech or gender-bias laws. The question also does not account for cultural differences and customs under which something not considered illegal in a foreign jurisdiction might be considered criminal in the United States—for example, polygamy or legal drinking age. 192. United States v. Oribello Eguilos, 2019 WL 1643234, at *1 (E.D. Cal. Apr. 16, 2019) (internal citations omitted). 193. Cong. Red. Vol. 107, pt. 4, at 18283 (1961). 194. 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 (citing INA § 340(a)). 195. 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 (citing INA § 340(a)). 196. See 8 U.S.C. § 1429. 197. See 8 U.S.C. § 1429. 198. See ILRC, at 5 (citing U.S. v. Kaur, 2014 WL 285077 (E.D. Pa. 2014) (revoking naturalization where the court concluded that derivative asylum status and adjustment were not lawfully obtained for a derivative asylee when principal’s asylum grant was not valid); Turfah v. USCIS, 845 F.3d 668 (6th Cir. 2017) (not permitting citizenship where individual received his legal permanent resident status by mistake by the government, even though the individual did not commit any fraud in obtaining his status)). 199. 12 USCIS Policy Manual L.3, Continuous Residence, https://www.uscis.gov/policy-manual/volume-12-part-dchapter-3. 200. USCIS, Continuous Residence and Physical Presence Requirements for Naturalization (Apr. 17, 2019), https://www. uscis.gov/us-citizenship/citizenship-through-naturalization/continuous-residence-and-physical-presence-requirements-naturalization. 201. There are some exceptions to the physical presence requirement, such as for those applicants working abroad for the U.S. government. See Section 316 paragraphs (b), (c), and (f ). 202. See INA § 101(f ). 203. Immigration and Nationality Act, 8 U.S.C. §1101(f )(1) (1952), https://www.law.cornell.edu/uscode/text/8/1101. 204. Catholic Legal Immigration Network, Immigration Law & The Criminal Client, Chapter 4 Good Moral Character, at 2, https://cliniclegal.org/sites/default/files/cerra/March-16- Endnotes Workshops/Good-Moral-Character-and-Naturalization/ Good-Moral-Character-Chapter-CLINIC-Crimes-Manual. pdf. 205. Id. at 3. 206. See INA § 101(a)(43). See Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA), Pub. L. 104-208, 110 Stat. 3009-546 (September 30, 1996). 207. INA § 101(a)(43)(P). 208. INA § 101(a)(43)(T). 209. 12 USCIS, Policy Manual, Part F, Good Moral Character, Chapter 5 – Conditional Bars for Acts in Statutory Period (June 6, 2019), https://www.uscis.gov/policy-manual/ volume-12-part-f-chapter-5#footnotelink-5. 210. USCIS summarizes that “[w]hether an offense is a CIMT is largely based on whether the offense involves willful conduct that is morally reprehensible and intrinsically wrong, the essence of which is a reckless, evil or malicious intent.” Id. 211. See USCIS, Policy Alert (Apr. 19, 2019), https://www. uscis.gov/sites/default/files/policymanual/updates/20190419-ControlledSubstanceViolations.pdf. 212. USCIS, supra note 210. 213. See INA § 316(a); 8 CFR 316.11. 214. 12 USCIS, Policy Manual Part D, General Naturalization Requirements, Chapter 7 - Attachment to the Constitution, (June 6, 2019), available at https://www.uscis.gov/ policy-manual/volume-12-part-d-chapter-7. See generally Aram A. Gavoor and Daniel Miktus, Snap: How the Moral Elasticity of the Denaturalization Statute Goes Too Far, 23 Wm. & Mary Bill Rts. J. 637, 640 (2015) (calling for elimination of attachment requirement as unconstitutional). 215. 12 USCIS, Policy Manual Part D, General Naturalization Requirements, Chapter 7 - Attachment to the Constitution (June 6, 2019), https://www.uscis.gov/policy-manual/ volume-12-part-d-chapter-7. 216. Id. 217. Comment, Denaturalization of Nazi War Criminals: Is There Sufficient Justice for Those Who Would Not Dispense Justice, 40 Md. L. Rev. 39, 54-55 (1981). 218. See Fedorenko v. United States, 1010 S. Ct. 737 (1981); Comment, Denaturalization of Nazi War Criminals: Is There Sufficient Justice for Those Who Would Not Dispense Justice, 40 Md. L. Rev. 39, 85 (1981) (“In the 1952 version of the [Immigration and Naturalization] Act, Congress deleted the ground of illegal procurement, thereby placing a uniform requirement that the Government must prove intent to be triumphant in a denaturalization case. In apparent reaction to the Court’s imposition of a heavy burden of proof, Congress in 1961 once again included the ground of illegal 171