Grounds for Denaturalization I. Civil Denaturalization A. Concealment of a material fact or by willful misrepresentation II. Criminal Denaturalization III. Other Than Honorable Military Discharge IV. Refusal to Testify B. Illegally procured citizenship 1. Residence 2. Physical Presence 3. Lawful Permanent Residence 4. Moral Character 5. Attachment to the U.S. Constitution Civil and criminal denaturalization cases are explored in more detail below. All denaturalization cases identified and analyzed for this report fell into these two categories. However, there are two additional forms of denaturalization that are relatively rare and not addressed in this report: Other Than Honorable (OTH) Military Discharge. Naturalization can be acquired through active-duty service in the U.S. Armed Forces during periods of military hostilities. Citizenship acquired this way may be revoked if the individual “is separated from the Armed Forces under other than honorable conditions before the person has served honorably for a period or periods aggregating five years.”184 Refusal to Testify. The “refusal on the part of a naturalized citizen within a period of ten years following his naturalization to testify as a witness in any proceeding before a congressional committee concerning his subversive activities” is grounds for denaturalization.185 This is considered a “remnant of the Cold War” but continues to be valid law.186 II. Denaturalization: A Radical Measure in the Hands of Zealots 51