denaturalization program directed principally against naturalized Germans who were affiliated with the German-American Bund (a pro-Nazi organization).”256 The experiences of these cases inspired Congress to change the language of the denaturalization statute to introduce a burden on the government to prove willful and material fraud.257 The Senate Judiciary Committee believed “concealment of material fact or willful misrepresentation is more easily proved” and the insertion of this language would eliminate conflicting interpretations of fraud in denaturalization cases.258 The passage of this provision was the most significant action Congress had taken on denaturalization since the 1940s. It is important to note this moment in the history of the denaturalization statutes as one instance in which Congress was inspired to rein in overzealous application of denaturalization for political reasons. The 1952 Act maintained the racial quota system of the 1924 National Origins Act. Most political and public debate around the 1952 Act centered on its use of racial quotas. However, the act’s retention of denaturalization was also controversial, with much of the American public and President Harry Truman opposed this provision. Congress passed the 1952 Act only after overriding his veto. Among his objections to the act was his strong opposition to the concept of denaturalization.259 The concerns of opponents of denaturalization would later be somewhat assuaged by a series of important Supreme Court cases in the 1950s and 60s, which introduced strict limits on involuntary expatriation and denaturalization (as explored in Chapter I, History and Context). War Crime Denaturalization – The Department of Justice Office of Special Investigations For a period of roughly 50 years following the end of World War II, very few denaturalization prosecutions occurred. However, a small unit within the U.S. Department of Justice was active during this period, prosecuting denaturalization cases against Nazi war criminals. These prosecutions were carried out under the civil statute, as the criminal statute’s time limitations had expired. The Office of Special Investigations (OSI) was established in 1979 within the Department of Justice’s Criminal Division, specifically to conduct this work.260 The purpose of OSI, as described by its champion and chief architect, Congresswoman Elizabeth Holtzman, was to be “an effective Nazi-fighting unit.”261 According to one account, “It could not bring Nazis to trial for the crimes they had committed elsewhere or seek prison sentences for them. But it could expose the lies they had told about their past when they had entered the country, leading to their loss of citizenship and deportation—in the best scenario, to countries that could then put them on trial.”262 Historical records of OSI’s prosecutions bear no resemblance to the average denaturalization case reviewed for this report. A 600-page report painstakingly examining OSI’s record, dated II. Denaturalization: A Radical Measure in the Hands of Zealots 63

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