denaturalization actions being the most effective remedy.” Conversely, criminal denaturalization prosecution “presents a number of constraints that the government does not face when bringing a civil denaturalization,” including that “the accused has the right to all of the constitutionally guaranteed due process rights…that are not available in a civil denaturalization proceeding.”379 That the civil and criminal statutes operate in parallel also creates problems associated with double jeopardy, deportation, and the ability to appeal. The government has capitalized on this, urging prosecutors to try defendants civilly if the criminal prosecution either failed or was declined for prosecution. The same DOJ bulletin states: Because of the advantages of a civil denaturalization…prosecutors should strongly consider referring any declination for [criminal denaturalization] for consideration as a civil denaturalization action. In particular, prosecutions declined based on the ten-year statute of limitations are often viable in civil proceedings. Moreover, pursuing civil denaturalization actions may be appropriate when a criminal denaturalization action results in an acquittal, as the causes of action between the two suits are not identical.380 Of the 168 cases analyzed for this report, criminal denaturalizations outnumbered civil denaturalizations nearly three to one. While pursuing civil denaturalization presents more latitude for government prosecutors, a criminal conviction remains on one’s record and can serve as a permanent bar to entering the United States following removal. The conviction may also preclude a person from re-naturalizing. A civil judgment carries no other consequences, beyond denaturalization (legally understood as an administrative measure to remove an improperly obtained immigration benefit). Reverting to permanent residency status without a criminal conviction allows a person to remain in the U.S. and potentially to re-naturalize should the facts of their case not preclude it. Deportation and ability to appeal. Conviction under the criminal denaturalization statute results in automatic denaturalization. Upon conviction, the newly unmade citizen is susceptible to deportation. Additionally, a district or magistrate judge can issue a Judicial Removal Order (JRO), which orders the expedited removal of the defendant from the United States, bypassing the immigration system and circumventing the individual’s opportunity to raise defenses to removal before an immigration judge. As of May 2019, JROs had already been issued in 13 closed cases reviewed for this report. In Logan v. Zimmerman Brush Co. (1982), the Supreme Court held that while “access to the courts is an entitlement, deprivation of that access may violate due process.” Courts have recognized the substantial difficulties faced by a person appealing their case from abroad, noting the “difficulties of pursuing an effective appeal while abroad,”381 and recognizing that 88 UNMAKING AMERICANS