Biometric Transactions / Year (millions) Possessed of a massive database with massive capabilities, the current administration—and any subsequent administration—could abuse this powerful tool to investigate the activities and relationships of virtually anyone it chooses to target. The “good moral character” and “attachment” requirements for naturalization (and denaturalization), leave considerable flexibility for citizenship stripping based on alleged “subversive” activities.467 As scholar Patrick Weil has shown regarding the attachment cases of the 20th century: denaturalization cases could use potential “fraud or illegality committed before” naturalization, as a means to punish people for something “they had done after they obtained American citizenship.”468 Given the increased likelihood of false positives for people with darker skin tones, and overrepresentation of minority populations in the data, denaturalization cases alleging involvement in criminal activity and relying on such data could also proliferate, disproportionately affecting people of color. To date, courts have not been amenable to the introduction of rebuttal evidence that demonstrates these complex technical flaws and interrogates their potential impact on an individual case. It is critical that the U.S. government comes to grips with the racial and gender disparities associated with these new technologies. 200 DHS Biometrics Systems - From IDENT to HART 180 Growth of Biometrics in DHS 160 140 120 100 80 60 Historical 40 Projected 20 0 FY10 FY11 FY12 FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 FY22 IDENT Gallery Size – 220m Unique Identities Office of Biometric Identity Management (OBIM) Slide from “DHS Identity Applications for Homeland Security Slide Presentation-9/12/17,” available at: https://www.eff.org/document/dhs-identity-applications-homeland-security-slide-presentation-91217 II. Denaturalization: A Radical Measure in the Hands of Zealots 105