• The number of Americans with derivative citizenship denaturalized due to their sponsor’s denaturalization. Legislative reforms. Enact reforms to address the harms identified in this report, including: Adopt legislation prohibiting denaturalization where it would result in statelessness. Amend the civil denaturalization statute (8 U.S.C. § 1451) as follows: • Add a statute of limitations. • Provide for a Sixth Amendment right to counsel in all civil denaturalization proceedings. • Codify the heightened evidentiary standard of “clear, unequivocal and convincing,” and require the government to prove intentional fraud in all civil cases. • Institute measures (including a heightened personal notice requirement) to ensure no denaturalization takes place in absentia. • Eliminate civil denaturalization based on membership in particular groups, because of its obvious clash with First Amendment rights and equal protection of the law. • Eliminate “refusal to testify” as a ground for civil denaturalization. Prohibit removal following trial court proceedings until all appeals are exhausted. Invalidate immigration waivers, including judicial removal orders and waivers that relinquish asylum and other protection claims, in negotiated settlements. Eliminate derivative denaturalization (8 U.S.C. § 1451(d)), so that the extreme negative consequences of denaturalization are restricted to the individual case. Eliminate “good moral character” and “attachment to the U.S. Constitution” as grounds for denaturalization. Amend the Immigration and Nationality Act to prohibit administrative denaturalization. Documentation of Citizenship Legislative reforms. Enact reforms to address inequality and discrimination in access to U.S. passports, including: Establish a right to counsel in challenges to executive decisions that deny rights or benefits on the ground that the claimant is not a U.S. citizen. Executive Summary 15