must be weighed against the harshness of the penalty—that is, it must be proportional. In
Graham v. Florida (2010), the court declared that “[t]he concept of proportionality is central to
the Eighth Amendment.”388
Yet, as noted above regarding the creation of statelessness through denaturalization, there is no
space for a proportionality analysis under either civil or criminal denaturalization statutes, and
no indication that the government is engaging in such an analysis prior to initiating proceedings.
DENATURALIZATION THROUGH OPERATION SECOND LOOK
Zarrin Hoque came to the U.S. from Bangladesh in the early 1990s. Desperate for work,
Hoque was introduced to a broker who promised she would help Hoque secure a work
permit that would allow her to make a living in the U.S. In the meantime, in 1995, Hoque
won the Diversity Visa lottery, through which she naturalized. According to Hoque, the
broker obtained work authorization for her in a different name, Munia Parvin. Hoque did
not disclose this fact prior to naturalizing. Hoque owns a market with her husband and as
she noted, “after being in this country for more than 20 years and spending the better part
of my life, I consider the USA as my country. I took the oath and believe in this great nation.
This is the only country I practically known today.”389 Hoque was denaturalized in December
2017 as a part of Operation Second Look and her whereabouts are currently unknown.
90
UNMAKING AMERICANS
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