the government’s consistent use of the name Enite Alindor, Ms. Dureland persisted that she was not known as Enite and signed all court documents as Odette Dureland. Ms. Dureland was eventually convicted and sentenced under the name Enite Alindor. The Justice Initiative reviewed other cases in which defendants continued to sign documents and refer to themselves with a name different from the one the government was alleging, including at the time of plea agreement. Impact of detention and bail procedures. Whether the government brings a denaturalization proceeding civilly or criminally will determine whether one is at risk of infringements on their movement. Unlike those facing civil action, those charged criminally may be arrested, detained, and have restrictions placed on their movement, including house arrest, electronic monitoring, limits on travel, and curfews. Despite the presumption of innocence, in all criminal denaturalization cases reviewed for this report, individuals were under some form of detainment.414 For those subject to bond, the amounts ranged from $5,000 to $250,000. For those who were able to post the bail amount—often in these cases by placing the family or a family member’s home up as collateral—the defendant was required to comply with conditions of release. Nearly all required restrictions on movement, including surrendering travel documents to the government, agreeing not to leave the district, GPS or ankle monitoring, curfews, and house arrest. Generally, individuals left in jail are more likely to be convicted. Studies have shown that conviction rates vary significantly depending on whether one is in jail awaiting the outcome of their case (non-felony 92%; felony 85%) as compared to those who are not (non-felony 50%; felony 59%).415 Often these convictions are a result of plea agreements, which even innocent people may be willing to sign due to jail conditions or other compelling reasons. No Statute of Limitations A statute of limitations dictates the amount of time within which a legal proceeding must begin. The purpose behind the statute is to spare a defendant the burden of defending against stale allegations “after memories may have faded or evidence is lost.”416 As recently as 2017, the Supreme Court affirmed the importance of statutes of limitations, holding “Such limits are ‘vital to the welfare of society’ and rest on the principle that ‘even wrongdoers are entitled to assume that their sins may be forgotten.’”417 As noted above, the government has 10 years to bring a criminal denaturalization charge,418 and essentially forever to file a civil denaturalization action. In the criminal context, the clock does not need to run from the moment of the initial act that prompted the charge, but can 94 UNMAKING AMERICANS