376. See United States v. Carolene Products Co., 304 U.S. 144 (1938) (footnote 4). Motion in Limine Improper Jury Nullification Arguments by USA 1-2 (Oct. 24, 2018). 377. See Cassandra Burke Robertson and Irina D. Manta., (Un)Civil Denaturalization, 94 New York University Law Review 402, passim (2019), https://www.nyulawreview. org/wp-content/uploads/2019/06/NYULawReview-94-3-RobertsonMantapdf.pdf; Comment, Denaturalization of Nazi War Criminals: Is There Sufficient Justice for Those Who Would Not Dispense Justice?, 40 Md. L. Rec. 39 (1981) (“Whether denaturalization is considered a civil proceeding, a criminal proceeding, or something in between is a determination crucial to arriving at a formula of due process which will pass fifth amendment tests.”); Abbe L. Dienstag, Comment: Fedorenko v. United States: War Crimes, the Defense of Duress, and American Nationality Law, 82 Columbia L. Rev. 120, 121 (1982) (“[T]he Supreme Court erred in its superficial approach to a case fraught with profound and perplexing issues of moral and legal significance.”). 388. Graham v. Florida, 130. S. Ct. 2011, 2021 (2010). 378. See, e.g., Comment, Denaturalization of Nazi War Criminals: Is There Sufficient Justice for Those Who Would Not Dispense Justice?, 40 Md. L. Rec. 39 (1981). 379. Anthony D. Bianco, Paul Bullis & Troy Liggett, Civil Denaturalization: Safeguarding the Integrity of U.S. Citizenship, in 65 U.S. Attorneys’ Bulletin (July 2017), at 8, https://www.justice.gov/usao/page/file/984701/ download. 380. United States Department of Justice, Executive Office for U.S. Attorneys, Civil Immigration Enforcement and the Office of Immigration Litigation-District Court Section, in 65 U.S. Attorneys’ Bulletin (July 2017), at 3, 9, https://www.justice.gov/usao/page/file/984701/ download. 389. United State v. Parvin, 8:17-cr-00269, Def. Statement, at para. 8 (Dec. 12, 2017). 390. United States v. Gaudin, 515 U.S. 506, 509-510 (1995). 391. Schneiderman v. United States, 320 U.S. 118, 125, 135 (1943). 392. Klapprott v. United States, 335 U.S. 601, 612 (1949). 393. See, e.g., United States of America v. Singh, 2:17-cv07214 (Doc. 9), Opinion 11 (Jan. 5, 2018). (“Since the Government has demonstrated, through clear and convincing evidence, that all four denaturalization requirements…are satisfied, this Court will grant its motion for summary judgment and enter an order to revoke Defendant’s naturalization and cancel his certificate of naturalization.”) (emphasis added). 394. Cornell Law School, Legal Information Institute (LII), Clear and Convincing Evidence, https://www.law. cornell.edu/wex/clear_and_convincing_evidence. 395. Timothy M. Belsan, Danielle K. Schuessler & Sebastian Kielmanovich, OIL-DCS Availability for Assistance and Support in Denaturalization Prosecutions under 18 U.S.C. § 1425, in 65 U.S. Attorneys’ Bulletin (July 2017), at 33, https://www.justice.gov/usao/page/ file/984701/download. 381. Thapa v. Gonzales, 460 F.3d 323, 331 (2d Cir. 2006). 396. U.S. Immigration and Customs Enforcement (ICE), Office of Investigations, Denaturalization Investigations Handbook, OI HB 08-01, Jan. 15, 2008, https://www. unicornriot.ninja/wp-content/uploads/2018/02/ Denaturalization-full-hsi.pdf. 382. Dorelien v. U.S. Atty. Gen., 317 F.3d 1314, 1325 (11th Cir. 2003). 397. United States v. One Assortment of 89 Firearms, 465 U.S. 354 (1984). 383. Brief for the Immigrant Defense Project as Amicus Curiae Supporting Respondent in removal proceedings (redacted date and matter), https://www.immigrantdefenseproject.org/wp-content/uploads/IDP-Amicus-Brief-on-Finality-Redacted.pdf. 398. United States v. Halper, 490 U.S. 435 (1989) (regarding a False Claims Act action and overwhelmingly disproportionate in compensating the government for its loss). 384. Id. 385. Pino v. Landon, 349 U.S. 901, 901 (1955); Matter of Ozkok, 19 I. & N. Dec. at 552 n.7; see also Brief for the Immigrant Defense Project as Amicus Curiae Supporting Respondent in removal proceedings (redacted date and matter), https://www.immigrantdefenseproject.org/ wp-content/uploads/2016/09/IDP-Amicus-Brief-on-Finality-with-Exhibits.pdf. 386. Knauer v. United States, 328 U.S. 654, 659 (1946) 387. E.g., USA v. Anderson, 0:18-cr-60252 (Doc. 26), Endnotes 399. One Lot Emerald Cut Stones v. United States, 409 U.S. 232 (1972). 400. In Gideon v. Wainwright (1963), the U.S. Supreme Court recognized the disadvantage faced by unrepresented defendants in civil cases, observing that: “reason and reflection require us to recognize that in our adversary system of criminal justice, any person haled into court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is provided for him. This seems to us to be an obvious truth…That government hires lawyers to prosecute and defendants who have the money hire lawyers to defend are the strongest indications of the widespread belief that lawyers in criminal courts are necessities, not luxuries... From the very beginning, our 179