In a civil case reviewed, a 64-year-old asylum seeker from Haiti signed a plea agreement in a July 2011 criminal denaturalization case. This agreement stipulated that the government would dismiss the denaturalization charge in return for the defendant’s pleading guilty to two lesser charges of making a false statement in an application for a passport and identity theft. The government subsequently waited seven years to initiate a civil denaturalization proceeding against him. While the case records state that the defendant was served with notice, he never appeared before the court, nor answered the complaint, and was denaturalized in absentia based on the government’s motion for a judgment on the pleadings. Under the Double Jeopardy Clause, only sanctions considered as “punishment” usually qualify to preempt re-litigating the issue. However, the Supreme Court has held that “the prohibition on double jeopardy extends to civil sanctions which are applied in a manner that is punitive in nature,”397 and “a civil sanction qualifies as punishment if the sanction is overwhelmingly disproportionate and if the disproportionate award can be explained only as a deterrent or as having a retributive purpose.”398 Furthermore, “Congress may impose both a criminal and a civil sanction in respect to the same act or omission, for the Double Jeopardy Clause prohibits merely punishing twice, or attempting a second time to punish criminally, for the same offense.”399 Although the Supreme Court’s logic would seem to prevent the sequential deployment of criminal and civil denaturalizations procedures, this does not appear to have stopped exactly that use. Sixth Amendment: Right to Counsel The Sixth Amendment of the U.S. Constitution guarantees criminal defendants the right to be represented by legal counsel, including at no expense to the defendant should they be unable to afford an attorney.400 However, there is no corresponding federal constitutional right in civil cases.401 In denaturalization cases, despite the same potential consequence facing defendants—citizenship revocation—there is no right to counsel in civil cases. Due to an inability to afford an attorney, many people facing civil denaturalization charges are forced to go it alone against the full force of the U.S. government. In the civil cases reviewed for this report, over 25% of civil defendants were unrepresented. Pro se defendants often faced three or more experienced government attorneys. In several civil cases reviewed for this report, attorneys for those threatened with denaturalization did not enter an appearance in the case until late in the proceedings, often only days prior to a settlement with the government. Without access to legal counsel, individuals are likely unaware of their legal rights and possible defenses and claims. Representation by a lawyer can have a profound material impact on an individual’s case.402 According to a meta-analysis of studies reviewing the effects of representation on adjudicated 92 UNMAKING AMERICANS