In practice, naturalized citizens are vulnerable even if the standards as envisioned by the Supreme Court apply, for two chief reasons. First, the application form for naturalization covers a voluminous amount of information, including whether the applicant has “EVER committed...a crime or offense for which you were NOT arrested.”191 A United States District Court, in its ruling in United States v. Oribello Eguilos, examined this complexity, and the uncertainty it presents for naturalization applicants: [The question] sets a trap for the unwary applicant. Given the thousands of possible offenses an individual can commit each day, no applicant can answer this question truthfully without jeopardizing their entire application and risking self-incrimination. Nevertheless, a false answer gives the government nearly limitless leverage over the naturalized individual’s citizenship. As the aforementioned question is often repeated during an individual’s citizenship interview, the government can argue that such false testimony means that the individual never possessed the requisite good moral character for citizenship. Or the government can simply claim that an untruthful answer caused the individual’s naturalization to be illegally procured by concealment or willful misrepresentation.”192 Second, and related, the requirements for naturalization cover discretionary determinations like “good moral character.” It is one thing to predict how newly discovered information might impact the answer to a purely objective fact, like whether a person was continuously present in the country; on the other hand, to predict the outcome of a discretionary determination that has no uniform application invites arbitrariness. Illegally Procured Citizenship Citizenship may also be revoked through a civil action if naturalization was procured “illegally.” Illegally in this case means that the individual was not eligible to be naturalized. The provision was inserted into § 1451 in 1961, without a debate.193 There are five requirements that must be met in order to procure citizenship legally (in other words, to naturalize): (1) residence, (2) physical presence, (3) lawful admission for permanent residence, (4) good moral character, and (5) attachment to the U.S. Constitution.194 According to USCIS, there is no intent requirement: “This applies even if the person is innocent of any willful deception or misrepresentation.”195 These five requirements are explored more fully below. 1. Lawful permanent residence. To be eligible for naturalization, an individual must have been lawfully admitted for permanent residence.196 No person can naturalize if there is a final order of deportability or pending removal proceedings against the individual.197 If lawful permanent residence was obtained in error, the subsequent naturalization may be challenged under this statute, even if the error is entirely innocent.198 For example, an II. Denaturalization: A Radical Measure in the Hands of Zealots 53