The Citizenship Clause of the Fourteenth Amendment states, “All persons born or naturalized in the United States…are citizens…” The Constitution draws only one distinction between the two categories of U.S. citizen: only citizens by birth may run for the offices of president and vice president.370 The Supreme Court has affirmed this as the only difference, holding that naturalized citizens “possess…all the rights of a native citizen, and standing, in the view of the constitution, on the footing of a native.”371 Yet the U.S. retains the denaturalization statutes, and voices opposed to those statutes, arguing that denaturalization is an unconstitutional scheme of second-class citizenship, have yet to command a majority.372 In one of a series of denaturalization cases heard by the Supreme Court in the 1940s, for example, Justices Wiley B. Rutledge and Frank Murphy expressed their concern with the use of denaturalization. They wrote, “No such procedures could strip a naturalborn [sic] citizen of his birthright or lay him open to such a penalty… the Constitution does not countenance either that deprivation or the ensuing liability to such a punishment for naturalized citizens.”373 In another case during this era, involving a member of the German Nazi party who had naturalized as an American, Justice Rutledge wrote: My concern is not for Paul Knauer. The record discloses that he has no conception of, much less attachment to, basic American principles or institutions. He was a thorough-going Nazi, addicted to philosophies altogether hostile to the democratic framework in which we believe and live. But if one man’s citizenship can thus be taken away, so can that of any other…Not merely Knauer’s rights, but those of millions of naturalized citizens in their status and all that it implies of security and freedom, are affected by what is done in this case. By the outcome they are made either second-class citizens or citizens having equal rights and equal security with others.374 Over 70 years later, the same concern persists. In a 2019 denaturalization case before U.S. District Judge William B. Shubb, he wrote: This court must once again dispel the commonly held misconception that all American citizens are afforded the same rights of citizenship. Through the denaturalization process, Congress has created two distinct classes of American citizens. …The government can always initiate proceedings to revoke a naturalized individual’s citizenship if it believes that the naturalization was illegally procured or procured by concealment of a material fact or by willful misrepresentation…this boundless discretion means that these second-class citizens can never feel entirely secure in their claim to American citizenship…There is also no assurance that the government will always institute these proceedings fairly, as it may harbor any number of ulterior motives.375 86 UNMAKING AMERICANS