The Fourteenth Amendment’s Citizenship Clause sits within a provision of our Constitution that towers over the history of equal rights movements in this country. The Fourteenth Amendment is a technical masterpiece, written in the aftermath of the Civil War and wide awake to the illegitimacy of self-government when subordination, violence, and hateful treatment against powerless minorities abides.376 Today, when the denaturalization statutes function as an anonymous, arbitrary enforcement tool, used to target some of the most vulnerable communities in the country, it is time to pull back and reckon with the nation’s constitutional conscience. “A Procedural Morass” – Overlapping Civil and Criminal Statutes and a Tortured Jurisprudence Although this report strives to lend clarity to the operation of the two denaturalization statutes, in reality the lines between categories and procedural rules are perpetually blurred, such that the law of denaturalization functions by its own rules, analogized to everything from property suits, to breach of contract, to excommunication. The few academics and practitioners familiar enough with the statutes to explain them find themselves mired in the Supreme Court’s hyper-technical ruminations on the statutory language, still grasping to answer the foundational constitutional questions that continue to plague this area of law.377 Threats to Rights and Liberties in Criminal and Civil Denaturalization Proceedings Criminal Denaturalization Civil Denaturalization Ten-year statute of limitations No statute of limitations Pretrial detention No right to an attorney Movement restrictions No right to trial by jury Forfeiture claims No right not to testify Plea agreements with immigration waivers In absentia denaturalization Removal by district judge Settlement agreements with immigration waivers 25 years imprisonment and fine Automatic citizenship revocation In recognition of the disproportionality between the outcome (loss of nationality, deportation, potential statelessness) and the standard procedural protections afforded in civil cases, the Supreme Court has developed a line of jurisprudence engineered to equalize the litigants’ rights and burdens under the two statutes, chiefly through the heightened burden of proof in civil cases.378 The enduring advantages in civil denaturalizations are described in a 2017 U.S. Attorneys Bulletin: “non-criminal due process protections often result…in civil II. Denaturalization: A Radical Measure in the Hands of Zealots 87