civil cases, “parties represented by lawyers are between 17% and 1,380% more likely to receive favorable outcomes in adjudication than are parties appearing pro se.”403 On average, those with representation were over five times more likely to prevail in court than were unrepresented litigants.404 The Criminal Justice Act provides for discretionary appointments of pro bono counsel “for a person charged with civil or criminal contempt who faces loss of liberty.”405 As some have argued in the civil denaturalization cases we reviewed, stripping citizenship qualifies as “loss of liberty,” thus requiring appointment.406 Nationality is inextricably intertwined with one’s identity and access to basic needs, and as such, a person whose nationality is at risk of being stripped should be entitled to representation in order to assure a fair trial in which he or she “stands equal before the law.”407 A U.S. district judge presiding over a civil denaturalization proceeding told the Justice Initiative that he himself ordered appointment of counsel, stating that the gravity of what was at stake—loss of nationality—made it essential the defendant had representation.408 The World Justice Project’s 2019 Rule of Law Index ranked the United States 99 out of 126 countries on the factor of “accessibility and affordability of civil justice.”409 In 2014, both the UN Committee on the Elimination of Racial Discrimination (CERD) and the Human Rights Committee raised concerns regarding access to legal representation in civil cases in the United States.410 The Trump administration has recommended defunding the Legal Services Corporation, the nation’s single largest funder of civil legal aid, providing financial support to 132 legal aid programs around the country.411 Denial of Presumption of Innocence While not explicitly mentioned in the Constitution, the “presumption of innocence” follows from the Fifth, Sixth, and Fourteenth Amendments and has been firmly established by the Supreme Court.412 This means that for those accused of committing a criminal act, the burden of proving guilt is on the other party (in the case of denaturalization, the U.S. government), to demonstrate that the accused is actually guilty. This principle is also codified in international law.413 Use of alias in proceedings. In many of the cases reviewed, the defendant is accused of using multiple identities. In these cases, the government proceeds with referring to the defendant by the name the government determines is the defendant’s real name, not necessarily the name the defendant asserts as their true name. The entire proceeding signals the guilt of the defendant in using a “false” name as a foregone conclusion in such cases. The court similarly uses the name chosen by the government for docket purposes. For instance, Odette Dureland, a naturalized citizen from Haiti, was accused of being a woman named Enite Alindor. Despite II. Denaturalization: A Radical Measure in the Hands of Zealots 93