Standing Groups, Warsaw (Mar 29-Apr. 2, 2015), at 19, https://ecpr.eu/Filestore/PaperProposal/2ab106b5-1c2a-4be4-9313-8d858890cb39.pdf. 140. Open Society Justice Initiative, Pham (previously B2) v. Home Secretary, Open Society Foundations, https:// www.justiceinitiative.org/litigation/pham-previously-b2-v-home-secretary. 141. Benjamin Weiser, British Man Admits Past in Terror Cell in Yemen, N.Y. Times, Jan. 8, 2016, https://www. nytimes.com/2016/01/09/nyregion/minh-quang-phambritain-man-linked-to-yemeni-militants-plea.html. . 142. Open Society Justice Initiative, supra note 140. 143. Id. 144. Nisha Kapoor, Deport, Deprive, Extradite: 21st Century Extremism 87 (2018). 145. Id. at 88. 146. Id. 147. House of Commons Library, Deprivation of British Citizenship and Withdrawal of Passport Facilities, 2017, H.C. SN06820, https://researchbriefings.parliament.uk/ ResearchBriefing/Summary/SN06820. 148. Tufyal Choudhury, The radicalization of citizenship deprivation, Critical Social Policy 37(2), 225-244. 149. Nisha Kapoor & Kasia Narkowicz, Unmaking citizens: passport removals, pre-emptive policing and the reimagining of colonial governmentalities, 42 Ethnic and Racial Studies 45, 48 (2017). 150. Id. 151. Don Davies, NDP MP for Vancouver Kingsway (B.C.), during Citizenship Act Government Orders, June 3, 2016, https://openparliament.ca/bills/42-1/C-6/. 152. Don Davies, NDP MP for Vancouver Kingsway (B.C.), during Citizenship Act Government Orders, June 3, 2016, https://openparliament.ca/bills/42-1/C-6/. 153. Tu Thanh Ha, Federal Court Voids Canadian Citizenship Revocation for 312 People, The Globe and Mail (July 12, 2017), https://www.theglobeandmail.com/news/ national/federal-court-voids-canadian-citizenship-revocation-for-312-people/article35675424/. Agenda, N.Y Times (Dec. 23 2017), https://www.nytimes. com/2017/12/23/us/politics/trump-immigration.html. 158. Id. 159. Civil Division, FY2020 Budget & Performance Plans, at 16 (Mar. 2019), https://www.justice.gov/jmd/page/ file/1143936/download. 160. Civil Division, FY2020 Budget & Performance Plans, at 26 (Mar. 2019), https://www.justice.gov/jmd/page/ file/1143936/download. 161. These former peaks, which are reflected in the higher averages under the Reagan and George W. Bush administrations, may be attributable to the passage of the 1986 Immigration Reform and Control Act (IRCA), which pressed for the deportation of all immigrants convicted of a deportable offenses, and the events of September 11, 2001. See American Immigration Council, The Growth of the U.S. Deportation Machine – More Immigrants Are Being “Removed” from the United States Than Ever Before (Mar. 1, 2014), https://www.americanimmigrationcouncil.org/ research/growth-us-deportation-machine. Most electronic files for civil denaturalization cases are not accessible through PACER. These files can only be obtained directly from courthouses across the country. The findings also present publicly available historical data. Freedom of Information Act requests filed in December 2018 to three divisions within the Department of Justice (DOJ) and USCIS, a component of the Department of Homeland Security (DHS), concerning the use of denaturalization, have not yielded significant information. The Civil Division partially responded to narrowed requests for historical data, citing 5 U.S.C. § 552(b)(5)-(6) exemptions. The Criminal Division of DOJ and Executive Office of U.S. Attorneys (which house information relating to criminal denaturalization), and USCIS (which retains information relating to denaturalization investigations, statelessness and deportations), did not supply information responsive to the request. 162. Data provided by the U.S. government was organized by calendar years, thus precise comparisons by presidential administrations was not possible. U.S. presidential annual terms run from January 20th through January 19th. The data used to generate this graph do not include the additional seven cases identified by the Open Society Justice Initiative in its independent review. 156. Tu Thanh Ha, supra note 153. 163. A 2017 article on § 1425 prosecutions states that 46 criminal denaturalization cases were brought in 2016, based on data from the Executive Office for United States Attorneys derived from the United States Attorneys’ Case Management System. See U.S. Dep’t of Justice Executive Office for U.S. Attorneys, Civil Immigration Enforcement and the Office of Immigration Litigation - District Court Section, volume 65, number 3 (Jul. 2017), https://www. justice.gov/usao/page/file/984701/download. 157. Michael D. Shear & Julie Hirschfeld Davis, Stoking Fears, Trump Defied Bureaucracy to Advance Immigration 164. Drug dealers, criminals, rapists: What Trump thinks of Mexicans, BBC News (Aug.31, 2016), https://www.bbc. 154. Id. 155. Hassouna v. Canada (Citizenship and Immigration), [2017] 4 FCR 555, 2017 FC 473 (CanLII), http://canlii.ca/t/ h4052. Endnotes 169