University (Nov. 24, 2010), https://nsarchive2.gwu.edu/ NSAEBB/NSAEBB331/index.htm. 264. Judy Feigin, The Office of Special Investigations: Striving for Accountability in the Aftermath of the Holocaust 49 (December 2006), https://www.nytimes.com/ interactive/projects/documents/confidential-report-provides-new-evidence-of-notorious-nazi-cases?ref=us#p=1. 265. Id. at 526. 266. Andrew Nagorski, The Nazi Hunters 318 (2016). Patrick Weil recites the following figures between 1979 and 2012: “OSI and its successor the Human Rights and Special Prosecutions Section, pursued the denaturalization or deportation of 137 individuals on the basis of participation in Nazi-sponsored acts of persecution. 86 such persons have been denaturalized (the last one in 2007) and 67 have been removed.”). Patrick Weil, The Sovereign Citizen: Denaturalization and the Origins of the American Republic 178 (2013). 267. Public Law 108-408, §§ 5501-26, 118 Stat. 3638 (2004). 268. Judy Feigin, The Office of Special Investigations: Striving for Accountability in the Aftermath of the Holocaust 49 (December 2006), https://www.nytimes.com/ interactive/projects/documents/confidential-report-provides-new-evidence-of-notorious-nazi-cases?ref=us#p=1 (citing three OSI cases to come before the Supreme Court: Federenko v. United States (1981), Kungys v. United States (1988), and United States v. Balsys (1998)). 269. Comment, Denaturalization of Nazi War Criminals: Is There Sufficient Justice for Those Who Would Not Dispense Justice?, 40 Maryland L. Rev. 39, 88-89 (1981). 270. Beth Van Schaack, EXCLUSIVE: FBI’s War Crimes Unit on the Chopping Block, Just Security (Feb.10, 2019), https://www.justsecurity.org/62548/exclusive-fbis-war-crimes-unit-chopping-block/. 271. See Gregory S. Gordon, OSI’s Expanded Jurisdiction under the Intelligence Reform and Terrorism Prevention Act of 2004, in 54 U.S. Attorneys’ Bulletin (January 2006), at 24. IRTPA gave OSI authority over cases of naturalized citizens “who participated abroad in acts of genocide or, acting under color of foreign law, participated in acts of torture or extrajudicial killing.” Id. at 25. 272. See United States Department of Justice Office of the Inspector General (DOJ-OIG), Special Report: An Investigation of the INS’s Citizenship USA Initiative, https:// oig.justice.gov/special/0007/. 273. See Rosemary Jenks, Testimony Prepared for the U.S. House of Representatives, Committee on the Judiciary Subcommittee on Immigration, Border Security, and Claims, Center for Immigration Studies (CIS) (Apr. 30, 1997), https://cis.org/United-States-Citizenship. In addition to IRCA eligibility, CIS cites the passage of Proposition 187 in 174 California (November 1994) and proposed legislation to restrict access to public benefits for non-citizens as negative incentives that could drive an increase in applications for naturalization. 274. DOJ-OIG, Special Report: An Investigation of the INS’s Citizenship USA Initiative, https://oig.justice.gov/ special/0007/. 275. DOJ-OIG, Special Report: An Investigation of the INS’s Citizenship USA Initiative – Criminal History, 155 n.143, https://oig.justice.gov/special/0007/crimhist.pdf. 276. Patrick Weil, The Sovereign Citizen: Denaturalization and the Origins of the American Republic 179 (2013). 277. Timothy M. Belsan, Aram A. Gavoor, Jennifer E. Levy, and Holly D’Andrea-Read, Civil Immigration Enforcement in National Security Cases, in 65 U.S. Attorneys’ Bulletin (July 2017), at 19, https://www.justice. gov/usao/page/file/984701/download. 278. In February 2018, a leaked copy of the “Denaturalization Investigations Handbook” dated January 15, 2008, appeared. ICE, Office of Investigations, Denaturalization Investigations Handbook, OI HB 08-01, Jan. 15, 2008, https://www.unicornriot.ninja/wp-content/ uploads/2018/02/Denaturalization-full-hsi.pdf. The handbook “includes information an agent would consult on whether to attempt stripping citizenship, and the intricacies of building up the case against a naturalized citizen.” Government Attic, a public records website, obtained the HSI “Special Agent Manual Index” through a FOIA request on January 28, 2018, and indicates that, at least until 2016, the leaked version remained in use. Government Attic, ICE FOIA Case Number 2017-ICFO-16778 (Jan. 29, 2018), https://www.governmentattic. org/26docs/ICE-HSIspecAgentManTOC_2016.pdf. 279. ICE, Office of Investigations, Denaturalization Investigations Handbook, OI HB 08-01, Jan. 15, 2008, https://www.unicornriot.ninja/wp-content/ uploads/2018/02/Denaturalization-full-hsi.pdf. 280. Id. 281. Id. 282. Id. 283. Id. 284. DHS-OIG, Potentially Ineligible Individuals Have Been Granted U.S. Citizenship Because of Incomplete Fingerprint Records, OIG-16-130, at 1 n.1 (Sept. 8, 2016), https://www. oig.dhs.gov/assets/Mgmt/2016/OIG-16-130-Sep16.pdf. 285. Id. at 1. 286. Id. at 6. 287. See Adiel Kaplan, Miami Grandma Targeted as U.S. Takes Aim at Naturalized Immigrants With Prior Offenses, UNMAKING AMERICANS