individual may unwittingly have been issued a visa to enter the United States in error, which eventually led to permanent residency and, later, to naturalization. The civil statute’s “illegal procurement” prong could be used to strip nationality in such a case. 2. Continuous residence. After admission to the United States as a permanent resident, individuals must reside continuously within the U.S. for a specific amount of time— usually five years; three years if married to a U.S. citizen—immediately preceding the date of filing for naturalization. Extended absences from the country can disrupt continuous residence. Absence over six months “is presumed to break the continuity of such residence.”199 3. Physical presence. To naturalize, individuals must show they were physically present in the U.S. either for 30 months within the five-year period before applying, or for 18 months within the three-year period before applying in the case of spouses of U.S. citizens.200 Applicants must also demonstrate they have resided in the U.S. for at least three months immediately preceding filing for naturalization. If a person omitted a trip outside the United States that would have made them ineligible to meet the physical presence requirement, they could be denaturalized.201 4. Good moral character. An individual attempting to naturalize must demonstrate that he or she has been a person of “good moral character” (GMC), including during the three- or five-year period immediately preceding an application for naturalization and until the time of taking the Oath of Allegiance. GMC “means character which measures up to the standards of average citizens of the community in which the applicant resides.”202 A person may be unable to establish GMC if she admits she committed (including conspiracy or attempt) offenses involving “moral turpitude” or relating to a controlled substance, even if she has never been charged or convicted. Conduct prior to the three- or five-year period may also affect whether the applicant meets the GMC requirement. Congress has determined that certain acts permanently foreclose naturalization (including participation in acts of genocide, torture, extrajudicial killing, severe religious persecution, or murder). GMC is an extremely pliable standard that the government can use as a “catch-all” when attempting to denaturalize someone. This provision was cited in nearly all of the civil denaturalization cases reviewed for this report. The statutory list of conduct that impugns moral character ranges from participation in genocide to being “a habitual drunkard.”203 Thus, even if an applicant’s conduct is not expressly cited as a bar to demonstrating GMC under INA § 101(f ), the adjudicator may look at other factors, and determine GMC based on the “totality of the circumstances.”204 Further complications related to GMC include: 54 UNMAKING AMERICANS