• An expanding list of permanent bars to good moral character. The list of acts or alleged acts that serve as permanent bars to GMC grew during immigration reforms in the 1990s. In 1991, Congress added a permanent bar for those convicted of an “aggravated felony” on or after November 29, 1990.205 In 1996, with the passage of the controversial Illegal Immigration Reform and Immigrant Responsibility Act, Congress expanded the type of offense considered an “aggravated felony” in the immigration context206 to include such offenses as those relating to passport and document fraud207 and failure to appear to court.208 • Discretionary decision-making: Conditional bars to good moral character. Federal law also includes bars to GMC that are not permanent (or automatic) in nature, known as “conditional bars.” The category is called “conditional” because a person may still qualify for citizenship if the conduct is considered an exception, for example if it was the only crime the person has ever committed, or it was committed prior to the threeor five-years leading up to the submission of one’s naturalization application. Conditional bars are discretionary in nature—that is, they are subjective and depend on the view of the adjudicator. For example, a person who has committed a “crime involving moral turpitude (CIMT)” will be conditionally barred from naturalizing. But according to USCIS, CIMT “used in the immigration context has no statutory definition.”209 Instead, case law is used as guidance when determining whether an offense rises to the level of a CIMT.210 Determining whether an offense rises to the level of CIMT is based on the judgment of the USCIS officer processing the application. The applicant’s admission alone, without any conviction, is sufficient to disqualify them. Conduct considered to be CIMTs listed by USCIS ranges from using marijuana or working in the cannabis industry (even in states where it is legal)211 to statutory rape, theft, forgery, and offering a bribe.212 5. Attachment to the U.S. Constitution. Prior to and after naturalization, a person must demonstrate that she is “attached to the principles of the Constitution of the United States and well-disposed to the good order and happiness of the United States during the statutorily prescribed period.”213 According to USCIS, an “applicant must understand that he or she is giving true faith and allegiance to the United States, its Constitution and laws” and “[a]n applicant who is hostile to the basic form of government of the United States, or who does not believe in the principles of the Constitution, is not eligible for naturalization.”214 • Membership in certain organizations. If an applicant was or is a member of, or associated (either directly or indirectly) with, certain organizations, this may be construed as indicating a lack of attachment to the Constitution.215 Such organizations include “the Nazi government of Germany, [t]he Communist Party; [a]ny other totalitarian party; or II. Denaturalization: A Radical Measure in the Hands of Zealots 55