December 2006 and leaked to the New York Times in 2010,263 describes the two-week Fedorenko trial in South Florida, quoting the district judge: From the beginning it was like a Hollywood spectacular and polarized the residents of South Florida. As an example of some of the emotional intensity surrounding the trial, the Jewish Defense League ran ads in newspapers offering chartered buses from Miami Beach to Fort Lauderdale on opening day. A demonstration outside the courtroom ensued with a chant: “Who do we want? Fedorenko. How do we want him? Dead.” After the court was interrupted twice and the first three warnings were ignored by the demonstrators, a leader who as using an amplified bullhorn was arrested.264 The report also recounts representation of OSI defendants, sometimes by Jewish lawyers, who “have generally defended their decision to represent alleged Nazi persecutors on the ground that refusing to represent a class of persons per se is reminiscent of the treatment Jews received in Nazi Germany.”265 While a proportion of cases settled, the purpose of OSI was to hold trials like Fedorenko’s. The goals were to expose a narrow set of actors who had knowingly concealed horrific deeds to secure safe haven living amidst their victims, to make a public record of all that the United States government could, belatedly, learn about surviving Nazi persecutors, and to engage survivor communities in an accountability process, however imperfect. Between its establishment in 1979 and 2015, OSI successfully prosecuted 108 cases and 68 people were stripped of nationality, leading to 67 individuals being “deported, extradited, or otherwise expelled.”266 In 2004, Congress passed the Intelligence Reform and Terrorism Prevention Act, establishing statutory recognition of OSI’s purpose and expanding its mandate to cover modern war criminals.267 Fedorenko v. United States (1981) was the first OSI case to come before the Supreme Court.268 Commentators analyzing the outcome of that litigation expressed concern about the procedural implications of using Nazi war crime “trials” to set the parameters for citizenship-stripping statutes that could, one day, target a much broader swath of the citizenry: The cry for retribution against war criminals, who are guilty of inhuman brutality, must be tempered by the American ideal of justice, particularly because this ideal was conspicuously absent from the Nazi regime. In the final analysis, the paramount concern is that the concepts of due process and citizenship rights are continuously honed and forever maintained.269 64 UNMAKING AMERICANS