consistently on the list are also heavily represented in the denaturalization cases filed in 2017 and 2018. Based on publicly available SIC lists issued by the government since 2003,429 denaturalization cases filed against individuals from SICs account for 49% of all cases reviewed for this report. In short, “Combining selective enforcement with race, religion, or national origin—as with Project Janus’s focus on ‘special interest countries,’ for example—gives rise to serious constitutional concerns.”430 Operation Janus’s use of SICs in the prioritization of cases intersects with a surge in targeting naturalized citizens from Mexico and Haiti as two of the top countries of origin in denaturalization cases in 2017 and 2018. Virtually all defendants in these cases are visible minorities. The correlation between these particular immigrant communities as targets for denaturalization and targets for harsh immigration policy measures and rhetorical invective from President Trump warrants explanation from his administration, if not yet in court then in the public domain, including specific information demonstrating a non-discriminatory justification for these disparities. The equal protection component of the Fifth Amendment’s Due Process Clause safeguards against discrimination, subjecting classifications based on race, alienage, or national origin to strict scrutiny.431At least one, pre-Trump, legal analysis called for the invalidation of § 1451(c) (the basis for “attachment” cases; see the Denaturalization Statutes section earlier in this chapter), because it subjects recently naturalized citizens to unequal treatment “and potentially massive civil penalties” as compared to citizens by birth, on the sole basis of national origin.432 The practice of scouring, in bulk, decades-old records and initiating denaturalization proceedings, strictly on the basis of national origin from an SIC, is not a narrowly tailored approach employing the least restrictive means available to address naturalization fraud. It is an over-inclusive and arbitrary program that aims to expel members of minority groups, subjecting them to degrading and unequal treatment. It has been emphasized already that citizenship measures convey important messages about national belonging, particularly in the emotion-driven politics of the Trump era. Messages about the use of extreme measures like deprivation of nationality may be seen to convey a certain strength of conviction and commitment to an agenda—whether that agenda is white nationalism or defending national security, or both. For example, in 2019, according to one news analysis, the Department of Justice is six times likelier to issue press releases in terror cases involving Muslim suspects than non-Muslim suspects.433 These messages are heard and processed within immigrant communities as well, as the Trump administration likely surmises. The stigmatizing impact of a denaturalization program, even though it may affect only a relatively small number of naturalized citizens, far exceeds the raw numbers. When those numbers are on the rise, by whatever order of magnitude, the risk only grows that II. Denaturalization: A Radical Measure in the Hands of Zealots 97