targeted communities will be more easily marginalized and discounted. It is entirely plausible that this stigmatizing effect is known and intentionally cultivated by the current administration in its use of denaturalization and its communications regarding the practice. Procedural Due Process and the Notice Problem Recently denaturalized individuals may be unaware that they have lost their U.S. citizenship. Unlike criminal denaturalization charges—where individuals are clearly notified that charges have been levied against them because they are usually arrested and forced to appear in court—in a civil suit, a person is not subjected to detention, and an entire case can move forward without the person’s participation. As held by the Supreme Court, “Procedural due process rules are meant to protect persons… from the mistaken or unjustified deprivation of life, liberty, or property.”434 Thus, to “minimize substantively unfair or mistaken deprivations,” defendants in civil proceedings have a right to notice and a hearing whenever the government threatens to deprive them of protected interests, enabling them to contest the basis for the potential deprivation.435 In the cases reviewed for this report, the Justice Initiative found instances in which the government was unable to serve defendants with notice, instances in which it appeared that notice of service was improper, and instances in which defendants were served, but never appeared in court, nor answered the complaint filed against them. Of particular concern are cases in which citizens have been denaturalized in absentia—that is, they were stripped of citizenship without being present for the proceedings. Under federal law, when a defendant does not respond to notice, the plaintiff can move for default judgment against the defendant. Pursuant to Rule 55 of the Federal Rules of Civil Procedure, “[w]hen a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the [court] must enter the party’s default.”436 In other words, a default judgment would be entered against the defendant, rendering a verdict against the individual solely based on the person’s failure to participate in the proceedings. Recognizing the gravity of the penalty of revoking citizenship, the Supreme Court has expressed disfavor with default judgments in denaturalization cases. In Klapprott v. United States (1949), the court stated, “there is strong indication…that Congress did not intend to authorize courts automatically to deprive people of their citizenship for failure to appear.”437 The court reasoned that: 98 UNMAKING AMERICANS