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Recently, the Department of Justice (DOJ) published a memo listing out its priorities for civil enforcement cases. In that memo, the DOJ states that it will be focusing on denaturalization cases. This memo - along with statements made by administration officials and members of congress - has sparked a lot of attention on denaturalization and questions about who could be denaturalized. This has caused a lot of fear and uncertainty in communities, but denaturalization is not as straightforward as you might think.

This practice advisory provides background on the disability waiver of the English and civics requirement for naturalization and describes the June 2025 revisions to the USCIS Policy Manual (PM) on the submission and review of disability waivers. The revised guidance in the PM applies to applications filed on or after the publication date of June 13, 2025. Overall, the PM revisions signal a change in tone that assumes fraud in the disability waiver process is frequent and encourages increased scrutiny by USCIS adjudicators.

For many noncitizens, naturalization is the best defense against deportation from the United States. Indeed, USCIS lacks the authority to detain or deport a U.S. citizen. However, applying for naturalization can be risky for some individuals because it can instigate immigration enforcement. This concern has increased following President Trump’s February 28, 2025 NTA Memo. The ILRC, NIPNLG, CLINIC, and the Ready to Stay collaborative wrote a practice advisory summarizing the most common reasons why USCIS may deny an N-400, providing guidance for ways to screen and avoid an N-400 denial and removal proceedings, and discussing immigration relief options in immigration court.