Trump Administration Moves to Strip Somali-born Citizen of U.S. Nationality under 1952 Law

Justice Department filed a petition to revoke the citizenship of Salah Osman Ahmed, a Somali-born man naturalized in August 2007, invoking Part C of 1952 Immigration and Nationality Act, allowing revocation if a naturalized person joins, within five years, an organization barred admission. Prosecutors argue Ahmed’s September 2007 trip to Somalia to join al-Shabaab, designated a Foreign Terrorist Organization, satisfies that condition.

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Part C of 1952 statute, enacted during Red Scare to target “world communism,” conflicts with 1943 Supreme Court decision barring citizenship revocation for political association. It was first used in 2020 to denaturalize Iyman Faris and again in 2026 against Khalid Ouazzani, fraud cases. TPM identified 50 denaturalizations since Trump’s return, and Shumate’s memo directs attorneys to “maximally” pursue denaturalization of naturalized persons deemed security threats.

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Critics argue the petition threatens First Amendment freedoms of speech and association, which Supreme Court applies equally to naturalized and native-born citizens. Applying law to post-naturalization conduct creates a distinction not imposed on long-time citizens, raising equal-protection and judicial-review concerns.

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White House spokesperson said citizenship fraud is a serious crime and deceitful naturalization will be punished. DOJ official noted novelty of using 1952 statute alone but said it aligns with Faris and Ouazzani cases. Cassandra Robertson and Patrick Weil warn courts may view reliance on post-naturalization conduct as contrary to precedent; Amanda Frost calls the approach an aggressive departure from restraint.

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Government filings claim Ahmed “fully understood” al-Shabaab’s objectives, while prosecution statements said he lacked such understanding. No appellate decision has addressed constitutionality of applying 1952 provision to post-naturalization conduct.

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• “All citizens have a right to freedom of speech and freedom of association, and the Supreme Court has been very clear that those rights apply absolutely equally between native-born citizens and naturalized citizens.” — Cassandra Robertson, Law Professor, Case Western Reserve University

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• “I think the courts will be very reluctant.” — Patrick Weil, Visiting Professor, Yale Law School

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• “Citizenship fraud is a serious crime; anyone who has broken the law and obtained citizenship through fraud and deceit will be held accountable.” — Abigail Jackson, White House Spokeswoman

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• “This is shameful.” — Daniel Gerdts, Attorney for Ahmed

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• “They’re being very aggressive, certainly in the light of the historical context, which is that Republican and Democratic administrations have been very hesitant to use denaturalization liberally and have done so very sparingly and with lots of discretion.” — Amanda Frost, Law Professor, University of Virginia

Talking Points Memo

The petition proceeds to federal court, prompting Supreme Court review of the 1952 statute’s compatibility with First Amendment jurisprudence. Administration’s denaturalization push suggests additional cases may follow, reshaping legal landscape for naturalized citizens.

Talking Points Memo