In 1933, Emma Goldman observed that “the essential significance of the idea of country, of citizenship” was “the possession of a certain guarantee of security, the assurance of having some spot you can call your own and that no one can alienate from you. Divested of that, it becomes sheer mockery” (2). Goldman spoke from bitter experience. In 1909, she lost her American citizenship when her former husband lost his denaturalization proceedings, as part of the Bureau of Immigration's campaign to bar Goldman from America. Without her American citizenship, Goldman had little recourse when the United States deported her in 1919. She became “a woman without a country” (187).

Goldman may have been one of the most famous, but she was hardly the only, naturalized American to lose her citizenship, as Patrick Weil reveals in his illuminating study of denaturalization. Weil highlights the “conditional” nature of American citizenship in the twentieth century, as Congress provided that both native-born and naturalized Americans could lose their citizenship for a range of reasons. Although Congress first authorized the “cancellation of citizenship” in 1906 to attack naturalization fraud, denaturalization soon became “a tool for ridding the American citizenry of ‘undesirables’,” targeting “non-whites” (especially Asian Americans), those who held “un-American” political beliefs (radicals but also fascists), and those whose behavior after naturalization betrayed, in policymakers' eyes, a lack of genuine attachment to the United States (7). American women who married aliens, naturalized Americans who lived abroad, and German Americans who expressed divided loyalties during World War I all became vulnerable to losing their citizenship, either through explicit statutory provisions or through administrative and judicial interpretations. By the century's end, more than 22,000 naturalized Americans lost their citizenship.

Denaturalization forced new debates about the meaning of citizenship and raised a key question: who decides who belongs? For the first half of the twentieth century, Weil argues, the answer seemed to be the federal government. Congress centralized the naturalization process and introduced novel denaturalization procedures, vesting power to oversee citizenship policies in the new Bureau of Naturalization. Citizenship in this era consisted of a “constellation of rights contingent on the satisfaction of certain obligations,” leaving it to the state to decide whether citizens had met their obligations, and providing denaturalization as a mechanism to expel those who had not. Weil digs deep into often-overlooked administrative records to reveal the “state in action,” highlighting the significant discretion administrative officials wielded in implementing denaturalization. However, stripping Americans of citizenship did not sit well with all officials, especially after Congress in 1940 divested native-born Americans of their citizenship for voting in a foreign election, serving in a foreign army or government, deserting the armed forces during time of war, or committing treason. Simultaneously, the Department of Justice embarked on an aggressive campaign to denaturalize hundreds of German-American members of the fascist Bund. How far could the state go?

Denaturalization divided administrative officials and, after 1940, also split Supreme Court justices who debated whether “conditional” citizenship could withstand constitutional scrutiny. Weil reveals in rich detail the Court's internal struggle as advocates of judicial deference to Congress's sovereign power to divest Americans of their citizenship gradually lost ground to those who stood “aghast” at such a cavalier attitude toward citizenship (8). In Afroyim v. Rusk: 387 U.S. 253 (1967), the Supreme Court majority declared that Congress had no express power “to strip people of their citizenship.” “In our country the people are sovereign,” Justice Hugo Black trumpeted, and every citizen has “a constitutional right to remain a citizen in a free country unless he voluntarily relinquishes that citizenship” (173, 175). Weil argues that the Afroyim majority did far more than dismantle denaturalization: “It had achieved, without much notice, a revolution in the definition of citizenship” by reversing the “traditional concept” of state sovereignty. “Citizens themselves were now the fount of sovereignty” (5, 9).

Weil's conclusion is puzzling, as the concept of “citizen sovereignty” was certainly not new in 1967, perhaps explaining why the Court's resort to it was received “without much notice.” Concepts of “citizen sovereignty” and volitional allegiance reached back to the American Revolution, although, as Weil's study demonstrates so well, they often collided with competing claims of the nation state to sovereign power. Although this was not a new concept, the Warren Court clearly expanded the reach of “citizen sovereignty” to anchor its bold and definitive claim that citizenship was “nearly unconditionally guaranteed” (5). The way in which the broader historical context made such internal legal changes possible is not a subject that Weil tackles in much depth, but Weil's informative twist on the traditional narrative, highlighting how Americans lost rather than attained citizenship, is a significant contribution to our understanding of American citizenship policy.