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Citizenship Applications Are Now Enforcement Triggers: Advising and Litigating Delays, Denials, and the Denaturalization Surge

Naturalization practice now runs through three Ds: delay, denial, and denaturalization. Learn to prepare N-400 clients from filing through review, litigate unreasonable delays and denials in federal court, and defend Shumate Memo denaturalization cases.

2026-08-14 13:00:00

Program Details

2026-08-14 13:00:00

Program Details

2026-08-14 13:00:00

Over 1,000+ webinars

2026-08-14 13:00:00

Course Overview

Every N-400 now carries three litigation futures: delay, denial, and denaturalization

2026-08-14 13:00:00

Naturalization practice changed in 2025. USCIS froze adjudications under policy memoranda PM-602-0192 and PM-602-0194 until the nationwide vacatur in Dorcas. The April 2026 FBI Next Generation Identification resubmission expanded criminal history checks in pending cases. The DOJ’s Shumate Memo directed a civil denaturalization surge. Cross-agency data-sharing and screening programs now feed each enforcement stage.

The consequences follow a pattern. A case sits unreasonably delayed, and federal court becomes the only path to a decision. An interview goes wrong, and post-interview review becomes the client’s remedy. A false statement meets the Maslenjak materiality test, and 8 U.S.C. § 1451(a) revocation follows. DOJ filed more than 64 civil denaturalization cases between January and March 2025.

Attendees leave with practitioner work product organized around the three Ds: client preparation frameworks from filing through post-interview review, administrative record checklists, and litigation roadmaps built on Dorcas, Wagafe v. USCIS, and Doe v. Trump. This is judgment work that no screening tool replaces.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
N-400 Preparation
Preparing clients from filing through interview and post-interview review, including pre-filing audits of social media and financial records.
02
Adjudication Freeze Triage
Determining whether a client’s N-400 is frozen, released, or unreasonably delayed under PM-602-0192, PM-602-0194, and the nationwide vacatur in Dorcas.
03
Litigating Delay
Building federal court challenges to unreasonably delayed naturalization cases, applying the APA and due process theories tested in Dorcas, Wagafe v. USCIS, and Doe v. Trump.
04
Challenging Denials
Identifying viable claims and building the administrative record to seek federal review of naturalization denials, from post-interview options forward.
05
Denaturalization Defense Strategy
Defending Shumate Memo cases through the Maslenjak materiality standard, the clear, unequivocal, and convincing evidence burden, and the statutory limits of 8 U.S.C. § 1451(a).
06
Enforcement Data Exposure
Counseling clients on exposure created by the IRS-ICE memorandum of understanding and USCIS Vetting Center screening, addressed as sub-issues within the delay and denaturalization prongs.

Program schedule

clock 1:00 pm - 2:00 pm EST

Preparing the N-400: Client Advising from Filing Through Post-Interview Review

This session equips immigration attorneys to advise N-400 clients in the post-2025 adjudication landscape, including the aftermath of USCIS policy memoranda PM-602-0192 and PM-602-0194 following the nationwide vacatur issued in Dorcas, and the expanded criminal history disclosures triggered by the April 2026 FBI Next Generation Identification resubmission. Attorneys will learn how to prepare clients at each stage — filing an N-400, awaiting an interview, preparing for the interview, and pursuing post-interview review.

Jesse Matthew BlessJesse Matthew Bless
Lance CurtrightLance Curtright
clock 2:10 pm - 3:10 pm EST

Litigating the Three Ds: Delay, Denial, and Denaturalization

This session examines the federal court remedies available to challenge naturalization delays, naturalization denials, and the DOJ’s civil denaturalization surge under the Shumate Memo. Attorneys will analyze the APA, due process, and statutory arguments that have succeeded and failed in live litigation, including Dorcas, Wagafe v. USCIS, and Doe v. Trump. Attendees will leave with a working framework for identifying viable claims, building the administrative record, and advising clients on exposure across all three enforcement pipelines.

Jesse Matthew BlessJesse Matthew Bless
Lance CurtrightLance Curtright
Jesse Matthew Bless

Jesse Matthew Bless

Bless Litigation LLC

Lance Curtright

Lance Curtright

De Mott, Curtright & Armendáriz, LLP

Jesse Matthew Bless

Jesse Matthew Bless

Bless Litigation LLC

Jesse M. Bless is the founder and owner of Bless Litigation LLC. In 2004, Mr. Bless was selected for the Attorney General’s Honors Program at the Department of Justice. Mr. Bless worked at the DOJ between September 2004 and May 2017. In September 2019, Mr. Bless was selected as the American Immigration Lawyers Association’s first Director of Federal Litigation. In September 2022, Mr. Bless started Bless Litigation LLC.

Education & Credentials

Mr. Bless entered federal practice in 2004 through the Attorney General's Honors Program at the U.S. Department of Justice. He is admitted to practice law in Massachusetts and litigates in U.S. District Courts nationwide.

Recognition & Leadership

In 2025, Mr. Bless received the Jack Wasserman Award, presented annually by the American Immigration Lawyers Association to the attorney who has made the most significant contribution to the development of immigration law through federal litigation.

Professional Involvement

From 2019 to 2022, Mr. Bless served as AILA's first Director of Federal Litigation, shaping national strategy for federal immigration litigation and supporting attorneys across the country.

Experience

During thirteen years at the Department of Justice, Mr. Bless worked for the Executive Office for Immigration Review, the U.S. Attorney's Office for the District of Columbia, and the Office of Immigration Litigation. From 2017 to 2019, he managed the litigation practice group at Jeff Goldman Immigration in Boston. Today he represents companies and individuals seeking relief from immigration-related decisions and delays in federal court, including mandamus actions against USCIS, visa denial challenges, and circuit court petitions for review.
Lance Curtright

Lance Curtright

De Mott, Curtright & Armendáriz, LLP

Lance Curtright is the Managing Partner of De Mott, Curtright & Armendáriz, LLP in San Antonio, Texas. He has practiced immigration law since 2001 and is Board Certified in Immigration and Nationality Law by the Texas Board of Legal Specialization. His practice spans removal defense, federal litigation, business immigration including TN and E visas, and family-based immigration.

Education & Credentials

Mr. Curtright earned his J.D. with distinction from the University of Nebraska, where he served on the National Moot Court team and received the Order of Barristers for advocacy. He holds a B.A. in Politics from the University of Dallas, where he graduated cum laude in 1998. He is Board Certified in Immigration and Nationality Law by the Texas Board of Legal Specialization.

Recognition & Leadership

Mr. Curtright has been selected for the Thomson Reuters Super Lawyers list and for the 2016 through 2024 editions of The Best Lawyers in America. Under his lead, the firm's Litigation Section received the 2013 Best Litigation Department of the Year award from Texas Lawyer magazine. In 2021, he was elected to the San Antonio Bar Foundation Class of Fellows.

Professional Involvement

He is a member of the American Immigration Lawyers Association, the Federal Bar Association, and the San Antonio Bar Association. He chaired the Texas/New Mexico/Oklahoma Chapter of AILA in 2019-2020 and previously served as the ICE liaison for the San Antonio district. He is admitted to practice before the United States Supreme Court, the Second, Fifth, and Sixth Circuits, the Western, Southern, Northern, and Eastern Districts of Texas, the District of Nebraska, and Texas state courts.

Experience

Mr. Curtright has represented hundreds of clients in federal removal proceedings and has helped individuals, corporations, and families secure permanent residency. His published decisions include Mejia v. Barr, Cabrera v. Sessions, Iruegas-Valdez v. Yates, Hosseini v. Johnson, Villegas-Sarabia v. Johnson, Amrollah v. Napolitano, Matter of Lamus, and Mortera-Cruz v. Gonzales. He has also advised on federal court matters involving Department of Labor and ICE I-9 employer compliance audits, publishes on immigration law, and speaks frequently at immigration law conferences.
Jesse Matthew Bless

Jesse Matthew Bless

Bless Litigation LLC

Jesse M. Bless is the founder and owner of Bless Litigation LLC. In 2004, Mr. Bless was selected for the Attorney General’s Honors Program at the Department of Justice. Mr. Bless worked at the DOJ between September 2004 and May 2017. In September 2019, Mr. Bless was selected as the American Immigration Lawyers Association’s first Director of Federal Litigation. In September 2022, Mr. Bless started Bless Litigation LLC.

Education & Credentials

Mr. Bless entered federal practice in 2004 through the Attorney General's Honors Program at the U.S. Department of Justice. He is admitted to practice law in Massachusetts and litigates in U.S. District Courts nationwide.

Recognition & Leadership

In 2025, Mr. Bless received the Jack Wasserman Award, presented annually by the American Immigration Lawyers Association to the attorney who has made the most significant contribution to the development of immigration law through federal litigation.

Professional Involvement

From 2019 to 2022, Mr. Bless served as AILA's first Director of Federal Litigation, shaping national strategy for federal immigration litigation and supporting attorneys across the country.

Experience

During thirteen years at the Department of Justice, Mr. Bless worked for the Executive Office for Immigration Review, the U.S. Attorney's Office for the District of Columbia, and the Office of Immigration Litigation. From 2017 to 2019, he managed the litigation practice group at Jeff Goldman Immigration in Boston. Today he represents companies and individuals seeking relief from immigration-related decisions and delays in federal court, including mandamus actions against USCIS, visa denial challenges, and circuit court petitions for review.
Lance Curtright

Lance Curtright

De Mott, Curtright & Armendáriz, LLP

Lance Curtright is the Managing Partner of De Mott, Curtright & Armendáriz, LLP in San Antonio, Texas. He has practiced immigration law since 2001 and is Board Certified in Immigration and Nationality Law by the Texas Board of Legal Specialization. His practice spans removal defense, federal litigation, business immigration including TN and E visas, and family-based immigration.

Education & Credentials

Mr. Curtright earned his J.D. with distinction from the University of Nebraska, where he served on the National Moot Court team and received the Order of Barristers for advocacy. He holds a B.A. in Politics from the University of Dallas, where he graduated cum laude in 1998. He is Board Certified in Immigration and Nationality Law by the Texas Board of Legal Specialization.

Recognition & Leadership

Mr. Curtright has been selected for the Thomson Reuters Super Lawyers list and for the 2016 through 2024 editions of The Best Lawyers in America. Under his lead, the firm's Litigation Section received the 2013 Best Litigation Department of the Year award from Texas Lawyer magazine. In 2021, he was elected to the San Antonio Bar Foundation Class of Fellows.

Professional Involvement

He is a member of the American Immigration Lawyers Association, the Federal Bar Association, and the San Antonio Bar Association. He chaired the Texas/New Mexico/Oklahoma Chapter of AILA in 2019-2020 and previously served as the ICE liaison for the San Antonio district. He is admitted to practice before the United States Supreme Court, the Second, Fifth, and Sixth Circuits, the Western, Southern, Northern, and Eastern Districts of Texas, the District of Nebraska, and Texas state courts.

Experience

Mr. Curtright has represented hundreds of clients in federal removal proceedings and has helped individuals, corporations, and families secure permanent residency. His published decisions include Mejia v. Barr, Cabrera v. Sessions, Iruegas-Valdez v. Yates, Hosseini v. Johnson, Villegas-Sarabia v. Johnson, Amrollah v. Napolitano, Matter of Lamus, and Mortera-Cruz v. Gonzales. He has also advised on federal court matters involving Department of Labor and ICE I-9 employer compliance audits, publishes on immigration law, and speaks frequently at immigration law conferences.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Approved
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Approved
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Approved
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Approved
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Approved
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Approved
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs