16 N.Y.U. J. Int'l L. & Pol. 829 (1983-1984)
United States Loss of Citizenship Law after Terrazas: Decisions of the Board of Appellate Review

handle is hein.journals/nyuilp16 and id is 845 raw text is: UNITED STATES LOSS OF CITIZENSHIP LAW
AFTER TERRAZAS: DECISIONS OF THE
BOARD OF APPELLATE REVIEW
I. INTRODUCTION
Each year more than one thousand Americans' lose their
citizenship2 by committing one of the acts defined to be
expatriatory3 in Section 349 of the Immigration and Nationali-
ty Act of 1952 (the Act).4 For some, this relinquishment of
citizenship is truly voluntary expatriation,5 while for others this
loss is undesired and effectively constitutes denationalization6
by congressional fiat.
* The author wishes to thank Alan G. James, Chairman of the United
States State Department Board of Appellate Review, Maggie Street, the
Board's Staff Assistant, Edward Betancourt and H. Edward Odom of the
State Department's Citizens' Consular Services Office, and William B. Whar-
ton of the Office of Citizenship Appeals and Legal Assistance for their time,
patience and valuable insight. The author also greatly appreciates the infor-
mation provided by consular officials of more than ten nations. Finally, there
is the love and confidence of the author's wife, Edith Linn, to whom this
Note is dedicated.
1. According to the Determination of Loss of U.S. Nationality
Statistics compied by the U.S. State Department's Office of Citizens' Con-
sular Services, 1,638 citizens lost their nationality during Fiscal Year 1977:
1,985 during Fiscal Year 1978; 1,236 during Fiscal Year 1979; 1,500 during
Fiscal  Year 1980; and 1,056 during Fiscal Year 1981 (Loss Statistics avail-
able in author's file at N.Y.U. J. INr'L L. & POL.).
2. Although there are slight differences between thetcrms citizenshil3
and nationality (there are some inhabitants of American South Pacific
territories who, while nationals of the United States, are not citizens), these
words will be used interchangeably throughout this Note.
3. See infra notes 17-18 and accompan'ying text (discussion of term
expatriatory).
4. Immigration and Nationality Act of 1952, § 349(a), 8 U.S.C. §
1481(a) (1982) [hereinafter Act] provides a list of expartiating acts. For
the text of this section, see infra note 61. For a discussion of the history of the
Act and its predecessors, see infra text and accompanying notes 20-67.
5. For example, some individuals wishing to be relieved of their U.S.
citizenship as a political act or as a demonstration of undivided loyalty to
another country may initiate expatriation through a formal oath of renun-
ciation. See infra notes 183-219 and accompanying text.
6. See Note, Expatriation - A Concept in Need of Clarification, U.C.D.L.
REv. 375, 388 (1975) [hereinafter Expatriation]. See also note 17 and
accompanying text.
829

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