Randy Fine Wants to 'Reevaluate' Every Naturalized U.S. Citizen Since 1990
Federal records show about 21.5 million people became citizens from fiscal 1990 through 2022.

Republican Representative Randy Fine of Florida said in an interview that the U.S. should reexamine the citizenship of every person naturalized since 1990. Federal immigration records put that group at about 21.5 million people through fiscal 2022.
Fine was asked whether the scrutiny he wants applied to Democratic Representative Ilhan Omar of Minnesota should also cover high-profile immigrants close to the administration, such as First Lady Melania Trump and Elon Musk, who the interviewer noted "was the head of Doge."
"I believe that we should go back to 1990 and we should reevaluate everyone who has become a naturalized citizen," Fine said.
"Reevaluate" was Fine's word, and he did not say how a review on that scale would work, which agency would run it or what standard it would apply.
Randy Fine Points to Minnesota and Ilhan Omar
Fine tied the proposal to Minnesota. "What I am understanding is the kind of fraud that we're hearing about from Ilhan Omar is endemic in Minnesota with many, many, many people having gotten citizenship without giving appropriate paperwork," he said. "So yeah, I think Ilhan Omar needs to be the first, she certainly should not be the last."
The claim that this kind of fraud is "endemic" is Fine's own characterization. Fine added that there have been allegations about Omar's citizenship for 10 years, "coming from the Somali community." Those allegations remain unproven. The federal prosecutions in Minnesota have centered on fraud against public programs, including daycare, Medicaid and social services programs, rather than on falsified naturalization paperwork. In January, the Department of Homeland Security was reviewing naturalization cases from 19 countries of concern, including Somalia, for fraud in the immigration process, Fox News reported.
Omar, who became a citizen in 2000, faces a federal inquiry into her immigration records, including questions about her date of birth. She has denied wrongdoing and called the inquiry politically motivated. None of the allegations has been proven in court, WJLA reported last week.
Asked again about the first lady and Musk, Fine said he was not aware of any allegations against either of them.
"I don't know anything about the circumstances of the First Lady or Elon Musk. I don't know that there's ever been an allegation," he said. "I believe anyone who lied on their paperwork to become a citizen should be de-naturalized and should be deported."
How Many People Naturalized Since 1990
The group Fine described is large. The Department of Homeland Security's Yearbook of Immigration Statistics records about 21.5 million people naturalized from fiscal 1990 through fiscal 2022. U.S. Citizenship and Immigration Services added 878,500 new citizens in fiscal 2023 and 589,400 in fiscal 2024 through June.
Fiscal-year totals in millions, summed from DHS annual counts; USCIS reports another 878,500 naturalized in FY2023.
Source: DHS Office of Homeland Security Statistics, Yearbook of Immigration Statistics
Not everyone counted is still alive.
Denaturalization Has Been Rare, but That Is Changing
The Justice Department filed 305 denaturalization cases from 1990 to 2017, an average of about 11 a year, NewsNation reported, citing research by Hofstra University law professor Irina Manta. The same research counted 168 cases in Donald Trump's first term and 64 under former President Joe Biden.
The Department of Homeland Security has since said it is reviewing naturalization cases from 19 countries of concern for fraud.
The law still sets a high bar. Under federal law, the government must show that citizenship was "illegally procured" or obtained "by concealment of a material fact or by willful misrepresentation." The Supreme Court held in Fedorenko v. United States in 1981, citing its earlier Schneiderman ruling, that the evidence must be "clear, unequivocal, and convincing" and not leave "the issue in doubt." In Maslenjak v. United States in 2017, the court held that a false statement on its own is not enough: "the illegal act must have somehow contributed to the obtaining of citizenship."
That means each case has to be argued individually in federal court. Fine did not say how a review of every naturalization since 1990 would be done.
Sources
- DHS Yearbook of Immigration Statistics, Table 20: Persons Naturalized, FY1907–2022 — Annual naturalization counts from 1990 to 2022, about 21.5 million in total, used for the scale figure and the chart
- USCIS Celebrates Independence Day 2024 and Continues Its Commitment to Naturalization — FY2023 (878,500) naturalization total and 589,400 in FY2024 through June
- NewsNation: DOJ ramps up efforts to revoke naturalized status — Historical denaturalization case counts: 305 cases from 1990 to 2017, 168 in Trump's first term, 64 under Biden
5 more sources
- Fox News: Minnesota fraud scandal intensifies debate over stripping citizenship — The Minnesota prosecutions involve daycare, Medicaid and social services fraud, and DHS is reviewing naturalization cases from 19 countries of concern, including Somalia, for fraud
- WJLA: Ilhan Omar denies any fraud, blasts probe as a political hit job — The federal inquiry into Omar's records, her denial, and the fact that the allegations are unproven
- 8 U.S. Code § 1451: Revocation of naturalization (Cornell LII) — Statutory grounds for revocation: naturalization 'illegally procured' or procured 'by concealment of a material fact or by willful misrepresentation'
- Fedorenko v. United States, 449 U.S. 490 (1981) (Cornell LII) — Government's burden of proof in denaturalization: evidence must be 'clear, unequivocal, and convincing' and not leave 'the issue in doubt,' citing Schneiderman
- Maslenjak v. United States (2017) (Cornell LII) — Supreme Court holding that 'the illegal act must have somehow contributed to the obtaining of citizenship'