What Happens When A Naturalized Citizen Commits Terror In America?

On Thursday, Mohamed Bailor Jalloh — an ex-National Guard soldier previously convicted of terrorism charges — opened fire at Old Dominion University, killing a decorated service member.

Jalloh, originally from Sierra Leone, is the latest naturalized American citizen to commit a violent attack in the United States. There have been at least three attacks carried out by naturalized citizens in the last two weeks, leading many to call for a change to the naturalization process that allows these attackers into the country.

It’s not that simple.

“If a naturalized U.S. citizen commits a heinous act of terrorism, that’s not a way to take away somebody’s [citizenship],” immigration attorney Matthew Kolken told The Daily Wire. “They’ve done everything right from an immigration standpoint.”

“The law does not allow you to just take away someone’s citizenship. They can be convicted of a crime and go to jail for the rest of their life, but they’ll die a United States citizen,” Kolken said.

Jalloh, for instance, was sentenced to 11 years in prison with another five years of supervised release in his terrorism case and was let out early in December 2024, according to the New York Post.

If the feds wanted to denaturalize Jalloh, they would’ve had to have found evidence of “fraud” tied to his immigration case.

“We’re not talking about a crime, we’re talking about an immigration law violation,” Kolken said.

“Even though you want to the United States wants to denaturalize somebody because they engaged in an act of terrorism and murdered people in this country, the way that you would effectuate a denaturalization is if you discover a fraud that was not disclosed in furtherance of their immigration journey,” Kolken said.

After the SAVE America Act, we must pass the SCAM Act so we can denaturalize & deport those who are here to hurt Americans.

We must denaturalize those who shouldn’t be here.

Will is exactly right. https://t.co/z31zdDvzMZ pic.twitter.com/QPN58EoJRX

— Senator Eric Schmitt (@SenEricSchmitt) March 12, 2026

In addition to committing immigration fraud, an individual can become denaturalized if they join the Communist Party or another “subversive organization” within five years of gaining citizenship, George Fishman, senior fellow at the Center for Immigration Studies, said.

But Fishman warned that denaturalization is “tough,” adding that in Jalloh’s case, “unless the government can come up with evidence that he lied, he concealed a material fact during his naturalization, I’m not sure there’s really a viable way forward.”

Naturalized citizens can also lose their citizenship if they are discharged from the military “under other than honorable conditions” after obtaining citizenship based on their military service, according to the United States Citizenship and Immigration Services. They must have been discharged before having served honorably for “at least five years.”

The federal government naturalized 818,500 new citizens in fiscal year 2024, which ran between October 2023 and September 2024, according to federal data.

With the mountain of cases, it may be difficult to go back and audit those who’ve already been naturalized, Fishman said, adding that the federal government should “be much more deliberative in deciding whether to naturalize someone in the first place.”

For any future cases, Congress “could … toughen the standards for naturalization,” Fishman said.

Missouri Senator Eric Schmitt (R) has introduced legislation to make it easier for the United States to denaturalize immigrants who pose a national security threat.

His proposed legislation, the Stop Citizenship Abuse and Misrepresentation (SCAM) Act, seeks to denaturalize those who commit welfare fraud, aggravated felonies, and espionage. It also applies to individuals with ties to drug cartels or foreign terrorist groups.

“We must denaturalize those who shouldn’t be here,” Schmitt said on X Thursday.