Mohamed Bailor Jalloh
The man who shot and killed an instructor^ at Old Dominion University in Norfolk, VA, on March 12, 2026 was a naturalized citizen WHO HAD ALREADY BEEN CONVICTED OF TERRORISM. In 2016 Mohamed Bailor Jalloh was convicted of attempting to provide material support to ISIS and sentenced to 11 years in federal prison. The Biden Regime released this terrorist early, after Trump won & before he was sworn in, but made no attempt to denaturalize and deport him. He was on supervised release at the time he went on a shooting spree at Old Dominion. Jalloh entered a classroom in Constant Hall, confirmed it was an ROTC class, and shouted “Allahu Akbar” before opening fire with a .22-caliber pistol.
FORMER NAZIS IN AMERICA
Since the end of World War II, the United States has investigated approximately 1,700 individuals residing in the United States who were suspected of involvement in Nazi war crimes. The US Department of Justice has successfully prosecuted hundreds of former Nazis and removed them from America, even those who had been naturalized. At least 107 to 109 former Nazis have been stripped of their US citizenship.
The most recent removal occurred in 2021, when Friedrich Karl Berger, age 95, a former concentration camp guard, was denaturalized and deported to Germany. Berger moved to the United States in 1959 and lived in Tennessee for decades. He continued to receive a pension from Germany for his wartime service, which eventually helped investigators identify him. The federal government used civil litigation to prove that these individuals had obtained their citizenship or visas through fraud or illegal procurement.
It is estimated that as many as 10,000 Nazi persecutors entered the US after the war, often by lying about their pasts on immigration applications under the Displaced Persons Act. In some cases, suspected Nazis were allowed to leave the US voluntarily. Not all denaturalized or ordered-deported individuals actually left the country. Because some foreign nations refused to accept them, several Nazis lived out their lives in “legal limbo” within the United States.
WE HAVE THE LEGAL TOOLS
The most common grounds used for denaturalizing someone is to prove that the individual willfully misrepresented or concealed material facts during their immigration or naturalization process. If an applicant had disclosed their true wartime activities (such as serving as a concentration camp guard), they would have been legally ineligible for a visa at the time. In the landmark 1981 case Fedorenko v. United States, the Supreme Court ruled that serving as an armed guard at a Nazi death camp was “per se” evidence of assisting in persecution, making any concealment of that service a “material misrepresentation.”
Citizenship can be revoked if it was illegally procured, meaning the person did not strictly comply with all statutory requirements for naturalization. To become a citizen, an applicant must demonstrate “good moral character.” Membership in organizations hostile to the US Constitution was often treated as prima facie (at first sight) evidence that the individual lacked this character.
Under Section 340(c) of the Immigration and Nationality Act, joining or being affiliated with a totalitarian party within five years of naturalization is considered evidence that the person was not truly attached to the principles of the US Constitution. We don’t know exactly when Jalloh became a US citizen, but it is likely that he committed the terrorist crimes for which he was convicted within five years of naturalization. Senator Cotton’s bill would expand the time frame to indefinitely. SEE BELOW
NOTE: Because these were civil rather than criminal proceedings, the government only needs to meet a “clear, convincing, and unequivocal” standard of proof, rather than the “beyond a reasonable doubt” standard required in criminal court. There is no statute of limitations for pursuing a civil denaturalization case.
The United States government has long maintained its power to revoke citizenship for war criminals, child rapists and terrorist funders. Between 1990 and 2017, the DOJ filed a total of 305 denaturalization cases, an average of eleven per year. That number has increased in the last decade. There were found 168 denaturalization cases filed in federal courts during President Trump’s first term in office (an average of 42 per year) and 64 during President Biden’s term (16 per year).
NATURALIZATION ACCOUNTABILITY ACT
Senator Tom Cotton (R-AR) recently introduced a bill called the Naturalization Accountability Act which subjects felons to denaturalization. If you get convicted of a felony before, during, or after going through the naturalization process to become an American citizen, you should have your citizenship revoked. Under current law, citizenship can only be revoked for actions or lies that occurred before or during the application process. Senator Cotton’s bill would expand this to include certain crimes committed after a person has already become a citizen.
Current law (INA § 340(c)) assumes that if you join a “totalitarian” or “terrorist” group within five years of naturalizing, you lied about your attachment to the Constitution. Cotton’s bill expands this indefinitely, allowing the government to strip citizenship for terror support regardless of how long the person has been a citizen.
Follow me on X @DianeLGruber
Why Is Biden Importing Military-Aged Men?
Readers: The following essay, written by a friend of mine, expresses the unease of many Americans. As hatred rages across our country, as we fund two wars, as we fund Iran’s terrorism network (including Hamas), as China flexes its military muscles, as foreigners invade our nation, Americans have reason to ask if war will come to our shores. Diane
^The deceased was Lieutenant Colonel Brandon A. Shah, age 42, who served as the department chair for military sciences and was a professor in the ROTC program. Witnesses and officials stated that Lt. Col. Shah confronted the gunman and placed himself between the shooter and his students to protect them.
After the initial shots, several ROTC cadets jumped on Jalloh to subdue him. During the struggle, one cadet reportedly fatally stabbed Jalloh with a knife, terminating the threat. In addition to the death of Lt. Col. Shah, two ROTC cadets were critically injured in the shooting. The FBI is officially investigating the shooting as an act of terrorism.
The author, Diane L. Gruber, is a First Amendment advocate who writes for Substack. She calls her Substack newsletter America First Re-Ignited. Follow me on X @DianeLGruber.
If you enjoyed this article, then please REPOST or SHARE with others; encourage them to follow AFNN. If you’d like to become a citizen contributor for AFNN, contact us at managingeditor@afnn.us. Help keep us ad-free by donating here.
Substack: American Free News Network Substack
Truth Social: @AFNN_USA
Facebook: https://m.facebook.com/afnnusa
Telegram: https://t.me/joinchat/2_-GAzcXmIRjODNh
Twitter: https://twitter.com/AfnnUsa
GETTR: https://gettr.com/user/AFNN_USA
CloutHub: @AFNN_USA
Patriot.Online: @AFNN