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

Jesse Matthew Bless
Jesse Matthew Bless
Bless Litigation LLC

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

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.

Live Video-Broadcast: August 14, 2026

2 hour CLE

Tuition: $195.00
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Program Summary

 

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

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.

Key topics to be discussed:

  • N-400 Preparation
    Preparing clients from filing through interview and post-interview review, including pre-filing audits of social media and financial records.
  • Adjudication Freeze Triage
    Determining whether a client's N-400 is frozen, released, or unreasonably delayed under PM-6020192, PM-602-0194, and the nationwide vacatur in Dorcas.
  • 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.
  • Challenging Denials
    Identifying viable claims and building the administrative record to seek federal review of naturalization denials, from post-interview options forward.
  • 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).
  • 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.

This course is co-sponsored with myLawCLE.

Date / Time: August 14, 2026

  • 1:00 pm – 3:10 pm Eastern
  • 12:00 pm – 2:10 pm Central
  • 11:00 am – 1:10 pm Mountain
  • 10:00 am – 12:10 pm Pacific

Closed-captioning available

Speakers

Jesse Matthew Bless, Founder and Owner | Bless Litigation LLC

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

Agenda

SESSION 1 – Preparing the N-400: Client Advising from Filing Through Post-Interview Review | 1:00pm – 2:00pm

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.

BREAK | 2:00pm – 2:10pm

SESSION 2 – Litigating the Three Ds: Delay, Denial, and Denaturalization | 2:10pm – 3:10pm

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.

Credits

Alaska

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for CLE Credits
2 General

Arkansas

Approved for CLE Credits
2 General

Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 General

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 CLE Hour(s)

Delaware

Pending CLE Approval
2 General

Florida

Approved via Attorney Submission
2 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Pending CLE Approval
2 General

Hawaii

Approved for CLE Credits
2 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Pending CLE Approval
2 General

Kansas

Pending CLE Approval
2 Substantive

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 CLE Hour(s)

Maryland

No MCLE Required
2 CLE Hour(s)

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 CLE Hour(s)

Minnesota

Pending CLE Approval
2 General

Missouri

Approved for CLE Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Pending CLE Approval
2 General

North Carolina

Pending CLE Approval
2 General

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for CLE Credits
2 General

Nevada

Approved for CLE Credits
2 General

New York

Approved for CLE Credits
2 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Approved for CLE Credits
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for CLE Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 CLE Hour(s)

Tennessee

Approved for CLE Credits
2 General

Texas

Approved for CLE Credits
2 General

Utah

Pending CLE Approval
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved via Attorney Submission
2 Law & Legal Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Pending CLE Approval
2 General

West Virginia

Pending CLE Approval
2.4 General

Wyoming

Pending CLE Approval
2 General

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