Citizenship Applications Are Now Enforcement Triggers: Advising and Litigating Under AI Vetting, IRS-ICE Data Sharing, 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
Subscribe to Federal Bar Association CLE Pass...
Co-Sponsored by myLawCLE
Get this course, plus over 1,000+ of live webinars.
Learn More
Training 5 or more people?

Sign-up for a law firm subscription plan and each attorney in the firm receives free access to all CLE Programs

Program Summary

Filing an N-400 now opens three federal enforcement pipelines at once

Naturalization practice changed in 2025. USCIS issued vetting memoranda PM-602-0192 and PM-6020194. The IRS opened a taxpayer data pipeline to ICE. The DOJ's Shumate Memo directed a civil denaturalization surge. The nationwide vacatur in Dorcas and the April 2026 FBI NGI resubmission freeze reshaped pending cases. The Atlanta Vetting Center now screens applications with AI tools such as StateChat and ImmigrationOS.

The stakes compound quickly. A client files taxes with an ITIN, and the IRS-ICE memorandum of understanding exposes that record. An application clears approval, and the USCIS Vetting Center can still reopen review. 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. D.D.C. and D. Mass. injunctions constrain the data pipeline. Relief in Doe v. Trump reaches only 266 named plaintiffs.

Attendees leave with practitioner work product: client triage frameworks, pre-filing audit checklists for social media and financial records, administrative record checklists, and litigation roadmaps built on Dorcas, Wagafe v. USCIS, and Doe v. Trump. This is judgment work that no automated screening tool replaces.

Key topics to be discussed:

  • 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.
  • Expanded Criminal Checks
    Preparing clients for the April 27, 2026, FBI Next Generation Identification resubmission and the expanded criminal history disclosures it triggers in pending cases.
  • IRS-ICE Data Exposure
    Advising clients who filed with an ITIN or as nonresident aliens under the IRS-ICE memorandum of understanding and applying the IRC § 6103(i)(2) injunctions from the D.D.C. and D. Mass. that constrain ICE's use of taxpayer data.
  • Holistic Vetting Audits
    Running pre-filing audits of social media, financial records, and community interviews against the holistic vetting standard now applied by USCIS officers.
  • APA Litigation Theories
    Identifying the APA and due process theories that succeeded and failed in Dorcas, Wagafe v. USCIS, and Doe v. Trump, including why injunctive relief remains limited to named plaintiffs.
  • Denaturalization Defense Strategy
    Defending Shumate Memo cases through the Maslenjak materiality standard, the clear, convincing, and unequivocal evidence burden, and the statutory limits of 8 U.S.C. § 1451(a).

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 – Advising Naturalization Clients Under the New AI Vetting and Cross-Agency Data-Sharing Regime | 1:00pm – 2:00pm

This session equips immigration attorneys to advise N-400 clients navigating the post-2025 adjudication landscape, including USCIS policy memoranda PM-602-0192 and PM-602-0194, the aftermath of these policies due to the nationwide vacatur issued in Dorcas, the April 2026 FBI Next Generation Identification resubmission freeze, the Atlanta Vetting Center’s AI-driven screening tools, and the IRS-ICE data-sharing pipeline. Attorneys will learn how to prepare clients filing a N-400, awaiting an interview, preparation for an interview, and post-interview options to seek review.

BREAK | 2:00pm – 2:10pm

SESSION 2 – Federal Court Challenges to Algorithmic Adjudication, the IRS-ICE Data Pipeline, and Civil 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

Pending CLE Approval
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

Indiana

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

Pending CLE Approval
2 General

New York

Approved for CLE Credits
2 General

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

Pending CLE Approval
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

Pending CLE Approval
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

More CLE Webinars
Upcoming CLE Webinars
Branding for Firms: Ethics & Strategy
Branding for Firms: Ethics & Strategy Thu, July 16, 2026
Live Webcast
Using AI in Your Law Practice: A Step-by-Step Guide
Using AI in Your Law Practice: A Step-by-Step Guide Wed, July 22, 2026
On-Demand
Live Replay
iPad for Lawyers: The Complete Mobile Practice Toolkit
iPad for Lawyers: The Complete Mobile Practice Toolkit Thu, July 23, 2026
On-Demand
Live Replay