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‘Good Moral Character’ and the Common Good:

Assessing Trump’s Newly Reformed Naturalization Requirement in Light of Catholic Social Teaching

By Caroline Funk
Moot Court Board
J.D. Candidate, Class of 2026

Over the last decade, 7.9 million+ individuals have become naturalized citizens of the United States.[1] In 2024 alone, the U.S. Citizenship and Immigration Services (USCIS), “welcomed 818,500 new citizens . . . during naturalization ceremonies held across in the United States and around the world.”[2]

To become a naturalized citizen, an applicant must meet essential criteria set forth in 8 USC § 1427[3] and 8 CFR § 316.2.[4] Applicants must, among other things,[5] be 18 years old, have “been lawfully admitted as a permanent resident,” and “hav[e] resided continuously within the United States from the date of application for naturalization up to the time of admission to citizenship.”[6] Critically too, applicants must “be a person of good moral character . . . and [be] favorably disposed toward the good order and happiness of the United States.”[7]

Federal law provides for unconditional and permanent bars to good moral character (“GMC”), including convictions of murder,[8] aggravated felony,[9] torture, and genocide.[10] The law also includes a “catch-all clause,” allowing officials to find that an applicant lacks GMC even without a record of a disqualifying offense.[11]

In practice, however, the catch-all clause fell into disuse, and GMC determinations became “a firm checklist” following the 1990s.[12] Findings for GMC became primarily violation-driven, turning almost exclusively on whether an applicant had committed an enumerated offense.[13] Officials effectively “equated GMC with the absence of statutory disqualifications rather than the presence of positive moral conduct and character.”[14]

This approach shifted with the Trump Administration’s issuance of PM-602-0188 on August 15, 2025.[15] The memorandum directs USCIS to restore a pre-1900s framework for evaluating GMC—a framework that “treated the [permanent] bars . . . as minimum disqualifiers, not as exclusive criteria” for GMC. [16] Under this restored framework, USCIS must return to a “holistic approach” and “account for an [applicant’s] positive attributes and not simply the absence of misconduct.” [17]

The policy specifically directs the USCIS to “review the complete history of [applicants] seeking naturalization” and to “place greater emphasis on . . . positive factors” and affirmative evidence of GMC.[18] These include: “sustained community involvement and contributions in the United States, family caregiving, responsibility, and ties in the United States, educational attainment, stable and lawful employment history . . . [and] compliance with tax obligations and financial responsibility.”[19] The memorandum also requires officials to consider rehabilitative evidence, such as “rectifying overdue child support payments or other family obligations, compliance with probation or other conditions imposed by a court, [and] community testimony from credible sources attesting to [] GMC.”[20]

Critics have expressed concern over this policy change.[21] However, when viewed through the lens of Catholic Social Teaching, the restored GMC framework reflects important teachings on human dignity and the legitimate authority of the U.S. to regulate immigration for the common good.

The Catechism of the Catholic Church teaches that “the more prosperous nations are obliged, to the extent they are able, to welcome the foreigner in search of the security and the means of livelihood which he cannot find in his country of origin [and] . . . [p]ublic authorities should see to it that the natural right is respected.”[22] At the same time, the Catechism teaches that “[p]olitical authorities, for the sake of the common good for which they are responsible, make the exercise of the right to immigrate subject to various juridical considerations, especially with regard to the immigrants’ duties toward their country of adoption.”[23] Indeed, “human society can be neither well-ordered nor prosperous unless it has some people invested with legitimate authority to preserve its institutions and to devote themselves as far as is necessary to work and care for the good of all.”[24]

These teachings highlight the balance between a nation’s moral obligation to treat immigrants with dignity and its own right to regulate citizenship in a way that promotes the common good.

The 2025 restored GMC framework reflects this balance. As the “people invested with legitimate authority to preserve its institutions,” the Trump Administration in issuing PM-602-0188 has exercised its right to impose “juridical considerations” on the naturalization process.[25] In doing so, its stated purpose is to ensure that applicants admitted to citizenship in the United States are prepared and “are worthy [to] assum[e] [its] rights and responsibilities.”[26]

Simultaneously, the comprehensive evaluation for GMC respects human dignity. By meaningfully evaluating an applicant’s positive actions, the revised policy advances a fuller understanding of GMC. A naturalization process that looks beyond a checklist of criminal activity to the “totality”[27] of an individual’s actions better reflects proper judgment of character.[28] After all, we are called to “use our judgment and use it to determine the right or wrong actions of [others].”[29] So long as officials are judging the actions of applicants to determine their eligibility to become a U.S. citizen, and not the state of their souls, that is permitted by Catholic Social Teaching, since the “latter judgment belongs only to God.” [30]

Moreover, by requiring officials to consider rehabilitative evidence, the policy affirms that applicants are not a mere product of their past failures, which again aligns with Catholic teaching on grace, forgiveness, and redemption.[31]

Overall, the reformed policy demonstrates that the common good involves both the respect of the human person, as well as “the stability and security of a just order.”[32] In its application, it is important that officials treat all applicants with dignity and that the policy be applied uniformly across all persons and cultures, consistent with the Catholic Church’s clear teaching against discrimination.[33]

 

[1] Naturalization Statistics, Citizenship Resource Center, USCIS, https://www.uscis.gov/citizenship-resource-center/naturalization-statistics (last visited Apr. 4, 2026).

[2] Id.

[3] 8 USC § 1427.

[4] 8 CFR § 316.2.

[5] Applicants for naturalization must take an English language test and a civics test. See Study for the Test, Citizenship Resource Center, USCIS, https://www.uscis.gov/citizenship/find-study-materials-and-resources/study-for-the-test (last visited Apr. 4, 2026).

[6] 8 CFR § 316.2.

[7] Id. (Emphasis added).

[8] Chapter 4 – Permanent Bars to Good Moral Character, Policy Manual, USCIS, https://www.uscis.gov/policy-manual/volume-12-part-f-chapter-4#footnote-1(last visited Apr. 4, 2026) (citing 8 CFR 316.10(b)(1)(i)).

[9] Id (citing 8 CFR 316.10(b)(1)(ii)).

[10] Id.

[11] PM-602-0188, USCIS (Aug. 15, 2022), https://www.uscis.gov/sites/default/files/document/policy-alerts/08.15.2025-Restoring_a_Good_Moral_Character_Evaluation_Standard_for_Aliens_Applying_for_Naturalization-Policy_Memorandum_FINAL.pdf (last visited Apr. 4, 2026).

[12] Id.

[13] Id.

[14] Id.

[15] Id.

[16] Id.

[17] Id.

[18] Id.

[19] Id.

[20] Id.

[21] Jarvis DeBerry, The Trump administration’s worrisome new focus on this group’s ‘good moral character’, MS NOW (Aug. 20, 2025), https://www.ms.now/opinion/msnbc-opinion/trump-uscis-citizenship-moral-character-rcna225846/.

[22] Catechism of the Catholic Church § 2241.

[23] Id.

[24] Catechism of the Catholic Church § 1897.

[25] Id; Catechism of the Catholic Church § 2241.

[26] Id.

[27] Id.

[28] Catechism of the Catholic Church § 1777 (“Moral conscience, present at the heart of the person, enjoins him at the appropriate moment to do good and to avoid evil. It also judges particular choices, approving those that are good and denouncing those that are evil.”).

[29] Dr. Edward Sri, Is It Loving to Judge, ASCENSION (Feb. 8, 2022), https://ascensionpress.com/blogs/podcasts/is-it-loving-to-judge?srsltid=AfmBOorjTxLLFGHMwhHK0V08DpSjWNMNKrXRmlV7U5rFxSskpGzapBXX (discussing the difference between judging others and using good judgment).

[30] Jim Blackburn, It’s Okay for Catholic to Judge, Catholic Answers (Nov. 19, 2021), https://www.catholic.com/magazine/online-edition/judge-not-2 (citing John 5:22-30).

[31] Catechism of the Catholic Church §§ 1988-1989 (“Moved by grace, man turns toward God and away from sin, thus accepting forgiveness and righteousness from on high.”).

[32] The Catechism of the Catholic Church §§ 1907-1908.

[33] The Catechism of the Catholic Church § 1935.

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