50 U.S.C. § 21
Section 21 · Restraint, regulation, and removal
Amended 1 time on record
Applied in 63 court decisions — leading case Harisiades v. Shaughnessy (1951)
Most recently applied in A.A.R.P. v. Trump (May 2025)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
The claim of any naturalized American citizen under the provisions of this Act [sections 1 to 6, 7 to 39, and 41 to 44 of this Appendix] shall not be denied on the ground of any presumption of expatriation which has arisen against him, under the second sentence of section 2 of the Act entitled “An Act in reference to the expatriation of citizens and their protection abroad,” approved March 2, 1907, if he shall give satisfactory evidence to the President, or the court, as the case may be, of his uninterrupted loyalty to the United States during his absence, and that he has returned to the United States, or that he, although desiring to return, has been prevented from so returning by circumstances beyond his control.
Editorial notes U.S. Code · Office of the Law Revision Counsel
References in Text
The second sentence of section 2 of the Act entitled “An Act in reference to the expatriation of citizens and their protection abroad,” approved March 2, 1907, referred to in text, is the second sentence of section 2 of act Mar. 2, 1907, ch. 2534, 34 Stat. 1228, which was classified to section 17 of Title 8, Aliens and Nationality, and which was repealed by act Oct. 14, 1940, ch. 876, title I, subch. V, §504, 54 Stat. 1172.