After the end of World War II, those who wanted their U.S. citizenship restored were generally successful at arguing before federal courts that their renunciations pursuant to the 1944 Act had been made under duress and were therefore invalid.

The law remained in effect but received little further attention until the 2000s, when a prisoner interested in renouncing U.S. citizenship won a ruling from a federal court that the U.S. was indeed in a "state of war" at the time for purposes of the 1944 Act.

[6] Under the Nationality Act of 1940 as it stood originally, renunciation of citizenship could only be performed before a United States diplomatic officer overseas.

Ennis saw the bill as crucial to the DOJ's efforts to retain custody of Japanese Americans suspected of disloyalty; he feared that the courts would find continued internment of U.S. citizens to be unconstitutional, and hoped that "militants" among Japanese American internees would voluntarily renounce citizenship under the bill's provisions, in which case the DOJ could continue to detain them until they could be deported to Japan.

[10] A number of West Coast representatives criticized it as insufficiently far-reaching for its failure to consider alleged renunciations of citizenship prior to the bill's enactment.

J. Leroy Johnson (R-CA) thus moved an amendment to the bill to allow the Attorney General to consider all statements of renunciation of citizenship as far back as October 1940.

In support, Clair Engle (D-CA) pointed to the refusal of 5,376 internees to "swear unqualified allegiance to the United States and renounce Japan" as an example of the type of alleged renunciations of citizenship which the original bill failed to consider, while Bertrand W. Gearhart (R-CA) noted that many internees who had earlier expressed enthusiasm for Japan were less vocal due to the defeats the country had suffered in battle and urged that their statements not go unpunished.

[12] He stated that "I am convinced that the method I propose, constitutional in all of its aspects, will reveal a large number of Japanese who are earnestly hoping for our defeat, secretly doing everything they can to insure a victory for our despicable foes.

"[13] However, Samuel Dickstein (D-NY), chairman of the House immigration committee, opposed Johnson's amendment, stating that Congress had no authority to revoke the citizenship of birthright citizens.

Prior to discarding citizenship, most or all of the renunciants had experienced the following misfortunes: forced removal from homes; loss of jobs; government and public assumption of disloyalty to the land of their birth based on race alone; and incarceration in a "segregation center" for "disloyal" ISSEI or NISEI...[22]Minoru Kiyota, who was among those who renounced his citizenship and swiftly came to regret the decision, has stated that he wanted only "to express my fury toward the government of the United States," for his internment and for the mental and physical duress, as well as the intimidation, he was made to face.

[23] [M]y renunciation had been an expression of momentary emotional defiance in reaction to years of persecution suffered by myself and other Japanese Americans and, in particular, to the degrading interrogation by the FBI agent at Topaz and being terrorized by the guards and gangs at Tule Lake.

[24]San Francisco attorney Wayne M. Collins helped many people who had renounced citizenship under the provisions of the 1944 Act to have the government's recognition of their renunciations reversed.

[25] However, not all renunciants sought to regain their citizenship; Joseph Kurihara, for example, chose instead to accept repatriation to Japan, and lived out the rest of his life there.

Accordingly, any attempt to renounce citizenship within the United States under the current provision, based upon the Viet Nam conflict, should be regarded as ineffectual.

"[3] In an obiter dictum in a 1970 Board of Immigration Appeals decision on the deportation case against Thomas Jolley, a North Carolina man who renounced U.S. citizenship in Toronto but later returned to the United States, Anthony Montaquila noted that "[t]he Immigration and Naturalization Service receives communications from persons in the United States imprisoned for crime who wish to renounce their citizenship, and those who wish to avoid military service.

Walton declined to grant relief, writing in his memorandum opinion that Schnitzler lacked standing to challenge the constitutionality of the statute and that USCIS had already acted on his application; with regards to Schnitzler's right to renounce his citizenship, Walton quoted the Supreme Court case Hewitt v. Helms, where it was stated that "[l]awful incarceration brings about the necessary withdrawal or limitation of many privileges and rights, a retraction justified by the considerations underlying our penal system.

[35] The ruling first disagreed that Schnitzler lacked standing to challenge the renunciation statutes, stating that as he remained a citizen against his wishes, he had grounds to seek redress against what he viewed as an injury.

[37][38] In a separate instance in 2012, Alan Horowitz, a dual citizen of the United States and Israel, also inquired with USCIS about renouncing U.S. citizenship under the Renunciation Act of 1944.

The New York Supreme Court granted Horowitz' motion for an order directing DOCCS to produce him at a USCIS office for the in-person interview.