Ange Samma

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Born in Burkina Faso in 1997, Ange Samma came to the United States when he was a teenager. With permanent resident (Green Card) status, but without citizenship, he decided to enlist in the U.S. Army in 2018. He hoped to become a citizen quickly and further his career goals of becoming an electrical engineer.

In the Army, Samma was deployed to South Korea. There, he found that he was unable to obtain citizenship through military service as expected due to a 2017 rule change enacted during the administration of President Donald Trump. The rule change affected the 1952 Immigration and Nationality Act that provides for the expedited naturalization of non-citizens who serve honorably in the military during a period of armed conflict, regardless of their immigration status or duration of residence in the United States. According to the American Civil Liberties Union (ACLU,) "By waiving the typical requirements for naturalization, Congress intended for non-citizens to apply to naturalize almost immediately upon entering service and prior to deployment." More than 100,000 non-citizens have done just that since 9/11. 

Yet, for non-citizens like Samma, among the 10,000 serving in the Army each year, the rule change removed the protections that would have been afforded to them as U.S. citizens serving abroad. They could not rely on consular services, seek to bring family members to the United States, or vote in elections. It also meant that they were not qualified for certain military positions and promotions that were made available only to citizens.

For that reason, Samma agreed to be part of a class-action lawsuit filed by the ACLU in April 2020 challenging the 2017 policy that blocked their expedited path to citizenship. In August 2020, a federal district court certified the class and ruled in their favor. The district court determined that  the policy violated the INA by extending the authority of the Defense Department past the administrative task of determining whether a soldier has served honorably thus far in their service. When pressed, the Defense Department could provide no rationale for the new rule.

As of 2022, the case is making its way through the appeals process, but the Defense Department cannot apply the policy for members of the class, including Samma, who continues to serve on active duty in the U.S. Army and looks forward to a career as an electrical engineer and U.S. citizen.

Update: Ange Samma was able to become a U.S. citizen officially in 2020.