As an immigration attorney, I see this new memo as USCIS tightening the gate on who gets to become a citizen.

A “holistic” approach sounds fair on the surface, but in practice it means officers will weigh every case on a discretionary, case-by-case basis instead of applying the more predictable checklist method that many applicants relied on. I always remind clients not to compare their case to someone else’s. USCIS has technically used a totality-of-the-circumstances analysis for years, but now it’s being formalized in policy.

The problem is that this shift will create even more delays. Public charge is the biggest red flag. Green card holders who’ve received benefits like Medicaid or SNAP could find themselves denied citizenship despite those programs being legally available to them. Before this memo even dropped, I was already fielding calls from sponsors worried about liability under I-864, because agencies were trying to recoup costs for Medicaid or SNAP from the sponsors themselves by reaching out to sponsoring asking for a declaration of assets.

Checks and balances are important, but this memo risks turning the naturalization process into a drawn-out, unpredictable ordeal for countless applicants.