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USCIS Revives Outdated “Neighborhood Investigations” to Heighten Good Moral Character Standard

Posted by Paul Saluja | Sep 02, 2025 | 0 Comments

On August 19, 2025, U.S. Citizenship and Immigration Services (USCIS) announced that naturalization applicants will now be evaluated under a heightened good moral character (GMC) standard. According to the agency, officers must conduct a “holistic assessment of an alien's behavior, adherence to societal norms, and positive contributions that affirmatively demonstrate good moral character.”

Only three days later, on August 22, 2025, USCIS added yet another barrier: it announced the revival of “neighborhood investigations.” Under this approach, officers may scrutinize the vicinity of an applicant's residence and employment for the five years preceding the filing of the naturalization application. The agency cites INA § 335(a), which authorizes investigations to corroborate an applicant's residency, good moral character, and attachment to the U.S. Constitution as required under INA § 316.

A Policy Rooted in the Past

The concept of neighborhood investigations is not new. Between 1802 and 1981, naturalization applicants were required to produce two witnesses who could testify to their eligibility. When Congress eliminated that requirement in 1981, neighborhood investigations became the substitute. By 1991, however, the former Immigration and Naturalization Service had stopped using them, recognizing their inefficiency and limited value.

Today's revival of this dormant practice represents a sharp departure from decades of policy and will likely create unnecessary hurdles for applicants.

What the New Policy Requires

USCIS guidance now suggests that applicants may be expected to provide testimonial letters from neighbors, employers, co-workers, and business associates to demonstrate their character. If this evidence is not proactively included with the N-400, officers may request it through a Request for Evidence. While framed as “discretionary,” the guidance implies that failing to provide such letters could trigger an investigation.

Why This Matters

Historically, good moral character was judged against the standard of the “average U.S. citizen,” not by requiring applicants to demonstrate extraordinary contributions. Courts and agency guidance—including In re Mogus (1947), Petition of De Leo (1948), and Matter of Castillo-Perez (2019)—emphasized that GMC determinations should be practical, objective, and streamlined.

By contrast, the new policy introduces subjectivity and delay. Applicants who would otherwise qualify within six months may now face protracted processing, new evidentiary burdens, and intrusive inquiries.

Practical and Privacy Concerns in a Post-COVID World

The idea of neighbors serving as character witnesses feels outdated in modern America. In many suburban communities, residents commute in and out of their homes without meaningful interaction. In cities, even within apartment buildings, anonymity prevails—neighbors may barely exchange greetings, let alone possess knowledge of each other's character.

This disconnect has only grown stronger since the COVID-19 pandemic. Our society now tends to socialize more virtually than in person, with community interactions increasingly taking place through online platforms, social media, or video calls rather than over backyard fences or in local town squares. For many, their strongest social ties may be with colleagues or family members living across the country—not with the person living next door.

This raises practical questions: How will USCIS investigators gain access to apartment complexes? How reliable are neighbor assessments when shaped by personal grievances, political biases, or cultural misunderstandings? Moreover, requiring applicants to involve neighbors in their private immigration process risks unwanted disclosure and potential prejudice.

A Step Backward

Reviving neighborhood investigations is more than an administrative adjustment; it is a regressive policy choice. Rather than ensuring fairness, it complicates the naturalization process and exposes applicants to the whims of personal bias.

USCIS's renewed focus on neighbor testimony does not reflect the realities of modern American life, especially in the post-COVID era where community interactions are increasingly virtual. It burdens applicants with new hurdles and threatens to erode trust in the fairness and efficiency of the naturalization system. At its core, this policy shift risks becoming less about safeguarding integrity and more about discouraging and delaying deserving applicants.

About the Author

Paul Saluja

Paul Saluja is a distinguished legal professional with over two decades of experience serving clients across a spectrum of legal domains. Graduating from West Virginia State University in 1988 with a bachelor's degree in chemistry, he continued his academic journey at Ohio Northern University, gr...

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