Appeals Court Upholds Denaturalization of Human Rights Violator and Former Bosnian Soldier Convicted of War Crimes

The Justice Department announced today that the Ninth Circuit Court of Appeals has affirmed the decision of the U.S. District Court for the District of Oregon that revoked the naturalized U.S. citizenship of a convicted Bosnian war criminal. Sammy Yetisen hid from immigration officials that she had engaged in human rights violations and war crimes in Bosnia, including the deaths of several civilians and prisoners of war.

Yetisen was born in a town in the former Yugoslavia. When the Yugoslav republics began seceding in the 1990s, Yetisen joined the Army of the Republic of Bosnia and Herzegovina, which was formed by the newly independent Bosnian state, as part of a special forces detachment known as the Zulfikar Unit. The unit was renowned as elite and was particularly cruel, often beating, sexually assaulting, burning, and cutting prisoners. As a member of the Zulfikar Unit, Yetisen participated in the Trusina Massacre, a horrific attack on April 13, 1993, in which Yetisen and others lined up six unarmed Croat prisoners of war and civilians and executed them by firing squad.

“The United States is not a safe haven for individuals who commit war crimes and human rights abuses around the globe,” said Assistant Attorney General Brett A. Shumate of the Justice Department’s Civil Division. “If you come to this country and hide those acts in your past to become a U.S. citizen, the Justice Department will discover the truth and come after you.”

In 1996, Yetisen came to the United States as a refugee, after alleging she had been persecuted as a Muslim, and in 2001, Yetisen applied for naturalization. Throughout her immigration proceedings Yetisen omitted her service in the Zulfikar Unit and participation in extrajudicial killings. She became a U.S. citizen in 2002.

In 2009, the Bosnia and Herzegovina Prosecutor’s Office issued a warrant for Yetisen’s arrest, alleging that she had committed war crimes against civilians and prisoners of war. The United States extradited Yetisen to Bosnia in 2011 where Yetisen pleaded guilty to committing war crimes and was sentenced in 2012 to five-and-a-half-years in prison. After completing her sentence, Yetisen returned to the United States.

In 2018, the Justice Department filed a complaint in the U.S. District Court for the District of Oregon seeking Yetisen’s denaturalization based on her crimes and failure to disclose them. In 2023, the court entered an order revoking Yetisen’s citizenship. On July 21, the Ninth Circuit affirmed the District of Oregon’s revocation of Yetisen’s U.S. citizenship.

This case was investigated by U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations Human Rights Violator and War Crimes Center and the Civil Division’s Office of Immigration Litigation with consultation and support from ICE’s Office of the Principal Legal Advisor, Seattle Office of the Chief Counsel, and U.S. Citizenship and Immigration Service’s Office of Chief Counsel, Western Law Division. The Justice Department’s Office of International Affairs also provided substantial assistance to secure the 2011 extradition of Yetisen to Bosnia and Herzegovina.

The case was jointly prosecuted by Senior Litigation Counsels Devin Barrett and Steven Platt, and Trial Attorney Nancy Pham with review from Senior Litigation Counsel Max Weintraub of OIL ‒ General Litigation and Appeals Section, Affirmative Litigation Unit and support from Assistant U.S. Attorney Dianne Schweiner for the District of Oregon.