Executive Order 12913: Revocation of Executive Order No. 12582
President: Bill Clinton
Revoked the Grenada-campaign naturalization order as void from its 1987 date after a court found its geographic limitation exceeded statutory authority.
Status: Completed/expired.
Is Executive Order 12913 still in effect? No. Completed retroactive revocation of EO 12582, while preserving completed naturalizations.
What does Executive Order 12913 do?
EO 12913 revoked EO 12582 and directed that it be treated as void from February 2, 1987. EO 12582 had attempted to limit expedited military naturalization during the Grenada period to service in specified locations. In Reyes, the Ninth Circuit held that 8 U.S.C. § 1440 authorized the President to designate time periods, not geographic areas, and found the invalid limitation inseverable. EO 12913 preserved the status of anyone already naturalized under the earlier order before publication of the revocation.
Before and after
Before the order
EO 12582 remained on the books despite the Ninth Circuit’s conclusion that its geographic restriction was invalid and inseverable.
After the order
The earlier order was formally voided retroactively, with an express protection for completed naturalizations.
Who had to do what
| Agency / office | Action | Timing / position |
|---|---|---|
| Executive branch | Treat EO 12582 as void from its signing date | After publication of EO 12913 |
| Naturalization authorities | Preserve status already granted under EO 12582 | For completed cases before publication |
What happened next
EO 12582 designated the Grenada period and limited qualifying locations.
EO 12913 formally revoked EO 12582 retroactively.
Court status
See the court documents in Sources by type.
Legal and source detail
How it works legally
Article I gives Congress power over naturalization, and § 1440 permits presidential designation of qualifying periods. The Ninth Circuit rejected a narrower geographic limitation; the savings clause protected reliance interests in completed naturalizations.
Sources by type
If a source is unavailable, first check the cited publisher or another official repository. The cited publisher remains the authority.
Primary and official sources
Orders, laws, court records and official implementation material.
- OpenJurist — Reyes v. INS, 910 F.2d 611 (opens in a new tab) Official record
How we checked this
Last checked against the sources above on September 14, 2026. How we research →