366           Fisher administrative agency, this commitment must come through executive action using existing authorities rather than new legislation. This Article proposes that the U.S. executive branch should consider statelessness as a significant, positive factor in discretionary analysis.8 This Article discusses two forms of discretion: (1) discretion in immigration benefits adjudications and (2) exercises of prosecutorial discretion in civil immigration enforcement.9 It argues that this comparatively minor, legally defensible change in administrative immigration policy can provide meaningful relief in addressing the legal uncertainty, financial hardships, lengthy immigration detention, and separation from family that many stateless people in the United States experience.10 Only legislation can provide stateless people with access to lawful permanent residence and naturalization based on a person’s statelessness.11 Even so, this proposal can provide some humanitarian relief immediately, which is critical given the small odds of legislation in the near future.12 In addition, this Article has two broader applications. First, it provides a blueprint for other jurisdictions that, like the United States, lack specialized legislation that addresses stateless people and thus rely on existing authorities to ameliorate the harms that stateless people experience. Second, current litigation threatens to sharply limit executive discretion in immigration enforcement. This Article demonstrates that, even if litigation succeeds in curbing the use of categorical programs like the Deferred Action for Childhood Arrivals (“DACA”), the executive branch can still address hardships created by U.S. immigration enforcement by examining humanitarian factors like a person’s statelessness.13 This Article draws from three strands of literature. First, a growing body of academic work analyzes the international law of 8 9 10 11 12 13 individuals-united-states. See infra Part III. There are many other forms of discretion that are exercised in immigration law, including procedural discretion, such as whether to delay proceedings or grant a change in venue. Daniel Kanstroom, Surrounding the Hole in the Doughnut: Discretion and Deference in U.S. Immigration Law, 71 Tul. L. Rev. 703, 761–63 (1997). See infra Part IV.C. See Our Mission, United Stateless, https://www.unitedstateless.org/purpose (noting that the organization’s mission includes “changes to domestic laws to introduce a path to citizenship for the stateless in the U.S.”) (last visited May 12, 2022). See infra Part I.C. See infra Part IV.A.