passport is denied or revoked are treated equally under the law: the nation’s borders play an outsized role in determining the fate of undocumented citizens. Within the United States. In order to challenge the denial or revocation of a passport directly on the grounds of U.S. citizenship, remedies differ depending on the physical location of the claimant. Individuals who are inside the United States may bring an action to challenge the outcome of the administrative agency’s decision (in this case, the U.S. Department of State) under § 1503(a) of the Immigration and Nationality Act of 1952 (INA). For individuals physically outside of the country’s borders, § 1503(a) does not apply: If any person who is within the United States claims a right or privilege as a national of the United States and is denied such right or privilege by any department or independent agency, or official thereof, upon the ground that he is not a national of the United States, such person may institute an action…against the head of such department or independent agency for a judgment declaring him [or her] to be a national of the United States.612 The 1952 Act retained this remedy from the previous Nationality Act of 1940, but eliminated its availability for those outside the United States,613 added a five-year statute of limitations (from the final administrative denial), and eliminated its availability where the issue of citizenship status arises in removal proceedings.614 The remedy in a § 1503(a) action is a declaratory judgment of citizenship (also known as a declaration of citizenship). The statute triggers a de novo review of the question of citizenship, which places the burden on the claimed citizen to produce supporting evidence. Such evidence can be impossible to obtain when the revocation occurs years or even decades after a passport was first issued. Because passports and birth certificates are not definitive proof of U.S. citizenship, should any American need confirmation of citizenship by birth on U.S. soil, an action under § 1503 is the only available recourse.615 Outside the United States. For individuals seeking legal confirmation of their citizenship from abroad, a different scheme under the INA, covered in 8 U.S.C. §§ 1503(b) and (c), provides for a more complex route to review of the central question of citizenship. Throughout that route, the individual concerned is, procedurally speaking, treated as a foreigner. III. Denial and revocation of documentation of U.S. citizenship 139