590. See, e.g., Elizabeth Brodyaga, Mexican-Americans and the Southern Border: So You Think You Were Born Here? Prove It!!, 17-06 Immigr. Briefings 1 (June 2017). 591. Anthony D. Bianco, Michael A. Celone & Sherease Pratt, Defending Agency Immigration Fraud Adjudications, in 65 U.S. Attorneys’ Bulletin (July 2017), at 103, https:// www.justice.gov/usao/page/file/984701/download (directing attorneys to the Texas Department of State Health Services page posting actions for violations by midwives). 592. Rachel E. Rosenbloom, From the outside Looking in: U.S. Passports in the Borderlands, in Benjamin N. Lawrance and Jacqueline Stevens, eds., Citizenship in Question: Evidentiary Birthright and Statelessness 135 (2016). 593. See Freedom of Information Act request by Hassan Ahmad, https://www.muckrock.com/foi/united-states-of-america-10/state-department-passport-adjudication-policy-60158/ (seeking “[a]ny and all documents, emails, internal memos, external memos, cables, correspondences, directives, or any other media dated January 20, 2017 to the present containing any of the following words: 1. ‘passport adjudication’ or ‘adjudication of passports’ 2. ‘birth certificate’ 3. ‘fraudulent’ 4. ‘citizenship fraud’ 5. ‘border’ 6. ‘midwife’ or ‘midwives’). 594. Rachel E. Rosenbloom, From the outside Looking in: U.S. Passports in the Borderlands, in Benjamin N. Lawrance and Jacqueline Stevens, eds., Citizenship in Question: Evidentiary Birthright and Statelessness 165 (2016). 595. See Why has a Texas-born marine veteran been left “stateless” under U.S. immigration policies? (Democracy Now! broadcast Jan.13, 2016), https://www.kcet.org/ shows/democracy-now/why-has-a-texas-born-marineveteran-been-left-stateless-under-us-immigration. 596. Anthony D. Bianco, Michael A. Celone & Sherease Pratt, Defending Agency Immigration Fraud Adjudications, in 65 U.S. Attorneys’ Bulletin (July 2017), at 102, https:// www.justice.gov/usao/page/file/984701/download (citing authorities from the Fifth Circuit and S.D. Tex.). 597. Elizabeth Brodyaga, Mexican-Americans and the Southern Border: So You Think You Were Born Here? Prove It!!, 17-06 Immigr. Briefings 1 (June 2017) (“[W]henever there is a ‘trigger,’ such as the passport holder applying to renew the passport or to immigrate a relative, a search is made to determine whether a Mexican birth certificate exists. If so, the passport usually is revoked, even if the Mexican birth certificate was filed many years after the person was registered in Texas.”). 598. Rachel E. Rosenbloom, From the outside Looking in: U.S. Passports in the Borderlands, in Benjamin N. Lawrance and Jacqueline Stevens, eds., Citizenship in Question: Evidentiary Birthright and Statelessness 138 (2016). 599. Interview with Jaime Diez, January 2019. Interview notes on file with the Open Society Justice Initiative. 188 600. Rachel E. Rosenbloom, From the outside Looking in: U.S. Passports in the Borderlands, in Benjamin N. Lawrance and Jacqueline Stevens, eds., Citizenship in Question: Evidentiary Birthright and Statelessness 124 (2016). 601. Pseudonyms are used throughout this and other case studies in this chapter. 602. Aarti Kohli, Peter L. Markowitz & Lisa Chavez, Chief Justice Earl Warren Institute on Law and Social Policy, University of California, Berkeley School of Law, Secure Communities by the Numbers: An Analysis of Demographics and Due Process (October 2011), at 3, https://www.law. berkeley.edu/files/Secure_Communities_by_the_Numbers.pdf. 603. See David J. Bier, U.S. Citizens Targeted by ICE: U.S Citizens Targeted by Immigration and Customs Enforcement in Texas (CATO Institute, Immigration Research & Policy Brief No. 8, Aug. 29, 2018), https://www.cato.org/ publications/immigration-research-policy-brief/ us-citizens-targeted-ice-us-citizens-targeted. 604. Paige St. John & Joel Rubin, ICE Held an American Man in Custody for 1,273 days. He’s Not the Only One Who Had to Prove His Citizenship, L.A. Times (Sept. 17, 2018), https://www.latimes.com/local/lanow/la-me-citizens-ice20180427-htmlstory.html. 605. Creedle v. Miami-Dade Cty., No. 17-cv-22477, 2018 U.S. Dist. LEXIS 192708, at *3 (S.D. Fla. Nov. 9, 2018). 606. St. John & Rubin, supra note 604. 607. See supra notes 445-452 and accompanying text. 608. Proof of citizenship, Immigration Law & Family § 15:27 (2018 ed.). 609. Ramzi Kassem, Passport Revocation as Proxy Denaturalization: Examining the Yemen Cases, 82 Fordham L. Rev. 2009 (2014). 610. Petition for Writ of Certiorari at 27, Hinojosa et al. v. Horn et al. (Oct. 8, 2018). 611. Rachel E. Rosenbloom, The Citizenship Line: Rethinking Immigration Exceptionalism, 54 B.C.L. Rev. 1695, 1682 (2013) (“The starting point for any discussion of immigration exceptionalism is the plenary power doctrine.”). 612. 8 U.S.C. § 1503(a). 613. Under the 1940 Act, actions for declaration of citizenship could be instituted from abroad. Individuals bringing an action under the previous statute could submit a sworn application demonstrating good faith and substantial basis for the claim to citizenship and obtain from diplomatic or consular authorities a certificate of identity permitting admission to the United States for the duration of the proceedings. 12 A.L.R. Fed. 2d 501 § 2. UNMAKING AMERICANS