In 2006, a further amendment allowed for deprivation of nationality that would be, to the satisfaction of the Home Secretary, “conducive to the public good.”132 Deprivations resulting in statelessness were still not permitted. Between 2006 and 2014, the United Kingdom made increasing use of its deprivation powers, revoking citizenship of at least 373 British citizens.133 As of 2014, the Bureau of Investigative Journalism identified 15 cases of individuals deprived of nationality on national security grounds while abroad.134 According to media reports, “[t]his power has almost exclusively been used against Muslims and such decisions will confirm to many that British Muslims are second class citizens in the eyes of the government.”135 In 2014, the United Kingdom expanded its deprivation power once again, to cover denationalization leading to statelessness in the case of naturalized British citizens, if reasonable ground exists to believe the person could obtain another nationality.136 The 2014 changes do not appear to comply with the United Kingdom’s obligations under the 1961 Convention on the Reduction of Statelessness, as the Justice Initiative has argued in a legal opinion on the question.137 Prior to the 2014 amendments to the British Nationality Act (BNA), the Supreme Court decided in Secretary of State for the Home Department v. Al-Jedda that the British Nationality Act provisions prohibiting creation of statelessness precluded the Home Secretary from issuing deprivation orders in cases where the individual concerned did not possess another nationality at the time of the order.138 The legislative history of the 2014 amendments makes clear that the Home Secretary’s loss in the Al-Jedda case was the reason for the newly expanded powers. Just weeks after the amendment was enacted, the Home Secretary issued a fresh order for Mr. Al-Jedda’s denationalization. The Al-Jedda decision and subsequent contentious amendments to the BNA, according to one scholar, “speak volumes for the fact that state power is not unrestricted and that state sovereignty is limited by international obligations (the statelessness issue) and their application by (national) courts.”139 This is an optimistic, if technically correct, take on the ability of international obligations to provide meaningful redress in citizenship deprivation cases. One year after the BNA amendments, the case of Pham Minh Quang would reach the UK Supreme Court. Pham was born in Vietnam and came to the United Kingdom seeking asylum at the age of six.140 He travelled to Yemen in 2010, taking on a role as an assistant for an al-Qaeda publication and swearing allegiance to al-Qaeda in the Arab Peninsula.141 Upon his return to the United Kingdom, Pham received an order depriving him of British nationality. Deportation proceedings ensued, triggering Vietnam to deny that Pham was a Vietnamese citizen.142 His case thus presented a quandary: how did Pham become stateless and when? The Supreme Court focused on the latter question, deciding that because the deprivation order preceded Vietnam’s pronouncement that Pham was not a citizen, British authorities were not responsible for his statelessness.143 In February 2015, while his challenge to denationalization 38 UNMAKING AMERICANS