available, which is why the use of this radical step is meant to be carefully circumscribed by law. However, such limitations have not completely prevented the creation of statelessness, including by the United States. Based on data reviewed by the Justice Initiative, the use of this extreme measure continues to give rise to new stateless people trapped in legal limbo in the United States. This section first looks at statelessness in the U.S., then at the causal link between denaturalization and statelessness, before examining the hazards of statelessness and the people most at risk of becoming stateless as a result of the current operation of the denaturalization statutes. Statelessness in the United States Statelessness is both a reflection and a product of an international political system based on sovereign states. Millions of people living today—and many millions more throughout modern history—have no nationality. Nationality in this sense means the legal bond between an individual and a state. Around the world, nationality is acquired or granted in three ways: • at birth, by descent/parentage (jus sanguinis, Latin for “blood”); • at birth, by birth on a country’s territory (jus soli, Latin for “soil”); • after birth, by way of naturalization (outside the U.S., the terms “registration” or nationality “by option” may be used).327 Statelessness is defined in international law. A stateless person is someone who is not considered to be a national by any state under the operation of its law.328 Some people are born stateless; others become stateless. Whether someone is stateless or not is a mixed question of fact and law, meaning that simply reading another country’s nationality laws is insufficient to determine how they apply in a particular case. The true number of stateless people living today is unknown, though estimates range between 12 to 15 million.329 An undetermined number of these individuals live in the United States, without access to a lawful status or to essential rights and protections.330 Citizens of Nowhere: Solutions for the Stateless in the U.S. (2012), a report by the United Nations High Commissioner for Refugees (UNHCR) and the Open Society Justice Initiative, scrutinized 70 U.S. court decisions where the issue of statelessness arose and identified the most common causes of statelessness in the U.S. The most common situations were: • Citizens of former Soviet satellite states who did not obtain citizenship in a newly independent state following the break-up of the Soviet Union. • Ethnic Eritreans who were denationalized by Ethiopia during the Eritrea-Ethiopia war and were unable to acquire another nationality. • Palestinians unable to obtain nationality in their state of birth (including Lebanon, Kuwait, Egypt, or Saudi Arabia) or any other state.331 II. Denaturalization: A Radical Measure in the Hands of Zealots 77