Sana’a, Yemen, OIG-ESP-19-01, Highlights (October 2018).
543. Stranded Abroad: Shadow Report on Coercive
Interrogations and Due Process Violations in the Confiscation
or Revocation of Passports of American Citizens of Yemeni
Origin, Asian Americans Advancing Justice (the Asian Law
Caucus) and the City University of New York (CUNY)
Creating Law Enforcement Accountability & Responsibility Project (January 2016).
544. “Congress has charged the Secretary of State with
“the administration and the enforcement of ... immigration and nationality laws relating to ... the determination
of nationality of a person not in the United States.”
Chacoty v. Tillerson, 285 F. Supp. 3d 293, 298 (D.D.C. 2018)
(citing 8 U.S.C. § 1104).
545. 22 C.F.R. § 50.7(a).
Seizures at Embassy in Sana’a, Yemen, OIG-ESP-19-01, at 17
n.54 (October 2018).
550. Ramzi Kassem, Passport Revocation as Proxy
Denaturalization: Examining the Yemen Cases, 82 Fordham
L. Rev. 2099, notes 72-73 and accompanying text (2014).
551. DOS-OIG, Review of Allegations of Improper Passport
Seizures at Embassy in Sana’a, Yemen, OIG-ESP-19-01, at 9
(October 2018).
552. Id. Generally, DOS-OIG reported “difficulty in
locating information relevant to the review.”
553. Id. at 6.
554. See id. at 5 n.8 (agreement between Bureau of
Consular Affairs and Bureau of Diplomatic Security).
546. 8 U.S.C. § 1504(a). On the legal effect of a CRBA, see,
e.g., Chacoty v. Tillerson, 285 F. Supp. 3d 293, 298 (D.D.C.
2018) (“The issuance or rescission of a CRBA, however,
“affect[s] only the document and not the citizenship status
of the person.” 8 U.S.C. § 1504(a). This is because CRBAs,
like passports, do not confer citizenship; rather, they
merely provide proof of one's status as a citizen. See 22
U.S.C. § 2705.”).
555. Id. at 7-8.
547. Stranded Abroad: Shadow Report on Coercive
Interrogations and Due Process Violations in the Confiscation
or Revocation of Passports of American Citizens of Yemeni
Origin, Asian Americans Advancing Justice (the Asian Law
Caucus) and the City University of New York (CUNY)
Creating Law Enforcement Accountability & Responsibility Project (January 2016).
560. Id.
548. Stranded Abroad: Shadow Report on Coercive
Interrogations and Due Process Violations in the Confiscation
or Revocation of Passports of American Citizens of Yemeni
Origin, Asian Americans Advancing Justice (the Asian Law
Caucus) and the City University of New York (CUNY)
Creating Law Enforcement Accountability & Responsibility Project (January 2016), at 19 (“[T]he Department’s
policy is a collateral attack on citizenship because it
abrogates a right of citizenship (access to a passport) even
though citizenship itself has not been abrogated. Such
collateral attacks are explicitly forbidden in well-established judicial precedent and prior opinions of the Attorney
General, and also contradict the Department’s own
policies”) (citing specific policies); DOS-OIG, Review of
Allegations of Improper Passport Seizures at Embassy in
Sana’a, Yemen, OIG-ESP-19-01, at 19 n.2 (October 2018)
(“There were, and are, differing views in the Department
on whether the passport may be revoked in such a case on
the basis of fraud in the identity document, or whether,
because the identity document matches a certificate of
naturalization or citizenship, the passport may not be
revoked until the certificate is revoked.”) (citing 7 FAM
1153e(4) & 7 FAM 1381.2d(1) as mutually contradictory on
this question).
563. Id.
549. DOS-OIG, Review of Allegations of Improper Passport
186
556. Id.
557. Id. at 11.
558. Id. at 23.
559. Id. Highlights.
561. Ramzi Kassem, Passport Revocation as Proxy
Denaturalization: Examining the Yemen Cases, 82 Fordham
L. Rev. 2099, 2100 (2014).
562. Nisha Kapoor, Deport, Deprive, Extradite: 21st
Century Extremism 55 (2018).
564. Id.
565. Id.
566. See Rachel E. Rosenbloom, The Citizenship Line:
Rethinking Immigration Exceptionalism, 54 B.C.L. Rev. 1695
(2013).
567. Beatrice McKenzie, Birthright Citizenship Documents
Regimes in U.S. History, in Benjamin N. Lawrance and
Jacqueline Stevens, eds., Citizenship in Question:
Evidentiary Birthright and Statelessness 118 (2016).
568. Elizabeth Brodyaga, Mexican-Americans and the
Southern Border: So You Think You Were Born Here? Prove
It!!, 17-06 Immigr. Briefings 1 (June 2017).
569. 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 (2016).
570. Id.
571. Damian Paletta, Mike DeBonis & John Wagner,
UNMAKING AMERICANS
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