Passports and certificates of citizenship should carry more weight than immigration databases, which the government has already recognized are incomplete and flawed.607 Proving U.S. citizenship in erroneous immigration enforcement cases that progress to removal proceedings presents unique challenges because of changes in access to remedies instituted since the 9/11 attacks. Individuals caught up in removal proceedings must raise the question of citizenship to a federal circuit court for a determination regarding whether further factual investigation is required. If so, the case will be remanded to the appropriate district court for a de novo hearing on the citizenship question. The additional procedures preclude the more direct route formerly available to “alien citizens”—that is, through a federal habeas petition in district court.608 Proving U.S. Citizenship: Anatomy of a Case Technical Roadmap This section focuses on statutory remedies available to obtain a final judgment that an individual is a U.S. citizen. In the United States, this is accomplished through seeking a declaration of citizenship under the Immigration and Nationality Act (§ 1503). Specific constitutional concerns arising in the recent practice of passport adjudications by the Department of State are explored in more depth in the following sections. While constitutional claims reach systemic issues in instances like the case studies described above, on an individual level due process and equal protection claims, for example, do not result in a declaration of citizenship. Ultimately, no single remedy is available to any American citizen who seeks to challenge discriminatory or arbitrary state action in the administration of proof of citizenship and confirm that they are U.S. citizens. For those who are excluded from the United States by a decision to deny or revoke a U.S. passport, it will in most cases be procedurally impossible to pursue either type of claim. Critics of the current statutory structure have referred to the situation of claimed Americans who are stranded abroad as “proxy denaturalization,”609 or “effective exile.”610 Declaratory Judgment of U.S. Citizenship (Immigration and Nationality Act) With the enactment of the 1952 Immigration and Nationality Act, borders became decisive in determining how individuals whose claim to U.S. citizenship comes under scrutiny can establish that they are, in fact, Americans. Rachel Rosenbloom identifies a “citizenship line”—a collection of legal distinctions in treatment between citizens and aliens—that runs through U.S. procedural and substantive law in relation to apportionment and adjudication of human rights. The means of establishing one’s citizenship, too, turns on access to the territory as a proxy for the citizenship line, with the state exercising its “plenary” immigration power over those claiming U.S. citizenship from abroad.611 In other words, not all people whose III. Denial and revocation of documentation of U.S. citizenship 137