This is a point of contention in the Hinojosa et al. v. Horn et al. petition for writ of certiorari to the U.S. Supreme Court – does “may” actually mean “must”? Habeas corpus, like the APA, is a “remedy of last resort” and, like the APA, only provides for a limited review of the agency action. Section 1503(a) is the most straightforward remedy (foreclosed to people outside the U.S.) that allows for judicial review of the question of citizenship. (c) Application for admission to United States under certificate of identity; revision of determination A person who has been issued a certificate of identity under the provisions of subsection (b), and while in possession thereof, may apply for admission to the United States at any port of entry, and shall be subject to all the provisions of this chapter relating to the conduct of proceedings involving aliens seeking admission to the United States. A final determination by the Attorney General This provision means that even people who have been recognized as Americans for their entire lives have to apply as foreigners to enter their own country. This requirement subjects the person to administrative detention, potentially far away from the port of entry, their family members and local counsel if they have a representation. that any such person is not entitled to admission to the United States shall be subject to review by any court of competent jurisdiction in habeas corpus proceedings and not otherwise. Any person described in this section who is finally denied admission to the United States shall be subject to all the provisions of this chapter relating to aliens seeking admission to the United States.616 It is unclear: • If section 1503 (b) and (c) preclude a claim under the APA • If an individual is required to exhaust all of the steps in order to seek habeas relief • If so, whether these requirements represent an “adequate” remedy for the purposes of precluding a cause of action under the APA • If federal habeas relief is sought without application for admission at a port of entry, whether the person is “in custody” for the purposes of the habeas statute (28 U.S.C. § 2241) III. Denial and revocation of documentation of U.S. citizenship 141