sole purpose is to expel (former) nationals,75 where it is discriminatory or results in the creation of statelessness, or where other indicators of arbitrariness are present, in particular a denial of due process.76 Denationalization and Expulsion – A Central Concern As described above, free black Americans’ struggle for citizenship, in the antebellum period and through the post-war amendments, was linked to freedom from expulsion.77 In the aftermath of the Holocaust and the dissolution and reconfiguration of states following World War II, with millions left stateless, an analogous alarm arose regarding the vulnerability of stateless people to banishment and extermination.78 This led the drafters of the 1948 Universal Declaration of Human Rights to include the “right to a nationality” (Article 15) as a fundamental right inherent in all people.79 That right has been incorporated into most major human rights treaties drafted in the past 70 years.80 The International Covenant on Civil and Political Rights (ICCPR),81 to which the United States is a party,82 prohibits arbitrary deprivation of an individual’s right to enter one’s “own country,” in Article 12(4).83 In its General Comment No. 27 on Freedom of Movement, the Human Rights Committee (HRC), the treaty body established to oversee implementation of the ICCPR, explained that Article 12(4) severely restricts denationalization leading to expulsion: The Committee considers that there are few, if any, circumstances in which deprivation of the right to enter one’s own country could be reasonable. A State party must not, by stripping a person of nationality or by expelling an individual to a third country, arbitrarily prevent this person from returning to his or her own country.84 A chief concern underlying Article 12 is the threat that states could, simply by declaring an individual a non-national, expel him or her and deny international responsibility, thus circumventing of the entire framework of human rights protection. The committee addressed this loophole by emphasizing that the right of return to one’s “own country” extends: [A]t the very least, [to] an individual who, because of his or her special ties to or claims in relation to a given country, cannot be considered to be a mere alien. This would be the case, for example, of nationals of a country who have there been stripped of their nationality in violation of international law . . . .85 It is widely recognized that deprivation of nationality complicates international relations by potentially forcing responsibility on a state for an individual who is not recognized by that state as its own, especially where deprivation is a prelude to expulsion and renders the person unreturnable.86 Diplomats negotiating treaties on statelessness following World War II voiced concerns regarding the implications of denationalization in international relations, noting: “A 28 UNMAKING AMERICANS