Voluntary renunciation. Some individuals formally renounce their citizenship, a voluntary act to relinquish ties with their country of nationality. Individuals who renounce any other nationality become mono-citizens in the United States. For naturalized U.S. citizens in this situation, denaturalization would make them stateless. Discrimination. Discrimination in nationality laws is one of the largest causes of statelessness.335 For example, members of minority ethnic or religious groups stripped of their nationality, or women who lose their nationality upon marriage to a foreign spouse, are vulnerable to statelessness if they have naturalized as Americans and are subsequently denaturalized. DENATIONALIZATION AND PROTECTION FROM STATELESSNESS Temesgen Haile, an Ethiopian of Eritrean ethnicity, fled to the United States when the Ethiopian government began arbitrarily expelling 75,000 persons of Eritrean ethnicity in 1998. He sought asylum based on his fear that he too would be stripped of his citizenship by the Ethiopian authorities. His claim was denied by the immigration judge and the Board of Immigration Appeals based on the conclusion that forced denationalization without additional harm is not persecution. On appeal, the circuit court ruled that in some circumstances forced denationalization could constitute persecution. “If Ethiopia denationalized [him] because of his Eritrean ethnicity, it did so because of hostility to Eritreans....To be deported to the country that made you stateless and continues to consider you stateless is to be subjected to persecution.” (Haile v. Holder, 591 F.3d 572 (7th Cir. 2010)). II. Denaturalization: A Radical Measure in the Hands of Zealots 79