withdrew their applications or received some other treatment. It can be inferred from these figures that, between 2005 and 2010, a minimum of 461 stateless individuals remained in the United States without any lawful immigration status and no means to attain one.105 The data from ICE from January 1, 2009 to April 15, 2011 indicate that of the 12,781 people released from detention after the 90-day removal period, 16 were considered to be “stateless”, four were of an “unknown nationality”, 18 were “Soviet nationals”, and 28 were “Yugoslavian nationals”.106 The apparent inability of immigration officials to remove these individuals, combined with their inability to assign an existing nationality to them, indicates these individuals may well be stateless, although it is not possible to be certain of this. While these imperfect statistics reveal a relatively low number of stateless individuals interacting with the U.S. immigration authorities, they are significant enough to warrant the creation of specific procedures and guidance for identifying stateless individuals, recognizing their unique situation, and ensuring their protection. Until the United States has in place a uniform system for determining whether an individual is stateless and provides meaningful access to certain rights, such as permission to work, that will draw people to submit to this determination process, the stateless population in the United States will continue to remain largely hidden, as will the extent of the hardships they face, who they are, where they come from and how they arrived here, and their numbers. Furthermore, the establishment of a statelessness status determination procedure and its implementation would enable ICE to distinguish between stateless persons who cannot leave the United States and individuals who, in fact, do have a nationality or right of residence elsewhere and can return or be returned to that country. Solutions for the Stateless in the U.S. Qualitative Aspects Identified in Federal Case Law As a supplement to official immigration statistics, federal case law addressing stateless individuals in the United States may capture some of the qualitative characteristics of this population.107 Between January 1980 and August 2011, there were at least 70 federal court decisions in which the petitioner made a specific claim of statelessness and the court either agreed with that assertion or information in the case did not otherwise contradict it. Cases raising the issue of statelessness were brought in every region of the United States108 by individuals from a variety of ethnic and national backgrounds. Among these 70 court decisions, the most common backgrounds are: individuals who traveled to the United States on a Soviet passport and were unable to obtain a citizenship from one of the newly independent countries after the fall of the Soviet Union;109 individuals from the former Yugoslavia who lacked a nationality in any of the newly formed countries;110 ethnic Eritreans who had held Ethiopian nationality but were denationalized during the war or whose parents fled the conflict and were born in countries in which they were unable to acquire citizenship;111 and Palestinians born in such places as Saudi Arabia, Lebanon, Kuwait, Egypt, Gaza, and the West Bank who were unable to obtain citizenship of any State.112 There have also been individual cases, such as a stateless Armenian Christian born in Lebanon;113 an Urdu speaker from Bangladesh;114 and a man born to a Syrian Arab mother and a Kurdish father in Syria, where the law does not allow citizenship to derive from a mother but only the father.115 Although in many of these cases the issue of statelessness arose in the context of a claim for asylum or related protection, the precise legal issues they address and their outcomes vary widely. Although 70 cases over a ten-and-a-half year period is significant, the limitations of a review of published court decisions make it difficult to draw any solid 23