the alien has a special role in the group or is more likely to come to the attention of the persecutors making him a more likely target for persecution).”98 The more widespread and well-documented the harm, the less evidence the individual must present to prove that she would suffer harm.99 In the context of statelessness, where groups as a whole often experience the harm, it may be easiest to demonstrate that the group itself is highly disfavored and that it is likely to suffer harm. For example, the Rohingya, a religious and ethnic minority in Myanmar, have been frequently denied citizenship and face severe restrictions on their freedom of movement, religion and access to education, as well as other forms of severe treatment. F. Statelessness and the Five Protected Grounds As with any claim to refugee status, it is necessary to establish whether the individual’s well-founded fear of persecution is linked to one or more of the five protected grounds: race, religion, nationality, political opinion or membership in a particular social group. As discussed above, U.S. law requires that the Convention ground be “at least one central reason” for the persecution in order for the individual to qualify for asylum.100 The following provides practical considerations for each protected ground in the context of an asylum claim based on statelessness. 1. Race and nationality or ethnicity In many contexts, race and nationality or ethnicity is at the source of a stateless individual’s claim to asylum. Race and nationality are two separate, but often interrelated, grounds for protection. Ethnicity is generally a sub-category of either or both of these. Policies that deny individuals of a particular race or ethnicity the right to a nationality or to be registered at birth would fall into this category. This Convention ground would apply similarly to cases of forced denationalization carried out on the basis of the individual’s race, nationality, or ethnicity. At least two circuit courts, the Seventh Circuit and the Sixth Circuit, have recognized that ethnically motivated citizenship revocation that results in statelessness is persecution and may give rise to a claim for asylum.101 2. Religion Forced denationalization carried out on the basis of an individual’s religious beliefs or practices, or those attributed to her, may amount to persecution. In Haile v. Holder, the Seventh Circuit acknowledged this argument, stating, “[f]rom the correct premise that a change of citizenship incident to a change in national boundaries is not persecution per se, it does not follow that taking away a person’s citizenship because of his religion or ethnicity is not persecution.”102 3. Political Opinion A claim based on political opinion presupposes that the applicant holds, or is assumed to hold, opinions not tolerated by the authorities or society and that are critical of generally accepted policies, traditions, or Mgoian v. INS, 184 F.3d 1029, 1035 n.4 (9th Cir. 1999). Id. 100 INA § 208(b)(1)(B)(i); 8 U.S.C. § 1158(b)(1)(B)(i) (2012). 101 Stserba, 646 F.3d 964; Haile, 591 F.3d 572. 102 Haile, 591 F.3d 572 (emphasis added). 98 99 21

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