explanation of previously unobtainable evidence that is in dispute. Zhao, 265 F.3d at 95-97. 2. The BIA failed to consider revocation of citizenship as a persecutory event that constitutes a change in country conditions Revocation of citizenship, especially when it results in a person having no nationality at all, has long been considered by U.S. courts to be a grave human rights violation. The Supreme Court has characterized denationalization as a “total destruction of the individual’s status in organized society” and is “a form of punishment more primitive than torture.” Trop v. Dulles, 356 U.S. 86, 101-102 Appeals has sanction” (1958). called and The Sixth Circuit denationalization inherently “troubling.” an Court of “extreme Stserba v. Holder, 2011 WL 1901546 (C.A.6) (May 20, 2011). The Seventh Circuit Court of Appeals stated that to be made stateless, even if no further harm will come to the individual, still amounts to persecution. Haile v. Holder, 591 F.3d 572, 574 (7th Cir. 2010) 21

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