stateless
through
an
denationalization:
affirmative
they
are
now
act
of
marginalized,
outcast, excluded and they have no right to engage
in basic rights. 4 , 5
In addition, the BIA ignores its own test to
determine
whether
persecution.
revocation
The
‘denaturalization
BIA
of
has
plus’
test
citizenship
articulated
that
requires
is
a
an
additional examination of the circumstances flowing
from
the
stripping
of
citizenship
to
determine
whether they rise to the level of persecution on a
protected ground. Haile, 591 F.3d at 573 (quoting
an unpublished BIA decision). The BIA did not do so
here.
By
ignoring
Petitioners’
citizenship
and
central
is
refusing
argument
persecution,
4
to
that
the
reach
revocation
BIA
refuses
the
of
to
M. Lynch, Lives on Hold: the Human Cost of Statelessness,
Refugees
International
(February,
2005)
http://www.refintl.org/sites/default/files/LivesonHold.pdf
5
Open Society Justice Initiative Makes Statement to the
African Commission on Human and Peoples' Rights, (May 2,
2005),
http://www.soros.org/initiatives/justice/focus/equality_cit
izenship/news/africa_20050502.
26
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