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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