methods.103 An individual may have his citizenship revoked and become stateless due to his political (or imputed political) opinion, or may face harm in his place of last habitual residence for the same reason. For instance, in Ahmed v. Kesiler, the petitioner was a native of Bangladesh and a Bihari. The Biharis consider themselves to be citizens of Pakistan. After the Biharis refused Bengali citizenship, the Bengali government removed them from their homes, confiscated their property, and relocated them to resettlement camps. The Ninth Circuit held that the record compelled “the finding that Ahmed was targeted and persecuted on account of his political opinion.”104 4. Membership in a Particular Social Group As defined in UNHCR’s Particular Social Group Guidelines, “[a] particular social group is a group of persons who share a common characteristic other than their risk of being persecuted, or who are perceived as a group by society.”105 U.S. law has taken a more restrictive approach to this definition. Not only does a particular social group refer to those who share a “common, immutable characteristic . . . that the group either cannot change, or should not be required to change because it is fundamental to their individual identities or consciences,”106 but the group itself must also be “defined with particularity” and be “socially distinct,” meaning that society perceives it to be a group.107 In the case of statelessness, social group claims frequently overlap with claims on other grounds, such as race, religion, or ethnicity. Moreover, statelessness itself can be a defining characteristic.108 Importantly, though, a social group cannot be defined exclusively by the fact that it is targeted for persecution.109 G. Practical Considerations 1. Posture of the Claim: Affirmative, Defensive, or Motion to Reopen Claims for asylum based on statelessness may be raised either affirmatively before U.S. Citizenship and Immigration Services (USCIS) or defensively before the Executive Office for Immigration Review (EOIR). However, where a person became stateless after the adjudication of her original claim, or there was otherwise a failure to raise the issue of statelessness in a prior claim for asylum, the fact of statelessness may be raised for the first time in support of a motion to reopen the underlying asylum claim. Motions to reopen are discussed in detail in Section 8 below. 2. Verifying Statelessness and Asylum Procedures UNHCR, GUIDELINES ON INTERNATIONAL PROTECTION NO. 8: CHILD ASYLUM CLAIMS UNDER ARTICLES 1(A)2 AND OF THE 1951 CONVENTION AND/OR 1967 PROTOCOL RELATING TO THE STATUS OF REFUGEES at ¶45 (Dec. 2009). 103 1(F) Ahmed v. Kesiler, 504 F.3d 1183 (9th Cir. 2007). UNHCR, GUIDELINES ON INTERNATIONAL PROTECTION NO. 2: “MEMBERSHIP OF A PARTICULAR SOCIAL GROUP” WITHIN THE CONTEXT OF ARTICLE 1A(2) OF THE 1951 CONVENTION AND/OR ITS 1967 PROTOCOL RELATING TO THE STATUS OF REFUGEES at ¶11 (May 7, 2002). 106 Matter of Acosta, 19 I&N Dec. at 233-34. 107 Matter of M-E-V-G-, 26 I&N Dec. 277 (BIA 2014). 108 In BA and Others, the UK Asylum and Immigration Tribunal acknowledged that “stateless Kuwaiti Bidoons” constitute a particular social group as “a collection of (mainly) stateless persons.” BA and Others (Kuwait) CG v. SSHD [2004] UK AIT 00256 (recognizing the particular social group but finding ‘race’ to be a more relevant option); see also LAMBERT, supra note 61. 109 UNHCR, GUIDELINES ON INTERNATIONAL PROTECTION, supra note 104, at ¶¶ 2, 7 (May 7, 2002). 104 105 22