YALE HUMAN RIGHTS & DEVELOPMENT L.J. 2017] The Risk of Statelessness VOL. XIX 69 civil registry offices should suspend birth certificates with irregularities, and that the JCE would initiate proceedings for the nullification of these documents in appropriate cases.144 Many people whose nationality documents were deemed to contain irregularities pursuant to Circular 017 had been registered by Haitian parents with a work permit. Persons registered in this manner had understood themselves to be Dominican, and many had been documented as such their entire lives. These people were at once told that they had been issued documentation under an erroneous interpretation of the Constitution, and that they were not Dominican. This campaign of denationalization began perhaps the most troubling chapter in recent history of the treatment by the Dominican State of this national ethnic minority. In 2010, the Dominican Republic took steps to definitively end the nationality debate by amending the nationality provision of its Constitution to guarantee nationality to all persons born in the Dominican national territory, excluding the children of “foreigners in transit or residing illegally in the Dominican territory.”145 Article 18 of the 2010 Constitution further provides that “[a]ny foreigner defined as such in the Dominican laws is considered a person in transit.”146 The effect of this provision was to provide clarity about who would have birthright nationality in the Dominican Republic, and to ensure the constitutionality of the framework set forth in the 2004 law. Nevertheless, this change did not resolve the situation of persons who had been born under the previous constitutional framework and believed themselves to be Dominican. Persons affected by the policy of denationalization began to raise legal challenges against the decisions of the JCE to seize nationality documents.147 There was a split in resolution of these cases, with some lower court judges finding that denationalization constituted a violation of the Constitution, which clearly extended birthright nationality to the children of long-term, irregular migrants.148 Other judges agreed with the Dominicans of Haitian Descent and the Compromised Right of Nationality, OPEN SOC’Y FOUNDS. 11-13 (Oct. 2010), https://www.opensocietyfoundations.org/sites/default/files/Dominican-RepublicNationality-Report-ENG-20110805.pdf [https://perma.cc/D66U-FHSP] [hereinafter Open Society Report on the Compromised Right of Nationality] (same). 144. JCE, Resolución No. 12/2007 de fecha 10/12/07, sobre procedimiento de suspensión provisional de la expedición de Actas del Estado Civil viciadas o instrumentadas de manera irregular. [Resolution No. 12/2007 of Dec. 10, 2007, which establishes the procedure for provisionally suspending issuance of birth, marriage and death certificates that are defective or were issued improperly] (Dec. 10, 2007) (Dom. Rep.); see also 2015 IACHR Report on the Dominican Republic, supra note 111, ¶¶ 166-67 (discussing the issuance and effects of Resolution No. 12/2007); Open Society Report on the Compromised Right of Nationality, supra note supra note 143, at 13 (same). 145. 2010 CONSTITUCIÓN DE LA REPÚBLICA DOMINICANA [2010 CONSTITUTION OF THE DOMINICAN REPUBLIC], Jan. 26, 2010, art. 18. 146. Id. 147. See, e.g., TCRD, 25 septiembre 2013, Sentencia TC/0168/13. 148. See TCRD, 26 diciembre 2013, Sentencia TC/0275/13 [Judgment TC/0275/13], pp. 2-8, https://www.tribunalconstitucional.gob.do/sites/default/files//documentos/Sentencia%20 Electronic copy available at: https://ssrn.com/abstract=3111529