YALE HUMAN RIGHTS & DEVELOPMENT L.J. 2017] The Risk of Statelessness VOL. XIX 55 While states were not limited in how they regulated nationality, two regimes for nationality acquisition became prevalent.35 States often had rules by which their nationals could pass nationality to their children, known as jus sanguinis nationality acquisition.36 Some states also provided a right to nationality for persons born in the national territory, or jus soli nationality acquisition.37 States codified laws about nationality that incorporated elements of these two regimes, as well as rules about loss of nationality, and viewed themselves as completely unencumbered by international law in their efforts to create these legal orders.38 Nevertheless, in the early part of the Twentieth Century, it became evident to the international community that international law regulation of nationality acquisition would facilitate amicable interactions between states. Once the international community had identified the goal of providing guidance to nation states on nationality, it took a first step towards this achievement with the promulgation of the 1930 Convention on Certain Questions Relating to the Conflict of Nationality Laws (1930 Convention).39 While the general provisions of that early Convention were clear that nationality was a matter to be regulated by internal law,40 the Convention set forth rules about nationality with the goal of eliminating conflicts arising from various state practices.41 Even with this concerted effort to leave sovereign discretion over nationality unencumbered, this attempt to provide loose international regulation of nationality was not widely adopted and the Convention garnered only a few ratifications.42 Nationality continued to be a source of conflict between states, particularly in the sphere of diplomatic protection. There is no better example than the Nottebohm Case, which involved an attempt by Liechtenstein to vindicate the rights of a recently naturalized citizen against Guatemala before the International Court of Justice (ICJ).43 Prior to the ICJ’s decision in the Nottebohm Case, it was uncontroversial that a state would exercise diplomatic protection over one of its citizens in the face of a violation by another state of that citizen’s internationally protected rights.44 35. Id. at 282. 36. Id. 37. Id. 38. Id. 39. Convention on Certain Questions Relating to the Conflict of Nationality Law, opened for signature Apr. 13, 1930, 179 L.N.T.S. 4137. 40. Id. art. 1. 41. See Spiro, supra note 7, at 283. 42. Id. 43. Nottebohm Case (Liech. v. Guat.), Judgment, 1955 I.C.J. 4 (1955). The case involved a German citizen who moved to Guatemala in 1905 at the age of twenty-four to join his family business, and remained there without acquiring Guatemalan citizenship. Id. at 13. Early in the Second World War, Nottebohm traveled to Liechtenstein and acquired citizenship in that country, which led to the automatic relinquishment of his German citizenship. Id. at 14. In 1941, Guatemala declared war on Germany, rendered Nottebohm to the United States, and in 1949 expropriated his property as enemy alien property without compensation. Id. at 18. Nottebohm moved to Liechtenstein, which initiated proceedings before the ICJ to secure compensation for its citizen’s expropriated property. 44. See Audrey Macklin, Nottebohm Turns Sixty: Time to Retire? (unpublished manuscript) Electronic copy available at: https://ssrn.com/abstract=3111529