Case Western Reserve Journal of International Law 53 (2021) Ghosts in America: Working Towards Building a Legal Framework for Stateless Individuals in the United States severe past persecution may be able to receive protection in the United States even if they lack evidence of current or future persecutory threats. 186 Second, the United States definition requires that the persecution be linked to either race, religion, nationality, membership in a particular social group, or political opinion, 187 which are frequently the basis for hostility directed against groups that are stateless.188 Lastly, under the 1951 Convention, remaining in the country where they reside precludes an individual from refugee protection. 189 This is problematic for stateless individuals who frequently lack access to the travel documents needed to cross international borders and have no choice but to remain in the country where they are being persecuted.190 However, under the United States refugee definition, individuals who have not left their country of nationality of residence may still receive protection. 191 Despite the ways in which the United States’ refugee definition could be used to increase the likelihood of conferring asylum to stateless individuals, case law is sparse. There are two federal court opinions, in 2010 and 2011, that address claims for protection raised by stateless individuals. 192 In 2010, in Haile v. Holder, the 7th Circuit Court of Appeals examined an asylum claim of Temesgen Woldu Haile, a young man born in Ethiopia to parents of Eritrean background who fled Ethiopia when war broke out in 1998 between Ethiopia and Eritrea over territorial boundaries. 193 Both countries conducted mass deportations of thousands of citizens and residents of the “wrong” background. 194 For example, Ethiopia expulsed more than 75,000 Ethiopian citizens of Eritrean descent, rendering them stateless. 195 The Court ruled that in some circumstances, forced denaturalization could constitute persecution. 196 The Court held that “to be deported to the 186. Fullerton, supra note 184. 187. See 8 U.S.C. § 1101(a)(42). 188. See Citizens of Nowhere, supra note 3, at 13. 189. 1951 Convention, supra note 184, at art. 1(C). 190. Fullerton, supra note 184, at 150. 191. See 8 U.S.C. § 1101(a)(42) (“in the case of a person having no nationality, within the country in which such person is habitually residing, and is persecuted or has a well-founded fear of persecution…”) 192. Fullerton, supra note 184, at 150. 193. Haile v. Holder, 591 F.3d 572, 573 (7th Cir. 2010). 194. Id. 195. Fullerton, supra note 184, at 160. 196. Citizens of Nowhere, supra note 3, at 19 (citing Haile v. Holder, 591 F.3d 572, 574 (7th Cir. 2010)). 378