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 were detained indefinitely by the INS under IIRIRA. 269 Legal challenges to this indefinite detention were consolidated into the case Zadvydas v. Davis. 270 The Court in Zadvydas concluded that where deportation is not “reasonably foreseeable,” the INA does not authorize continued detention. 271 The Court concluded that the INA had a presumptive post-removal detention period of 6 months, after which, if the alien provides “good reason to believe that there is no significant likelihood of removal in the reasonably foreseeable future, the government must respond with evidence…to rebut [the alien’s] showing.” 272 Therefore, unless the government can show that there is significant likelihood of removing the alien, the alien must be released. 273 Repatriation agreements are a mechanism used by the United States to deport otherwise non-deportable individuals such as stateless individuals. 274 Repatriation is defined as “the act or process of restoring or returning someone of something to the country of origin, allegiance, or citizenship.” 275 In the context of United States immigration policy, repatriation agreements are diplomatic agreements between the United States and a country that previously refused to accept deportees from the U.S, in which noncitizens in the United States with an order of removal against them are forcibly returned to their country of origin.276 Countries may not deport an individual to their country of origin unless there is a repatriation agreement in place between the repatriating country and the receiving country. 277 Repatriation agreements are nothing new and their effectiveness is questionable. In 2008, the United States entered into an agreement with 269. Megan Peitzke, The Fate of “Unremovable” Aliens Before and After September 11, 2001: The Supreme Court’s Presumptive Six-Month Limit to Post-Removal-Period Detention, 30 PEPP. L. REV. ISS. 4 769, 771 (2003). 270. Id. 271. Id. (citing Zadvydas v. Davis, 533 U.S. 678, 699 (2001)). 272. Id. at 771–772. 273. Id. at 772. 274. See Price, supra note 180, at 481. 275. Repatriation, MERRIAM-WEBSTER, https://www.merriamwebster.com/dictionary/repatriation?utm_campaign=sd&utm_medium=serp&utm _source=jsonld [https://perma.cc/U4CS-H86R]. 276. See Price, supra note 180, at 481. 277. See U.N. High Commissioner for Refugees, Note on Voluntary Repatriation, Note Submitted by U.N. High Commissioner for Refugees, EC/SCP/13 (Aug. 27, 1980), https://www.unhcr.org/excom/scip/3ae68cce8/note- voluntaryrepatriation.html [https://perma.cc/CAB5-NM8Q]. 386