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 persons. 148 These States force stateless individuals into refugee determination procedures. 149 These procedures often treat stateless persons as other irregular migrants; as a result, their vulnerabilities and need for special protection are ignored. 150 For example, in the Netherlands, applicants are required to show official evidence to support their claim that they cannot return to the country, which is difficult when an applicant is unable to obtain official evidence. 151 In Sweden, officials take a strict approach on proving identity, which is an even greater burden on stateless individuals who often do not have access to birth certificates or government identification. 152 Greece appears to provide the least protection of all States, as it refuses to grant permits to persons who are unable to leave the country. 153 Another country with a terrible reputation regarding their treatment of stateless individuals is Australia. 154 When Australia was asked by the UNHCR how many stateless people were within its borders, Australia answered there were zero. 155 However, after some investigating, information emerged that there were 37 stateless people being held by the Australian government in immigration detention, on average for more than two-and-a-half years. 156 Some people, like Said Imasi, have been in immigration detention for over nine years. 157 Under Australia’s current legal framework, he could—theoretically—be incarcerated for the rest of his life because the Australian government refuses to release him from detention or grant him a protection visa.158 Many other stateless individuals have been detained indefinitely in immigration detention as well as in offshore centers on Nauru and Manus Islands. 159 Further, Australia does not have a procedure for 148. Katia Bianchini, Not a Level Playing Field — Statelessness Determination in the EU, EUROPEAN NETWORK ON STATELESSNESS (July 20, 2017), https://www.statelessness.eu/blog/not-level-playing-field-statelessnessdetermination-eu [https://perma.cc/QKV3-R6VY]. 149. Id. 150. Id. 151. Id. 152. Id. 153. Id. 154. U.N. High Comm’r for Refugees, Inquiry into the Australian Citizenship Amendment (Citizenship Cessation) Bill 2019, ¶ 3 (Oct. 14, 2019). 155. Doherty, supra note 47. 156. Id. 157. Id. 158. Id. 159. Id. 374

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