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 authorization and the spouse or child of a recipient of conditional lawful status could also qualify for conditional lawful status if they met certain criteria. 305 Then in 2013, the bipartisan Border Security, Economic Opportunity, and Immigration Modernization Act (S. 744) was introduced in Congress, which included provisions that would have incorporated stateless individuals into United States immigration law. 306 The proposal included: a legal definition of stateless person that would be incorporated into the Immigration and Nationality Act (INA); an application procedure, which includes eligibility criteria, exclusions and waivers, rules for employment authorization, and derivative beneficiaries; considerations for stateless persons to adjust status to Lawful Permanent Resident (LPR); some information about evidentiary considerations; and provisions establishing rules for administrative review, reopening proceedings, and judicial review. 307 A) A New State for the Stateless The first recommendation is the creation and addition of a new state (with a lower case “s”) in the United States for the stateless. This “51st” state would accept all stateless individuals who were not granted asylum and provide them with shelter and means of living. 308 The state would be governed by a local state government and be part of the federal United States government, the same as our current 50 states.309 The United States Constitution grants general state-creation powers to Congress in Article IV, Section 3, under the Admissions Clause. 310 The clause states, “New States may be admitted by the Congress into this Union; but no new State shall be forced or erected within the Jurisdiction of any other State; nor any State be formed by the Junction of two or more States, or Parts of States, without the Consent of the Legislatures of the States concerned as well as of the Congress.” 311 While the creation of a new state in the United States is 305. Id. 306. Corgan, supra note 18; Baluarte, supra note 20, at 353. 307. Baluarte, supra note 20, at 372. 308. See VIK SASI, WORLD REFUGEE AGENCY, FEASIBILITY STUDY: SACROSANCTUARY, A STATE FOR THE STATELESS PRELIMINARY REPORT 3 (2019). 309. See Admission of and the Rights of New States: Doctrine and Practice, ANNOTATED, CONST. https://constitution.congress.gov/browse/essay/artIV-S3-C1-1-12/ALDE_00001171/ [https://perma.cc/Q7WD-GHRB]. 310. U.S. CONST. art. IV, §3. 311. Id. 390