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 Stateless individuals who have failed to obtain asylum often find themselves in removal proceedings. 177 The majority of stateless individuals encountered by UNHCR in the United States have a final order of removal issued against them and have therefore spent some time in immigration detention awaiting removal from the United States. 178 Most of these individuals have experienced tremendous emotional trauma during detention; including the stress of detention itself, the removal from their daily life, transfers to different immigration detention facilities away from their homes and communities, the uncertainty of how long they will be detained since no country recognizes them, and fears about being sent to a country with which they have no connection. 179 Furthermore, the burden is on the stateless individual to pursue release from detention because there is no right to counsel provided by the government. 180 Even if a stateless individual is released, they can be subsequently detained again, even though nothing in their situation had changed. 181 The United States is not a signatory to either the 1954 Convention or the 1961 Convention. 182 However, there is room in the United States’ immigration and refugee legal framework for conferring stateless individuals a path to citizenship. 183 The United States definition of “refugee” is more expansive than the “refugee” definition provided by the 1951 Convention and Protocol Relating to the Status of Refugees (1951 Convention) in ways that are especially pertinent to stateless individuals. 184 First, unlike the definition of “refugee” in the 1951 Convention, the definition of “refugee” in the INA encompasses those who suffered persecution in the past but no longer face a threat of future persecution. 185 Therefore, a stateless individual who has suffered 177. See Citizens of Nowhere, supra note 3, at 20. 178. Id. at 25. 179. Id. 180. Polly J. Price, Stateless in the United States: Current Reality and a Future Prediction, 46 VAND. J. TRANSNAT’L L. 443, 482 (2013). 181. Citizens of Nowhere, supra note 3, at 20. 182. Corgan, supra note 18. 183. See DONALD KERWIN ET AL., STATELESSNESS IN THE UNITED STATES: A STUDY TO ESTIMATE AND PROFILE THE US STATELESS POPULATION 14 (2020). 184. Maryellen Fullerton, The Intersection of Statelessness and Refugee Protection in US Asylum Policy, 2 J. MIGRATION & HUM. SEC. 144, 149 (2014). See 8 U.S.C. § 1101(a)(42); Convention Relating to the Status of Refugees art. 1(A), July 28, 1951, 189 U.N.T.S at 137 [hereinafter 1951 Convention]. 185. Fullerton, supra note 184. See also 8 U.S.C. § 1101(a)(42); 1951 Convention, supra note 184. 377