Latin American Research Review 597 The JCE was the perfect agency to blame. Even before Circular 017 and Resolución 122007 were introduced, established procedures had effectively restricted identity documentation for Dominico-Haitians. The JCE was also notorious for issuing decisions without notice to those affected (Hartlyn 1990), a common practice of organizations that engage in administrative obstructionism. Additionally, after Roberto Rosario (president of the JCE from 2010 to 2016) took exclusionary practices a step further, it became more convenient to shift blame down the bureaucratic chain of command.14 The hoops that victims of discrimination had to jump through to successfully restore their rights, including trying to identify themselves to JCE officials after their identity documents had been invalidated, deterred many from even trying to appeal their case. Administrative obstructionism employed fully: 2010–2015 Administrative obstructionism emerged in full force in the 2010–2015 period. Marking the start of this era was a new Dominican constitution, which stated explicitly that the children of migrants “illegally residing in Dominican territory” were excluded from jus soli– based nationality going forward (República Dominicana 2010, Artículo 18). But because it did not cover tens of thousands of people born in the DR before 2010, other, more underhanded means were developed to retroactively exclude them. The single most egregious development came in September 2013, when the Constitutional Court issued a ruling (168-2013) in the case of Juliana Deguis Pierre, which established that the principle of undocumented migrants being permanently “in transit” would apply retroactively, since the 1929 Constitution (Tribunal Constitucional de la República Dominicana 2013). In other words, the court applied the “in transit” clause of the 2010 Constitutional amendment to Pierre and thousands of others born in the DR to bar them from Dominican nationality due to the undocumented status of their parents. Consequently, any Dominican-born descendant of migrants (since 1929), even with proof of birth in the DR, lost citizenship. Going back eighty-four years, the ruling affected some four generations of people. Thus it included not just the first-generation descendants of Haitian migrants but thousands of Dominican-born children of Dominican citizens thereafter. The retroactive nature of this judgment instantly created the largest population of stateless people (estimates of up to two hundred thousand) in the western hemisphere. Resolution 168-2013 (La Sentencia) generated a dramatic spike in international media attention. This was the bright-line event that activated domestic and international opposition. Following the lead of the domestic human rights community, the United Nations High Commissioner for Refugees (UNHCR) and IACHR condemned it. Expats formed solidarity groups and began mobilizing protest movements, such as the We Are All Dominican movement in the United States. Legal scholars at leading US universities and human rights institutions published highly critical reports (De Vos 2013; Alrabe et al. 2013). The Caribbean Community (CARICOM) suspended the DR’s application for membership (Human Rights Watch 2015, 8). Prominent international organizations such as Robert F. Kennedy Human Rights provided support to Dominican NGOs such as the Movement of Dominican-Haitian Women (MUDHA) and Reconoci.do. In turn, domestic NGOs served as an essential link between the community and international human rights bodies. Their roles have included providing insight into victims’ daily struggles and bringing their voices to the international stage. However, sustaining, much less expanding, the ranks of domestic activists proved difficult. A poll conducted in the DR by Gallup-Hoy in 2014 revealed that 62 percent of all respondents thought that La Sentencia was not anti-Haitian in nature, and 40 percent 14 According to a well-placed anonymous source, it was Rosario’s ties to the Leonel Fernández faction of the Partido de la Liberación Dominicana (PLD) that led him to tighten JCE procedures even further, with a likely motive being to prevent Haitian descendants from gaining the right to vote. https://doi.org/10.1017/lar.2022.48 Published online by Cambridge University Press