38.2 (7) TEMPROSA.DOCX38.2 (7) TEMPROSA.DOCX (DO NOT DELETE) 280 BERKELEY JOURNAL OF INTERNATIONAL LAW 1/16/2021 12:59 PM [Vol. 38:2 study ascertained trends in the denaturalization of naturalized US citizens, denial and revocation of passports, and political attacks on citizenship by birth of children born in the United States to non-citizens. 264 While it is not possible to conclusively state that passport denials and revocations have increased recently,265 in comparison with previous administrations, denaturalization rose in the first two years of the Trump administration. 266 Nearly three times as many civil denaturalization cases (29.5 per year) were filed than the average of the eight previous administrations (12 per year). Criminal denaturalization cases have also increased in 2017 and 2018. 267 It is believed that a significant portion of the denaturalizations "have or will result in statelessness," 268 and suggests a "selective targeting based on national origin, as a proxy for race, ethnicity, and religion, and contributes to the overall charge that the administration is seeking to exclude immigrants and citizens because of its nativist ideology." 269 Efforts to redefine jus soli citizenship may also be considered as a practice that threatens the security of citizenship by birth. 270 New analyses of citizenship laws in Europe, the Americas, and Asia also reveal discrimination and inequalities between and among different kinds of citizens. 271 The cases and examples provided above show that while it is possible for States to uphold a person's citizenship to avoid statelessness based on the letter of the law, such is not always the case and inequality still persists within States when dealing with issues of citizenship and statelessness. Significantly, the formalism of the law is used as a subterfuge. The Ideology of Discretionism In Part I.D.2, I discussed that through State privilege and gaze, the State could constitute polities—create and uncreate the status of people. The State has the primary privilege to grant and revoke citizenship. The definition of statelessness retains the partiality towards State gaze predominant in the early half of the 264. See generally LAURA BINGHAM & NATASHA ARNPRIESTER, UNMAKING AMERICANS: INSECURE CITIZENSHIP IN THE UNITED STATES (2019). 265. Id. at 12. 266. Id. at 10. 267. Id. 268. Id. at 11. 269. Id. 270. Id. at 13. 271. Olivier Vonk et al., "Benchmarking" Legal Protection against Statelessness, in SOLVING STATELESSNESS 163, 187 (Laura van Waas & Melanie Khanna eds., 2017). This study concluded many nationality laws in the Americas discriminate between categories of nationals. This type of discrimination is less pronounced, but is also present in Europe. The study looked at seventy-six countries. For a study of the laws in Asia, see Olivier Vonk, Comparative Report: Citizenship in Asia (2017), http://cadmus.eui.eu/handle/1814/50047 (last visited May 2, 2019).