84 | Report on the Situation of Human Rights in the Dominican Republic be regarded as foreigners in transit because: a) the Dominican State had allowed them to enter the country to work under a bilateral agreement between the Dominican Republic and Haiti; b) they carried a document identifying them as temporary workers, and c) under the 1939 Immigration Law, transient alien status lasted only ten days. She also disagreed with the position that the parents’ illegal status passed to their descendants, pointing out that it was not “until the 2010 Constitution that the exception to the principle of jus soli was expanded to include foreigners residing illegally in Dominican territory.” This “shows that the “transit” concept in the 1966 Constitution did not include illegal aliens.” 191 185. As for the condition of statelessness that Juliana Deguis might ultimately face, Justice Jiménez Martínez pointed out that the Court’s decision “fosters the stateless condition of petitioner Juliana Deguis, as she would have to face a proceeding; for the duration of that proceeding she would be without juridical personality and vulnerable, a situation only made worse by the fact that the petitioner does not have any ties to Haiti and is being not just denationalized but forced to become a Haitian citizen.” Finally, Justice Jiménez Martínez took issue with the Constitutional Court’s interpretation of this judgment’s reach and argued that “it violates the principle of relativity of amparo judgments, which holds that their effects are inter partes, which means that only those who have been party to the petition stand to gain or lose.” 192. 186. The Constitutional Court used the arguments it made in judgment TC/0168/13 in 16 subsequent judgments. 193 In all these cases, the petitioners, Dominicans of Haitian descent, were claiming that their rights to nationality, identity, and juridical personality had been violated. The Constitutional Court followed its own case law on the grounds that the legal arguments “must remain the same, not just in this case but in all cases in which the Central Electoral Board is being asked to issue birth, marriage, or death certificates or an identity document on the basis that the lack of these documents causes serious problems and provided the matters in question were brought before the Constitutional Court before September 23, 2013, the date on which it delivered judgment TC/0168/13.” In those 16 cases, justices Isabel Bonilla Hernández and Katia Miguelina Jiménez Martínez have repeated and even elaborated upon their dissenting votes. 4. Decree No. 327-13: National Plan to Regularize Foreigners in an irregular migratory situation 187. As judgment TC/0168/13 held that Mrs. Juliana Deguis Pierre and many other persons caught in situations that were the same or similar to hers were not entitled to Dominican nationality and were instead entitled to Haitian nationality, 191 191 192 192 193 Dominican Republic, Constitutional Court, Judgment TC/0168/13. September 23, 2013. Dominican Republic, Constitutional Court, Judgment TC/0168/13. September 23, 2013. Dominican Republic, Constitutional Court, Judgment TC/0168/13. September 23, 2013. Dominican Republic, Constitutional Court, Judgment TC/0168/13. September 23, 2013. See, Dominican Republic, Constitutional Court, judgments TC/0275/13, TC/0290/13, TC/0028/14, TC/0042/14, TC/0043/14, TC/0044/14, TC/0048/14, TC/0057/14, TC/0064/14, TC/0078/14, TC/0086/14, TC/0108/14, TC/0111/14, TC/0117/14, TC/0122/14, and TC/0309/14. Organization of American States | OAS