By contrast, the court ruled that Peru violated Article 20 in Ivcher Bronstein v. Peru.65 Mr. Bronstein, a naturalized Peruvian citizen, had renounced his Israeli nationality. Peru denationalized him in order to block him from exercising his property rights as majority shareholder and CEO of a TV channel that had publicly spoken against the government. Once deprived of his Peruvian nationality, he became stateless. The court ruled in his favor, blocking Peru’s action.66 In the landmark decision Yean and Bosico Children v. The Dominican Republic of 2005, the court considered the case of the refusal by the Dominican civil registration authorities to register two Dominican-born girls of Haitian descent. The court stated that the link between an individual and a state can be “proved by various elements considered together,” which included place of birth, place of residence, or “self-identification with the people of the said State.” In the court’s view, the “structure of their lives and their relationships are with the Dominican Republic.” Furthermore, given that the Dominican Constitution followed jus soli as the main basis for the attribution of nationality, the court rejected the use of the nationality or legal status of the parents as a basis to deprive the children of Dominican citizenship.67 The Yean and Bosico judgment also reiterated that under Article 20 of the Convention, “the fact that a person has been born on the territory of a State is the only fact that needs to be proved for the acquisition of nationality, in the case of those persons who would not have the right to another nationality if they did not acquire that of the State where they were born.”68 Therefore, the Dominican Republic has the obligation to “adopt all necessary positive measures” in order to guarantee that every child born in its territory who would otherwise be stateless acquires Dominican nationality under conditions of equality and nondiscrimination. The court described the situation in which the state placed the Yean and Bosico children as one of extreme vulnerability because of the impossibility of receiving protection of the state, and the denial of their nationality as discriminatory.69 In the Case of Expelled Dominicans and Haitians v. Dominican Republic of October 70 2014, the court built upon its case law, particularly with regard to the right to nationality of Dominican-born children of Haitian descent, referencing the principles the Yean and Bosico case had established. The case reviewed the September 23, 2013, decision of the Dominican Constitutional Tribunal in the case of Juliana Deguis Pierre.71 The state had stripped thousands of Dominican citizens of foreign descent of their Dominican nationality, by applying retroactively the exception to jus soli citizenship as set forth in the 2010 Constitution, which denied nationality to children born to undocumented parents in the country’s territory. The Constitutional Tribunal ordered the government to review birth registries and establish a process to implement the decision. In May 2014 in response to international pressure, the Dominican Republic enacted Law 16914, which established a special regime of naturalization for those affected by the ruling. BORN IN THE AMERICAS 33