considered. Judges will only be able to confirm the officer’s decision or order another officer to make a new decision. If applicants have new evidence, they can re-apply, but each application has a cost. Unless the H&C application is approved, applicants can be removed from Canada. Alejandro was born in Spain during the Franco regime and fled to Latin America with his parents as a baby. He migrated to the U.S. as a youth and, because he did not have any identity documents, assumed a fraudulent identity and lived and worked there for several years. Alejandro was investigated by the U.S. authorities and detained. He was ordered to be removed from the U.S., which prompted him to travel to Canada where he submitted a claim for asylum. There he was granted a work permit and access to health care. While the Refugee Protection Division confirmed he was stateless, they found that he was not a refugee. Both his work permit and study permit were revoked when his refugee claim was rejected. He then applied for residency based on H&C grounds, but his application was also denied. He subsequently sought a judicial review of that decision which was granted. The Federal Court has returned his H&C application for redetermination on two separate occasions. During this process, Alejandro has not been able to secure work because potential employers have refused to hire him as he does not have legal status in Canada. Alejandro has been granted temporary access to health care, however, and residency in community housing. On living in community housing, Alejandro states if he did not have social housing “the only alternative I would have is to die on the street”. [Alejandro] c. Failed Pre-removal Risk Assessment (PRRA) Applications Rejected PRRA applicants may apply for a reconsideration of their case or to the Federal Court for a review of the decision. Historically, there has been a low acceptance rate (between two and three per cent)55, especially since many applicants are failed asylum-seekers. There is no automatic stay of removal after a failed refugee claim. An application to stay the removal must be made to the Federal Court. Between 2016 and August 2017, 12 PRRA applications were submitted by stateless individuals out of which nine were rejected. 2.4 “In Limbo” Facing Removal Stateless persons without any legal residency status in Canada in the removals process may be subject to lengthy detention, as they are often unable to prove their identity or obtain travel documents that would allow for their removal.56 In these cases, detention can be “prolonged and potentially indefinite”.57 The case of Paul Rooney illustrates this clearly.58 Mr. Rooney did not 55 https://www.canada.ca/en/immigration-refugees-citizenship/corporate/reports-statistics/evaluations/removal-risk-assessment- program/prra.html#toc1-2-3. 56 Brouwer, A. Statelessness in the Canadian Context: An Updated Discussion Paper. (2012), 57. 57 Ibid, p. 54. 58 Canada (Minister of Public Safety and Emergency Preparedness) v. Rooney, 2016 FC 1097. 16