2013/ STA TELESS IN THE UNITED STA TES 449 persons within their territory.1 9 Further, stateless persons are not to be expelled except on "grounds of national security or public order." 20 The 1961 Convention attempted to strengthen international intervention to reduce statelessness, including a UN mandate. Among other provisions, the 1961 Convention specifies the circumstances in which contracting states should award legal status to stateless persons, including granting citizenship to persons born within their borders who would otherwise be stateless. 2 ' A related international agreement is the Convention Relating to the Status of Refugees. 22 Designed to protect persons fleeing persecution in their own countries, the Convention defines persons needing protection as well as the responsibilities of the states to which they have fled. 23 The Convention recognizes that while some refugees may not have a nationality, all bona fide asylum seekers are effectively stateless if they cannot return to the country of their nationality. 24 Refugees have a right not to be expelled or punished for illegal entry into the territory of a contracting state, as well as the right to be issued identity and travel documents. 25 The United States signed the Protocol Relating to the Status of Refugees in 1967, and later enacted legislation incorporating its key provisions. 26 In the 19. See id. art. 28 (governing travel documents under the Convention). 20. See id. art. 31 (governing expulsion under the Convention). 21. See 1961 Convention, supra note 8 (agreeing that citizenship shall be given at birth or through an application submitted to appropriate authorities). 22. See UNHCR, Advisory Opinion on the Extraterritorial Application of NonRefoulement Obligations Under the 1951 Convention Relating to the Status of Refugees and Its 1967 Protocol 2 (Jan. 26, 2007), http://www.unher.org/refworld/docid/ 45fl7ala4.html [hereinafter UNHCR Advisory Opinion] (addressing application of the 1951 Convention principle of non-refoulement to extraterritorial cases). 23. The Convention Relating to the Status of Refugees, as amended by the 1967 Protocol, defines refugee as [a person who,] owing to well-founded fear of being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion, is outside the country of his nationality and is unable or, owing to such fear, is unwilling to avail himself of the protection of that country; or who, not having a nationality and being outside the country of his former habitual residence as a result of such events, is unable or, owing to such fear, is unwilling to return to it. Convention Relating to the Status of Refugees art. 1, § A(2), July 28, 1951, 189 U.N.T.S. 137, available at http://www2.ohchr.org/english/law/refugees.htm. 24. See UNHCR Advisory Opinion, supra note 22, at 3 (noting the application of the Convention to both the stateless and any individual who cannot return to the country of his or her nationality). 25. See id. at 4 (listing rights made available through the 1951 Convention). 26. See Immigration and Nationality Act § 101(a), tit. 1, Pub. L. 101-132, 66 Stat. 163, 166 (1952) (codified as amended at 8 U.S.C. § 1101(a)(42) (2006)) (adopting the 1951 Convention's definition of refugee); Ritu Ghai, Deciphering Motive: EstablishingSexual Orientationas the "One Central Reason" for Prosecution in Asylum Claims, 43 COLUM. HUM. RTS. L. REV. 521, 530 (2012) (arguing Congress intended for