determined that several aspects of the law contravened international human rights standards. According to the Court, “Law No. 169 represented an impediment to the full exercise of the right to nationality of the victims. In this regard, it violated the obligation to adopt domestic legal provisions, in relation to the rights to juridical personality, to a name, and to nationality…and owing to the violation of these rights taken as a whole, the right to identity, and the right to equal protection of the law.”57 In response to these findings, the Dominican Republic not only failed to make substantive changes to the law in order to comply with its international human rights obligations, but instead the Dominican Constitutional Court issued a decision attempting to nullify the Court’s jurisdiction58, although this decision itself violates international law. V. Human rights violations resulting from the Dominican Republic’s nationality laws and their implementation A. Shortcomings in the implementation of Law 169-14 23. During the preparation of this submission, numerous civil society organizations acknowledged that Law 169-14 does provide a potential, although limited and fundamentally flawed, way to address the large-scale statelessness generated by TC/0168/13. These organizations then expressed concern that the Dominican Republic had conflated a human rights issue, the right to a nationality for those born on Dominican territory, with one of migration and naturalization, which can be more politically contentious, logistically challenging, and potentially xenophobic. Thus, instead of providing a solution to the mass denationalization created by TC/0168/13, the implementation of Law 169-14 by the JCE instead generated a series of obstacles for both people initially registered in the Civil Registry (Group A) and those born in the country but not registered (Group B) to overcome.59 24. One of the most significant concerns expressed by civil society organizations was that persons born in the Dominican Republic who comprise Group B would have to register as foreigners in their country of birth and nationality, only to later apply for Dominican citizenship through an uncertain naturalization process.60 This requirement is especially problematic given the historical discrimination practiced and individual discretion exercised by officials in charge of the Civil Registry. In its 2015 Country Report, the Inter-American Commission on Human Rights (“IACHR”) observed that the most frequently reported human rights problem in the Dominican Republic related to the authorities’ refusal to issue birth certificates, which appeared in 1,360 cases, and noted that the four most frequently reported issues all related to structural problems around the right to a nationality for individuals of Haitian descent.61 During the implementation of Law 169-14, 57 Inter-American Court of Human Rights. Case of Expelled Dominicans and Haitians v. Dominican Republic. Official Summary. 28 August 2014. http://corteidh.or.cr/docs/casos/articulos/resumen_282_ing.pdf. 58 Romero, Argénida. TC declara inconstitucional vinculación de República Dominicana a CIDH. Diario Libre. 5 de noviembre de 2014. https://www.diariolibre.com/noticias/tc-declara-inconstitucional-vinculacin-de-repblica-dominicana-a-cidh-KGDL867841. 59 El Congreso Nacional en Nombre de la República. “Ley No. 169-14.” Congreso Nacional. Consideración Octavo. https://presidencia.gob.do/themes/custom/presidency/docs/gobplan/gobplan-15/Ley-No-169-14.pdf. 60 Estado del arte de las migraciones que atañen a la República Dominicana: 2014. 61 Inter-American Commission on Human Rights. Situation of Human Rights in the Dominican Republic. Country Report: Dominican Republic. (31 December 2015). http://www.oas.org/en/iachr/reports/pdfs/DominicanRepublic-2015.pdf. 10