2021] NATIONALITY LAWS 95 implementation practices. 46 The Citizenship Law and its implementation are “at the heart of a discriminatory system” which left not only Rohingya people but also other non-Rohingya Muslim minorities without citizenship.47 Another blatantly discriminatory instance of mass denationalization involves Dominicans of Haitian descent in the Dominican Republic. In 2010, a new Dominican constitution inscribed the already precarious citizenship status of Haitian Dominicans by providing that the children of persons “in transit or residing illegally in the Dominican territory” 48 were not considered citizens of the Dominican Republic.49 Prior to 2010, the 1929 Constitution of the Dominican Republic operated under the principle of jus soli, thus recognizing as Dominican most persons born within the territory of the country.50 In Pierre v. No. Judgment 473/2012, the Dominican Constitutional Court ruled that children of “irregular migrants” were not considered 46 Id. at 282 (“[T]he 1982 law—however discriminatory its textual provisions are according to international human rights standards—should not be regarded as the sole cause of the Rohingya problem.”). 47 IRISH CTR. FOR HUM. RTS., CRIMES AGAINST HUMANITY IN WESTERN BURMA: THE SITUATION OF THE ROHINGYA, 10 (2010); U.N. HIGH COMM’R FOR REFUGEES, STATELESSNESS AND THE ROHINGYA CRISIS 2 (Nov. 2017), https://www.refworld.org/docid/5a05b4664.html [https://perma.cc/C976-M7WT]. The authors note that approximately one million, largely Rohingya people, within the Rakhine State are stateless “due to the restrictive provisions and application of the Myanmar citizenship law which primarily confers citizenship on the basis of race.” See also Hum. Rts. Council, Rep. of the Detailed Findings of the Independent International Fact-Finding Mission on Myanmar, ¶¶ 458– 748 U.N. Doc. A/HRC/39/CRP.2 (2018) (finding that based on its overall assessment of the situation in Myanmar since 2011, and particularly in Rakhine State, the extreme levels of violence perpetrated against Rohingya people in 2016 and 2017 resulted from the “systemic oppression and persecution of the Rohingya,” including the denial of their legal status, identity, and citizenship, and followed the instigation of hatred against Rohingya people on ethnic, racial, or religious grounds). 48 CONSTITUCIÓN DE LA POLÍTICA DE LA R EPÚBLICA DOMINICANA [CONSTITUTION] Jan. 26, 2010, art. 18(3) (Dom. Rep.). 49 Ernesto Sagas & Ediberto Roman, Who Belongs: Citizenship and Statelessness in the Dominican Republic, 9 GEO. J. L. & MOD. CRITICAL RACE PERSP. 35, 35 (2017). 50 Nicia C. Mejia, Dominican Apartheid: Inside the Flawed Migration System of the Dominican Republic, 18 HARV. LATINO L. REV. 201, 202–03 (2015) (noting an exception to the principle of jus soli for those born to foreign diplomats or foreigners who were “in transit”). See also Richard T. Middleton, The Operation of the Principle of Jus Soli and its Effect on Immigrant Inclusion into a National Identity: A Constitutional Analysis of the United States and the Dominican Republic, 13 RUTGERS RACE & L. REV. 69, 70 (2011).