Akron Law Review, Vol. 57 [2025], Iss. 1, Art. 2 80 AKRON LAW R EVIEW [57:49 newborns. Despite widespread literature on birth registration in low- and middle-income countries, 174 no such data exists in the United States. 175 This Article has demonstrated that at least some people born in the United States do not have their births registered as newborns, and without official documentation of the facts of their birth, they experience significant exclusion. The U.S. birth registration system demonstrates dual-concurrence federalism, in which a person must have documentation of their birth from the state and concurrence from federal agencies to be recognized as a U.S. citizen. A federal court noted in 1961: that citizenship of the United States is a very precious thing; that naturalborn citizens very frequently have a great deal of difficulty in proving their status due to uncertainties of birth records and that this circumstance should not lead to a lack of stability of citizenship because, if it did, many a legitimate citizen of the United States would find himself deprived of it. 176 Perhaps sixty years later, it is a small few rather than “many” a citizen that experiences these hardships, but the resulting deprivation that the individual faces is likely more acute because of the prevalence of birth registration in the United States. The first step for a person who lacks birth registration to secure “stability of citizenship” will be to apply to state authorities to register their births through delayed processes. 177 These processes are governed 174. See, e.g., Jazmine Hesham Elmolla, Birth Registration in Crisis: Exploring a Rights-Based Approach to Birth Registration through the Experience of Syrian Refugees, 31 INT’L J. R EFUGEE L. 541 (Dec. 2019), https://doi-org.libproxy.law.umich.edu/10.1093/ijrl/eez043; Cyril Bennouna, Brooke Feldman, Rahmadi Usman, Rama Adiputra, Santi Kusumaningrum, and Lindsay Stark, Using the Three Delays Model to Examine Civil Registration Barriers in Indonesia, 11 PLoS ONE e0168405 (2016) doi:10.1371/journal. pone.0168405. https://journals.plos.org/plosone/ article?id=10.1371/journal.pone.0168405 [https://perma.cc/ZHQ9-M5BN]; Amiya Bhatia, Nancy Krieger, Jason Becfield, Aluisio Barros, and Cesar Victora, Are Inequities Decreasing? Birth Registration for Children under Five in Low-Income and Middle-Income Countries, 1999–2016, BMJ GLOBAL HEALTH 4:e00192 (2019) https://gh.bmj.com/content/bmjgh/4/6/e001926.full.pdf [https://perma.cc/MU2J-5WDG]; Andrea Wendt, Franciele Hellwig, Ghada E. Saad, Cheikh Fate, Ties Boerma, Aluisio J.D. Barros, and Cesar G. Victora, Birth Registration Coverage According to the Sex of the Head of Household: An Analysis of National Surveys from 93 Low- and Middle-income Countries, 22 BMC P UBLIC HEALTH, 1942 (2022), https://bmcpublichealth.biomedcentral.com/ articles/10.1186/s12889-022-14325-z [https://perma.cc/89YQ-NZVG]. 175. The most recent available studies on the completeness of birth registration in the United States are from 1934 and 1950. Sam Shapiro & Joseph Schachter, Birth Registration Completeness United States, 1950, 67 P UBLIC HEALTH R EPS. (1896-1970) 513 (1952), https://doi.org/10.2307/4588130; P. K. Whelpton, The Completeness of Birth Registration in the United States, 29 J. AM. S TAT. ASS’N 125 (1934). 176. Liacakos v. Kennedy, 195 F. Supp. 630, 634 (D.D.C. 1961). 177. United States government agencies such as the Department of State may challenge the U.S. citizenship of children with delayed birth registration, particularly those “born to noncitizen parents, https://ideaexchange.uakron.edu/akronlawreview/vol57/iss1/2 32