practice at that time of marking passport applications as “filed without action”—effectively denying them but without taking a formal decision and thus evading judicial review.584 This practice was challenged successfully in Castelano v. Clinton, a class action that resulted in a class-wide settlement and the issuance of passports to all 15 plaintiffs.585 Numbers. Because the Department of State does not keep comprehensive centralized records of the number of passport revocations requested and granted, and on which grounds, determining how many individuals are affected by a given practice involves a time-consuming search of administrative records. In the case of the DOS-OIG investigation into passport seizures in Yemen, a full review of all cases was not even possible.586 Estimates supplied by the State Department to congressional offices suggest that the average annual number of recorded revocations on the basis of non-citizenship or identity fraud is in the hundreds.587 One attorney in Texas who has litigated passport cases for the past 10 years estimated that he alone had handled 200 lawsuits and assisted more than 1,000 clients with responding to the department’s heightened vetting of passport applications.588 The Justice Initiative’s review of existing court cases identified 69 post-January 1, 2017 civil actions in which claimants sought to confirm their citizenship following a passport denial or revocation or denial of citizenship, a 64.5% increase over the equivalent pre-2017 period. This figure represents only those instances in which claimants were able to lodge federal cases, which requires significant resources that many people living in the region simply do not have. Births attended by a midwife. The Castelano litigation resulted in a 2009 settlement stipulating certain measures that the State Department would take in “suspicious birth attendant” (SBA) cases.589 One of the attorneys representing the class discussed in a June 2017 article what she has learned about the potential breadth of such cases in South Texas: The “suspicious midwife list” which the INS had used for years was only the beginning. The State Department has its own list, the “suspicious birth attendant” list, which it considers to be protected by the law enforcement privilege and which has many more names than the one used by INS (now U.S. Citizenship and Immigration Services (USCIS)), which is in the public domain. Under the Castelano settlement, it was clear that the list was to be comprised only of midwives, or other “birth attendants,” and not medical doctors. But it has been learned that the DOS has included some licensed physicians on the list. For example, a recently deceased obstetrician, Dr. J.H. Trevino, who practiced in the Rio Grande Valley for about 60 years and delivered over 15,000 babies, is on the list. Why? Because in one of those 15,000 cases, the DOS allegedly discovered an affidavit from a Mexican doctor asserting that he had birthed the child. For those familiar with cross-border issues, the first thought that comes to mind is: “So what?”590 III. Denial and revocation of documentation of U.S. citizenship 127