fas.org/sgp/crs/homesec/R44038.pdf 314. Jordan, supra note 309. 315. Asian Americans Advancing Justice, Keep the Path to Citizenship Open – Tell USCIS to Reject the Proposed Changes to Fee Waiver Eligibility, https://advancingjustice. salsalabs.org/protectfeewaivers/index.html?eType=EmailBlastContent&eId=2f3d730d-4301-4987-9f79-c172046c706c&sl_tc=feewaiveremail 316. See e.g., Carlotta Mohamed, LIC Clinic Helps Immigrants Apply for Citizenship, Times Ledger News (Aug. 8, 2018), https://www.timesledger.com/stories/2018/31/ naturalizationclinic_2018_08_03_q.html (“there is now a general feeling of fear about becoming denaturalized, since it’s a risky time to apply for citizenship”). 317. John Ganz, Trump’s New Target in the Politics of Fear: Citizenship, N.Y. Times, July 23, 2018, https://www. nytimes.com/2018/07/23/opinion/trump-birthright-citizenship-mccarthy.html. 318. INA § 340(d); 8 USC § 1451(d). 319. Nikki Marquez & Eric Cohen, Denaturalization – Understanding the Process and Recent Increases in Denaturalization Efforts, ILRC, at 10 (Dec. 2018), https://www.ilrc. org/sites/default/files/resources/denaturalization_und_ prcs_rcnt_effrts-20181221.pdf. 320. 8 USC § 1451(d) (emphasis added). 321. USCIS, Policy Manual Part L, Chapter 3 – Effects of Revocation of Naturalization, C(1)-(2), https://www.uscis. gov/policy-manual/volume-12-part-l-chapter-3#footnotelink-3. 322. Nikki Marquez & Eric Cohen, supra note 319, at 11. 323. Sanders v. Clark, 76 F. Supp. 489, 491 (E.D. Pa. 1948). 324. U.S. ex rel. Harrington v. Schlotfeldt, 136 F.2d 935, 939 (7th Cir. 1943). 325. U.S. Immigration and Customs Enforcement (ICE), Office of Investigations, Denaturalization Investigations Handbook, OI HB 08-01, at 11 (Jan. 15, 2008), https:// www.unicornriot.ninja/wp-content/uploads/2018/02/ Denaturalization-full-hsi.pdf. In its FOIA request, the Justice Initiative sought information regarding the number of derivative citizens whose citizenship had been revoked every year since 1948, along with any policies pertaining to the practice of revoking derivative citizenship. Only the Civil Division complied with its requirement to respond to the request, but stated that it “does not maintain…records regarding derivatives.” Email from Civil Division, Feb. 25, 2019 (on file with the Open Society Justice Initiative). 326. Interview notes on file with the Open Society Justice Initiative. 176 327. See, e.g., INA § 101(a)(23) (“‘naturalization’ means the conferring of nationality . . . on a person after birth, by any means whatsoever”). 328. 1954 United Nations Convention relating to the Status of Stateless Persons, Article 1(1). 329. UN News, “12 million” Stateless People Globally, Warns UNHCR Chief in Call to States for Decisive Action (Nov. 12, 2018), https://news.un.org/en/story/2018/11/1025561; Institute on Statelessness and Inclusion, Statelessness in Numbers: 2018 – An Overview and Analysis of Global Statistics, https://www.institutesi.org/ISI_statistics_analysis_2018.pdf. 330. Due to a lack of reliable, comprehensive data on stateless individuals in the United States, this number is undetermined. UNHCR & Open Society Justice Initiative, Citizens of Nowhere: Solutions for the Stateless in the U.S., at 1 (Dec. 2012), https://www.opensocietyfoundations.org/ sites/default/files/citizens-of-nowhere-solutions-for-thestateless-in-the-us-20121213.pdf. 331. See UNHCR & Open Society Justice Initiative, Citizens of Nowhere: Solutions for the Stateless in the U.S., at 23 (Dec. 2012), https://www.unhcr.org/en-us/about-us/ background/56fbfcea4/citizens-of-nowhere-solutionsfor-the-stateless-in-the-us.html. Because the U.S. Constitution and subsequently enacted laws on acquisition by birth are generally inclusive, the laws of the United States do not “create” stateless individuals and the jus soli provision of the Fourteenth Amendment in particular ensures that statelessness is not passed from one generation to the next for children born in the United States. 332. See 12 USCIS, Policy Manual Part H, Children of U.S. Citizens, Chapter 3 – United States Citizens at Birth (INA 301 and 309) (June 6, 2019), https://www.uscis.gov/policy-manual/volume-12-part-h-chapter-3#footnote-4 (“Until the Act of October 10, 1978, persons who had acquired U.S. citizenship through birth outside of the United States to one U.S. citizen parent had to meet certain physical presence requirements to retain their citizenship. This legislation eliminated retention requirements for persons who were born after October 10, 1952. There may be cases where a person who was born before that date, and therefore subject to the retention requirements, may have failed to retain citizenship.”). In Rogers v. Bellei, 401 U.S. 815 (1971), the Supreme Court upheld distinctions between citizens born in the United States and citizens born abroad to American parents on the ground that the Fourteenth Amendment’s Citizenship Clause only covers citizens born or naturalized in the United States. Id. at 830. 333. See UNHCR, Handbook on Protection of Stateless Persons (2014). 334. See World Bank, 1.1 Billion ‘Invisible’ People without ID are Priority for new High Level Advisory Council on Identification for Development, Press Release (Oct. 12, UNMAKING AMERICANS