=cp112gnzmL&r_n=hr091.112&dbname=cp112&&sel=T OC_412336&>. H.R.2017, the Continuing Appropriations Act of 2012, introduced on May 26, 2011, became Public Law 112–33 on September 30, 2011. 74 Fourteenth Amendment (Amendment XIV) to the United States Constitution, adopted July 9, 1868, available at: <http://www.archives.gov/exhibits/charters/ constitution_amendments_11-27.html>. This provision is known as the “Citizenship Clause” or the “Naturalization Clause.” 75 The 14th Amendment Citizenship Clause is also consistent with Article 24.3 of the International Covenant on Civil and Political Rights, which guarantees the right of every child to acquire a nationality. 76 Under 8 U.S.C. § 1401, a child born abroad to two married U.S. citizen parents automatically acquires U.S. citizenship at birth so long as one of the parents resided in the U.S. prior to the birth of the child. Children born to one citizen parent and one foreign national will obtain citizenship at birth if the citizen parent resided in the U.S. for the requisite period of time before the child’s birth (the length of required residence is either five years or ten years depending on the law that was in effect on the date of the child’s birth). Children born out of wedlock to a U.S. citizen mother will be U.S. citizens if the mother resided in the United States for at least one year prior to the child’s birth. Children born out of wedlock to a U.S. citizen father do not automatically acquire U.S. citizenship but can if the father agrees in writing to financially support the child and can prove a blood relationship. As discussed previously, there are a few limited situations in which an individual may be national of the United States and not a citizen. 77 See also infra note 75. 78 1951 Refugee Convention, art. 1 A (2). (emphasis added). 79 The United States acceded to the 1967 Protocol in 1968. The 1967 Protocol to the 1951 Refugee Convention incorporates by reference all the substantive provisions of the 1951 Refugee Convention. Its primary purpose was to amend the 1951 Refugee Convention definition of refugee by removing all geographic and temporal references to World War II, thereby universalizing the refugee definition. The U.S. Supreme Court has recognized that when Congress enacted the Refugee Act of 1980, Pub. L. No. 96-212, 94 Stat. 102, it made explicit its intention to “bring United States refugee law into conformance with the 1967 United Nations Protocol Relating to the Solutions for the Stateless in the U.S. Status of Refugees”. INS v. Cardoza-Fonseca, 480 U.S. 421, 436-37 (1987) (citing H.R. Rep. No. 96-608 at 9 (1979)). 80 8 U.S.C. § 1101(a)(42) (emphasis added). The asylum provisions under U.S. law contain several references to persons with “no nationality” and such persons’ “country of last habitual residence”. See, e.g., 8 U.S.C. § 1158(c)(1)(A) regarding asylum status in general. The regulations subsequently drafted and promulgated by the U.S. Department of Justice to provide the procedures and criteria to implement the statutory requirements replace “no nationality” with the term “stateless”. See, e.g., 8 C.F.R. § 208.13(b)(2) (i)(A) (“The applicant has a fear of persecution in his or her country of nationality or, if stateless, in his or her country of last habitual residence”). 81 Of course, not all refugees are stateless and not all stateless individuals are refugees. This section refers only to cases where an individual is both stateless and seeking asylum or relate protection under U.S. law. 82 See Guerrero v. United States, 691 F. Supp. 260, 264 (D. N. Mar. I. 1988). 83 Haile v. Holder, 591 F.3d 572 (7th Cir. 2010); Mengstu v. Holder, 560 F.3d 1055, 1059 (9th Cir.2009); Stserba v. Holder, 646 F.3d 964,(6th Cir. 2011). In all three of these, the courts have sent the case back to the Board of Immigration Appeals to consider this issue. The 7th Circuit in Haile found that forced denaturalization is discrimination and remanded to the BIA for further proceedings consistent with that understanding. In the other two cases, the 6th Circuit in Stserba and the 9th Circuit in Mengstu indicated that forced denaturalization may be discrimination, and both courts remanded to the BIA for consideration in the first instance of whether there was discrimination in the particular case. Under international refugee law, where discriminatory denationalization is due to a protected ground, it would clearly satisfy the refugee definition. 84 See, e.g., Faddoul v. Immigration & Naturalization Service, 37 F.3d 185 (5th Cir. 1994); Fedosseeva v. Gonzales, 492 F.3d 840 (7th Cir. 2007); Pavlovich v. Gonzales, 476 F.3d 613 (8th Cir. 2007); Al Najjar v. Ashcroft, 257 F.3d 1262 (11th Cir. 2001). 85 8 U.S.C. §1231(b) (governing the designation of a country of removal). 86 Id. at §1231(b)(2)(A) (concerning individuals placed in removal proceedings sometime after they have been inside the U.S.). 43