Case Western Reserve Journal of International Law 53 (2021) Ghosts in America: Working Towards Building a Legal Framework for Stateless Individuals in the United States determining statelessness within its legislative framework. 160 Nor does it have a specific visa for stateless individuals despite a public pledge in 2011 “committed to minimising the incidence of statelessness and to ensuring that stateless person are treated no less favourably than people with an identified nationality.” 161 Such a promise rings hollow if not supported by concrete reform. Part Three: Statelessness in the United States In Part Three, we will discuss how statelessness fits under the United States’ current immigration legal framework and the United States’ current approaches to statelessness. A) Statelessness under United States Immigration Law Individuals who are already living in the United States when they apply for protection from persecution are referred to as “asylum seekers” or “asylum applicants.” 162 In order to be granted asylum, the applicant must meet the definition of “refugee” under the Immigration and Nationality Act (INA). 163 To meet the definition of “refugee,” an asylum applicant must demonstrate that he or she is “outside any country of such person’s nationality or, in the case of a person having no nationality, is outside any country in which such person last habitually resided,” that he or she is “unwilling or unwilling to return to” and is “unable or unwilling to avail himself or herself of the protection of that country” because of “a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion.” 164 The second reference to the term “nationality” in the refugee definition specifically allows for protection of stateless individuals. 165 Because they have no nationality or cannot establish nationality, stateless individuals must demonstrate that he or she is “outside any country in which such person last 160. Michelle Foster, Jane McAdam, & Davina Wadley, Part One: The Protection of Stateless Persons in Australian Law —The Rationale for a Statelessness Determination Procedure, 40 MELBOURNE UNIV. L. REV. 401, 421 (2016). 161. Doherty, supra note 47. 162. DREE K. COLLOPY, AILA’S ASYLUM PRIMER: A PRACTICAL GUIDE TO U.S. ASYLUM LAW AND PROCEDURE 52 (Am. Immigr. Law. Ass’n 8th ed. 2019). 163. Id. 164. 8 U.S.C. § 1101(a)(42). 165. Id. 375