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 country that made you stateless and continues to consider you stateless is to be subjected to persecution.” 197 In 2011, in Stserba v. Holder, the 6th Circuit Court of Appeals addressed the asylum claim of Lilia Stserba, a woman born in Estonia to an ethnically Russian family. 198 Stserba received her medical training in Russia but practiced medicine in Estonia. 199 After Estonia achieved independence from the Soviet Union, Stserba and her husband did not qualify for citizenship under the new Estonian law, presumably because they did not speak Estonian. 200 Consequently, they became stateless.201 Two years later, due to an electoral change, Stserba and her husband received Estonian citizenship. 202 Five years after that, Estonia stopped recognizing scientific degrees issued by Russian institutions. 203 Due to its retroactive effect, Stserba claimed that she became unable to practice medicine in Estonia. 204 Stserba claimed that the two years that she was stateless constituted persecution by the Estonian government. 205 The immigration judge denied her asylum on the grounds that Stserba regained citizenship relatively quickly and had not suffered “any adverse consequences” during the time she was stateless. 206 The BIA affirmed. 207 However, the 6th Circuit took a more nuanced approach, stating that “a person who is made stateless due to his or her membership in a protected group may have demonstrated persecution, even without proving that he or she has suffered collateral damage from the act of denationalization.” 208 The decisions in Haile and Stserba are significant in the context of statelessness in the United States legal framework because they recognize that statelessness itself can constitute severe harm, the vulnerability that accompanies being stateless, and that when the government takes actions to render an individual stateless, it should give rise to a presumption of persecution. 209 Further, these decisions 197. Haile, 591 F.3d at 574. 198. Stserba v. Holder, 646 F.3d 964, 968–69 (6th Cir. 2011). 199. Id. at 969. 200. Id. 201. Id. 202. Id. 203. Id. 204. Id. 205. Id. at 968–969. 206. Id. at 971. 207. Id. at 978–979. 208. Id. at 974 (citing Haile v. Holder, 591 F.3d 572, 574 (7th Cir. 2010)). 209. Id. 379