352 GEORGETOWN IMMIGRATION LAW JOURNAL [Vol. 29:351 in the world that considered him its national, and that none would ever take him. He was stateless, unwanted and completely without the protection of any nation. The immigration authorities were eventually forced to admit that chances for his removal were so remote that he had to be released. Mikhail lived more than a decade on supervised release from detention, surviving under varying levels of restriction placed on him by the immigration officials charged with his supervision in Houston and Los Angeles. Mikhail travelled to American Samoa on vacation in 2012, made a day trip to Western Samoa, and inadvertently executed his removal order. He spent the next year of his life stranded in American Samoa, living on the kindness of strangers and working desperately to return to his life in the mainland United States. Mikhail’s health suffered, as he toiled day-after-day sending messages around the world in hopes that someone would take up his case. It was only through tireless advocacy by Mikhail, the United Nations High Commissioner for Refugees, and a cadre of lawyers that it was possible to convince U.S. immigration authorities to exercise their humanitarian discretionary authority to permit his return to the U.S. mainland. Mikhail returned to his stateless legal limbo, threatened again by removal proceedings, detention, or worse.1 There are migrants in the United States who have no land to call home; they are stateless and they exist in a precarious legal limbo within U.S. borders. To be stateless is to have no nationality, which the U.S. Supreme Court has called “a fate of ever increasing fear and distress” that is “deplored by the international community of democracies.”2 Stateless persons are not recognized as citizens by any country, and as such, their enjoyment of fundamental human rights depends on the good faith of host countries, and their basic human security and dignity are often subject to the whims of immigration authorities. Despite this intense level of vulnerability, U.S. immigration law does not explicitly recognize statelessness, nor does it provide for humanitarian protection to relieve stateless persons of their suffering. Rather, stateless persons are treated like any other unauthorized migrants in the United States; when they are ordered removed, they are mandatorily detained while immigration officials undertake efforts to execute those orders. Such removal 1. This summary of Mikhail’s life is drawn from news reports that covered his story while he was stranded in American Samoa, and after he returned. See Stateless And Stranded On American Samoa, NAT’L PUBLIC RADIO (Oct. 7, 2012), available at http://www.npr.org/2012/10/07/162445840/statelessand-stranded-on-american-samoa; Moises Mendoza, Back from Samoa: Stateless Man Allowed Entry into US, GLOBAL POST (Feb. 16, 2013), http://www.globalpost.com/dispatch/news/regions/americas/ united-states/130215/samoa-stateless-us. 2. See Trop v. Dulles, 356 U.S. 86, 102 (1958) (holding that denationalization of U.S. citizens who had abandoned their mandatory military service was cruel and unusual punishment prohibited by the 8th Amendment of the U.S. Constitution). Electronic copy available Electronic copy availableat: at:https://ssrn.com/abstract=2796321 http://ssrn.com/abstract=2796321