2015] LIFE AFTER LIMBO 353 efforts are futile in the case of stateless persons, and when they are ultimately released from detention, they are cast into a legal limbo in which they spend the rest of their lives on immigration parole, uncertain as to what their future may hold. This troubling gap in humanitarian protection has gone unaddressed in the United States for too long. Notably, U.S. lawmakers have made great strides to codify international humanitarian protections for certain at-risk migrants.3 In particular, over the last thirty-five years, the United States has incorporated international refugee law into U.S. immigration law, and created a process through which persons who demonstrate a fear of persecution abroad because of some protected characteristic may seek asylum in the United States.4 While an analogous body of international law exists for the protection of stateless persons who have no nationality under the operation of laws of any country, this body of law has never been made part of the U.S. protection framework. While some stateless persons are also refugees, and therefore may benefit from the U.S. system of asylum protection, many are not. Therefore, stateless persons— like Mikhail—are left stranded without protection under U.S. immigration law. An important development in this regard was a proposal by the U.S. Senate to establish a mechanism for the protection of stateless persons under the Immigration and Nationality Act (INA) as part of its 2013 comprehensive immigration reform bill, the Border Security, Economic Opportunity, and Immigration Modernization Act (SB 744).5 This proposed incorporation of statelessness protection into U.S. immigration law has been underreported, and its potential as a humanitarian remedy that would mitigate bureaucratic inefficiency has been underappreciated. The current ebb in the tide of reform of the U.S. immigration system provides an important moment for reflection about the recent proposal to address the problem of statelessness in the United States. This article argues that it is imperative to establish a protection mechanism for stateless persons in the United States, but that the proposed mechanism may fail to meaningfully address the statelessness problem if it is not tethered to the international protection framework. This discussion is divided into three sections. The first section provides a brief overview of the historical roots for the international protection regimes for refugees and stateless persons. It describes the overlap between the two populations and the relationship between the two governing legal regimes so as to highlight the importance of utilizing the experience of refugee protection in the project to eradicate 3. See 8 U.S.C. § 1231(b)(3). 4. Refugee Act of 1980, Pub. L. No. 96-212, 94 Stat. 102 (1980); see also 8 U.S.C. § 1158. 5. See S. 744, 113th Cong. § 3405 (2013), available at https://beta.congress.gov/bill/113thcongress/senate-bill/744/text. Electronic copy available at: https://ssrn.com/abstract=2796321