EU citizenship: Still a Fundamental Status? 17 majorities, and what might be the legitimate role of a Dutch court to set in train a series of events that might lead to a legally legitimate decision of the UK electorate being constrained in its effects? The stage could be set, therefore, for a constitutional confrontation of the highest order before the CJEU, where the limits of the CJEU’s capacity for judicial activism (or, as some might have it, legitimate protection of constitutional constraints on oppressive state action) will be tested. EU citizenship may remain very different to national citizenship, but it is possible that it has already acquired enough of its own distinctive ‘sticky’ qualities that it will come to haunt the Brexit negotiations in unexpected ways. Open Access This chapter is licensed under the terms of the Creative Commons Attribution 4.0 International License (http://creativecommons.org/licenses/by/4.0/), which permits use, sharing, adaptation, distribution and reproduction in any medium or format, as long as you give appropriate credit to the original author(s) and the source, provide a link to the Creative Commons license and indicate if changes were made. The images or other third party material in this chapter are included in the chapter’s Creative Commons license, unless indicated otherwise in a credit line to the material. If material is not included in the chapter’s Creative Commons license and your intended use is not permitted by statutory regulation or exceeds the permitted use, you will need to obtain permission directly from the copyright holder.