38.2 (7) TEMPROSA.DOCX38.2 (7) TEMPROSA.DOCX (DO NOT DELETE) 2020] STATELESSNESS AS RHETORIC 1/16/2021 12:59 PM 279 citizenship, enabling her to run for public office as a Senator. 252 The court enthused over a "disputable presumption that things have happened according to the ordinary course of nature and the ordinary habits of life." 253 The Supreme Court was willing to assume citizenship based on the fact that things happen the way they do ordinarily, for example a baby with Filipino features who was abandoned in a province in the Philippines likely had Filipino parents, and therefore, birthright citizenship. 254 States view citizenship as the normal and statelessness as the abnormal. 255 States do not afford complete rights to all people. 256 In its intervention in AS (Guinea) before the UK Court of Appeal, the UNHCR admitted that the assumption of the binary of statelessness and citizenship in international law leaves individuals in limbo, deprived of substantive nation-State protection. 257 For one, States may choose not to accord citizenship-related rights to persons possessing formal citizenship. 258 In the Introduction of this Article, I demonstrated that States chose not to protect Hoda Muthana and Shamima Begum and treat them as citizens based on national security interests. 259 States can deliberately provide citizens with access to only a subset of citizenship-related rights, or even grant certain citizens no political rights at all. 260 Further, according to Laura van Waas and Sangita Jaghai, not everyone admitted as a citizen enjoys the full package of attached rights; citizens may still suffer from insecure citizenship status. 261 For example, citizenship by birth is typically more secure than acquired citizenship. 262 Withdrawal of citizenship occurs more frequently for naturalized citizens. 263 In the United States, a recent 252. Poe-Llamanzares v. COMELEC, G.R. Nos. 221697 & 221698-700, Republic of the Philippines: Supreme Court, Mar. 8 2016, https://www.lawphil.net/judjuris/juri2016/mar2016/gr_221697_2016.html (last visited May 2, 2019). I am not arguing that this case was wrongly decided on a point of domestic law. I reference this case merely to illustrate the premise of States' assumptions of citizenship. Though such a presumption may enable citizenship rights to be honored and attenuates a person's burden of proof to prove citizenship, it works against an applicant trying to prove statelessness. 253. Id. 254. Id. 255. See Rudolf Graupner, Statelessness as a Consequence of the Change of Sovereignty over Territory after the Last War, in THE PROBLEM OF STATELESSNESS 27, 29 (World Jewish Congress ed., 1944). 256. See David Weissbrodt & Michael Divine, Unequal Access to Human Rights: The Categories of Noncitizenship, 19(8) CITIZENSHIP STUD. 870 (2015). 257. UNHCR Submission in AS (Guinea), supra note 206, ¶ 16. 258. For an illustration, see Leti Volpp, Citizenship Undone, 75 FORDHAM L. REV. 2579 (2007). 259. See supra note 12 and accompanying text. 260. ELIZABETH COHEN, SEMI-CITIZENSHIP IN DEMOCRATIC POLITICS 6 (2009). 261. See Laura van Waas & Sangita Jaghai, All Citizens are Created Equal, but Some are More Equal Than Others, 65 NETH. INT'L L. REV. 413 (2018). 262. Id. 263. Id.