Happy Ending for Berlin Refugee Strike?

Image via Der Tagespiegel

The hunger strike of asylum seekers/ refugees at Berlin's famous Brandenberg Gate has come to an end after 8 days, following a long discussion yesterday evening between strikers and politicians. This is a highpoint but hopefully not the conclusion, of over a year of hardcore activism on refugee issues in Germany.

The protest, which followed last month's march throughout Germany, aimed in general to call attention to the plight of refugees in Germany but it also had several key specific demands (a full list can be found here.) Namely, to stop deportations, close refugee "camps" (holding facilities for asylum seekers, often in the middle of nowhere), recieve working permits and permission to learn German, and above all, to abolish the Residenzpflicht. 

Residenzpflicht is a long standing policy applying to asylum seekers that limits their freedom of movement while their asylum applications are being processed. They may not leave the administrative zone where they have first registered in Germany without a permit until their asylum status has been sorted out- which in extreme cases can take up to 10 years. Naturally, this policy keeps refugees in a sort of limbo, preventing them from fully integrating into society, traveling to visit relatives, studying at university, or finding work. This nasty law also means the state controls whether you can attend meetings or protests- limiting freedom of speech and the right to assemble.

With the recent refugee march from Wurzburg to Berlin, the refugees and their allies practiced non-violent resistence to these and similar policies, and sought to make the invisible visible.

Did it work? Der Tagespiegel reports today that the Berlin Senator for Integration Dilek Kolat and Refugee Commissioner Maria Böhmer visited the strikers and had a 4 hour discussion with them about their demands. Although the resulting quotes are basically platitudes, the politicians expressed their support of the protest and stated that they supported the desires of the protestors to learn German and start working. Böhmer apparently questioned whether the Residenzpflicht is still "up-to-date," and hinted that they would write a letter discouraging the arrest of the protestors for violating their residence restrictions by travelling to Berlin.

We'll have to keep an eye on the situation to see whether any changes are made to refugee housing, work permits, or the draconian Residenzpflicht. In the meantime, I think the protestors can cautiously celebrate a success.

Read More:
Refugees End Their Hungerstrike (Der Tagespiegel, in German)
Refugee Tent Action (The website of the Hunger Strikers)
AsylstrikeBerlin (Website with information about the refugee march and protest)
Karawane (Organization for the Rights of Refugees and Migrants)
Pro-Asyl (NGO supporting Refugees in Germany)

And finally, here's a clip from an awesome recent documentary by Denise Garcia Bergt about Germany's refugees and migrants, called "Residenzpflict."

Trailer Residenzpflicht from denisebergt on Vimeo.

New Israeli Regulation Bars Some Non-Citizens from Filing Lawsuits

Child of a migrant worker in Israel, photo via Global Post

 The Jerusalem Post reported Tuesday that the Israeli Justice Minister has signed a new regulation requiring an Israeli ID or a foreign passport number to anyone wishing to file a lawsuit. If true, this law would seem to flagrantly violate many international human rights norms by preventing stateless persons, refugees and asylum seekers from having their day in Court.

Just to refresh your memory, the 1954 Statelessness Convention, to which Israel is a signatory, touches on the topic at article 16. 

Article 16: 1. A stateless person shall have free access to the Courts of Law on the territory
of all Contracting States.
2. A stateless person shall enjoy in the Contracting State in which he has his habitual residence the same treatment as a national in matters pertaining to access to the Courts, including legal assistance and exemption from cautio judicatum solvi.

The Universal Declaration of Human Rights also discusses access to Courts in several articles (see, e.g. Art.6-10), and the sentiment of right to legal personhood is echoed continuously throughout the human rights cannon. In other words, Israel could not possibly have failed to notice that a law like this would raise eyebrows, to say the least.

When pressed, the government has responded that,

"amendments were purely technical in nature, and ensured that litigants in possession of an Israeli ID number or foreign passport specified those details on court documents so that court registrars could be certain that they were dealing with the correct individuals.

“The regulation does not alter therefore the current legal situation regarding the basic right to access the courts,” wrote Dr. Peretz Segal, head of the Justice Ministry’s Legal Counsel department. (JPost)

Hmm. So either we have a regulation that would prohibit Palestinians, who de facto do no often possess a government-issued passport, along with a host of other non-citizens, from accessing basic Court procedures, OR we have a meaningless administrative hurdle that does not change the law. If so, why pass it in the first place?

After a few days of back and forth with the government (while Israel steadily garnered increasing attention from the media for this rule, see here, here and here) the Justice Ministry has agreed to review the rule, but is sticking to the story that this does not change anything, really.

Au contraire, says the Association for Civil Rights in Israel, among others.

Attorney Oded Feller of the Association for Civil Rights in Israel warned Neeman the regulations will immediately deprive Palestinian residents of the territories, migrant workers and stateless individuals who have no passports the right to file claims in Israeli courts. ..."Technical matters become fundamental when they specify explicitly who will not be able to file claims in court."

Hopefully the negative attention this rule has attracted in advance of its debut in September will force the Israeli government to reconsider whether this is a step they really want to take. If not, I predict we will see continuing major action on the subject in the Fall. 

Greece is at it Again: Mass Deportation Raids Over the Weekend

Via FoxNews

Very depressing news from Greece in the last few days, as the government has rounded up thousands for deportation and shamelessly sought to shift blame for financial issues onto the shoulders of non-citizens.

The minister, Nikos Dendias, defended the mass detentions, saying that a failure to curb a relentless flow of immigrants into Greece would lead the country, which is surviving on foreign loans, to collapse. “Our social fabric is at risk of unraveling,” Mr. Dendias told a private television channel, Skai. “The immigration problem is perhaps even greater than the financial one.”(NYT)

 Oh, if only that were true.

Unfortunately, it is far more likely that this is a cynical move to distract from the country's actual financial problems- reliance on foreign debt, risky lending, artificial inflation- by suggesting that this is an outsider problem, caused by foreigners.

As we have discussed previously in this blog, Greece's asylum system is dangerously backed up, with asylum seekers waiting for years to get a (mandatory) interview or possibly receive refugee status if they are entitled to. With Greece being an entry point into the EU, and with the masses of refugees pouring out of countries effected by the recent tumult in the Middle East, this has meant a compounding of problems- larger numbers of people waiting larger amounts of time to have their status regularized (or, alternatively, to reach a determination that they are not refugees and may legally be deported.) This means some people have been living in Greece for years, waiting to get their status regularized.

It is understandable that the Greek government is anxious to clear up this issue. However, the solution is not to utterly disregard human rights obligations, both under EU and international human rights law, by arbitrarily deporting anyone found during mass "immigration raids" to not possess papers. Not only are some of these individuals likely to be waiting for their appointment with the immigration services, but more to the point, deporting an individual who qualifies as a refugee is refoulement, and is reprehensible and illegal. And you can't tell whether a person is a refugee by a brief glance at their papers, or lack thereof. When 6,000 people are detained over one weekend, it is hard to believe that anyone received a fair shake at a refugee status determination interview.

As history has often demonstrated, in times of economic and social strife it is tempting to rely on xenophobia and anti-immigrant sentiment as a tool of distraction. But that doesn't mean they should get away with it.

Come on, Greece, you can do better.

Previously:
Greece: The Pressure is on to Fix an Failing Asylum System
Deja Vu: Greek Immigration Crackdown

ECtHR backs deportation of settled migrant in Balogun v. UK

Yesterday the European Court of Human Rights released a disappointing decision in the case Balogun v. UK. The headline out of the case is that the UK may deport long-term settled migrants for sufficiently serious offenses without violating Article 8. Let's dig a little deeper and see what the implications of this ruling may be.

Facts: The applicant, B, is a Nigerian immigrant who was born in '86 and has been in the UK since the age of 3 (this is debated a bit, but at least since age 5.) He lived with an allegedly abusive Aunt and was granted indefinite leave to remain after being kicked out of her house, and entered the foster care system until age 18 when he began to live by himself. From then on he has a criminal record of several counts of theft and possession of controlled substances (all occurring before he reached the age of 21). After a final count of possession with intent to distribute, he was sentenced to 3 years in prison and put into deportation proceedings. He appealed on human rights ground, and the first instance court found that, since he didn't have a significant private life in the UK, his deportation was proportional to the crime.

 With regard to his private life, while it was accepted that he had been in the country since a young age and had been educated there, as well as gaining some work experience, it was not considered that these ties were sufficiently strong to render his deportation an interference with his private life. It appeared that his mother still lived in Nigeria and, even if contact had been lost, as claimed by the applicant, there was no reason why it could not be re-established. Whilst the applicant would have practical difficulties in relocating to Nigeria, he could re-establish his private life there.

Several appeals and a suicide attempt later, we end up at Strasbourg debating whether this deportation violates article 3 (prohibition against torture) or article 8 (freedom from interference with family life).

Ruling: Article 3 is thrown out for being "manifestly unfounded" and I don't care to debate that since this is not an issue involving refoulement. 

Article 8, on the other hand, is where it gets interesting. Both the applicant and the UK spend their time arguing about the nature of the applicants connections to the UK. B claims that he has a long-term girlfriend, his Aunt is like a mother to him, and he has friends and employment connections that he may utilize now that he out of jail and off of drugs. The UK meanwhile contends that B has no significant friends and family interests, at least nothing serious enough to outweigh the public interest served by deporting a threat to public order.

The Court more or less agrees. Having a girlfriend and a few scattered relatives with whom you are on bad terms does not amount to a family life (um, guys, isn't that what most families look like?) but it does make a private life. And importantly, the Court recognizes that the length of time spent in the UK, and having grown up almost exlusively in the care of UK social services means that he has significant ties to the country and will be strongly effected by deportation. However, his criminal record ultimately outweighs these considerations.

He was left at the age of three with an aunt who, according to the applicant and to social services, ill-treated the applicant. He was thrown out by this aunt at the age of fifteen and was thereafter taken into foster care. He has therefore not only spent by far the greater part of his childhood in the United Kingdom and been entirely educated in that country, but has been partly brought up in the care of the United Kingdom’s social services. These elements of the applicant’s background contribute significantly to the Court’s finding that his ties to the United Kingdom are stronger than those to Nigeria. However, while the Court views with sympathy the circumstances of the applicant’s formative years, the fact remains that he is responsible for his own actions. Particularly in light of the fact that the majority of the applicant’s offences were committed when he was already an adult, the Court finds that the applicant cannot excuse his past criminal conduct by reference to his upbringing.

 Even with the impact on his private life, the UK's deportation of B does not violate article 8.

Response: It is obvious from the slant of this blog that I would disagree with this ruling. Legally, I don't think this is a totally outrageous ruling (reasonable people can always disagree), but the underlying premise is one that I think is extremely damaging and unfair.

Someone that lived in the UK since the age of 3, and was raised more or less by the system, is a product of that country. Deporting them to Nigeria is a non-sequitor and obliterates the chance for such a troubled individual to ever lead a normal life. It punishes him for the actions of his parents or parents in moving illegally to the UK, that he could not help or influence. It punishes Nigeria by sending back a bitter individual with a criminal history that will have a hard time adjusting to a completely foreign life. It violates the individual's right to a private life, and it encourages the UK to dump problematic foreigners back to countries they have hardly any connections with.

Its a bad decision and is not justified by out-dated drug charges for which the individual has already served time. B was not a drug dealer at age 3, but became one after spending his entire childhood in the UK. This is a home-grown problem, and regardless how many criminals the UK deports, they will find new ones that they cannot.

As ever, it is my opinion that deportation is not the only, nor the best solution.

ECtHR: Case of Balogun v. the United Kingdom 

And here's a nice fear-mongering Telegraph article pushing for more deportations.

Kuwait: Is it legal to deport stateless protesters?

Image via Mideastposts.com

According to news coming in the past few days from Kuwait, a meeting assembled by the Central Agency in charge of illegal residents (bidoon/bedoon) has reached a decision following several weeks of protests by members of the community. The government will take "deterrent measures" against protesters, including layoffs, eviction, cancellation of naturalization cases and, most crucially, deportation. These measures will apparently be levied against those who participated in the protests, and those who plan to participate in the future. (if you're not raising an eyebrow now, go back and re-read that sentence.)

Although there are an estimated 100,000 bidoons in Kuwait, naturally only a portion of these participated in the protests, and an even smaller portion are currently in jail or under investigation for such participation. (Some 80, according to the AFP.) Even one person in jail for peaceful protest is too many, but symbolically these actions are even more important as instruments to intimidate the bidoon population and to discourage further shows of solidarity or discontent with their untenable situation. In recent weeks the protests have turned ugly, with riot police attacking protestors with tear gas and batons and government spokesmen claiming that the demonstrations have been incited by Iraqis and other "enemies of Kuwait."

Despite the tough talk, both supporters and non pretty much agree that the aim of the protests has always been to ensure citizenship and other basic rights for this population that has been living illegally for almost 4 decades, and of course I tend to believe that too, absent evidence to the contrary. It seems much more likely that bidoons were inspired to non-violent protest by Arab Spring than that they were foreign provocateurs trying to destabilize one of the most democratic regimes in the Middle East.

Regardless, it is worth asking now: under international human rights law, is it legal to deport non-citizens based on their participation in a protest? In other words, do non-citizens possess the right to assemble?

First, let's look to the Universal Declaration of Human Rights. Article 20(1) states "everyone has the right to freedom of peaceful assembly and association." (Other relevant provisions for this question could be articles 6, 9, 15, and 19.) A threshold question might be whether the UDHR is binding on Kuwait. My opinion is of course "yes"- as I have stated elsewhere:

"through multiple invocations in state constitutions, international law cases, and repetition in subsequent conventions, the UDHR is regarded to be of special significance and almost certainly of an instructive character in defining what is meant in the U.N. Charter by “human rights". 

I think the UDHR has special status as evidence of international customary law on human rights. (For case law on the subject, see e.g., Corfu Channel Case (Merits), ICJ Reports (1949), Iranian Naturalization Case, 60 ILR 204 at 207,  Case Concerning the United States Diplomatic and Consular Staff in Tehran, ICJ Rep 1980, 3).

Moving more to the point, can the expansive term "everyone" really mean, well, everyone? Is a state really bound to protect the rights of non-citizens, especially when it comes to expressing discontent? Again, I would say "yes." The drafters were not shy about sprinkling universalizing terms like "all" "no-one" and "everyone" throughout the UDHR, but neither were they shy about confining rights when necessary by adding modifiers like, "within their own state." Further, the Preamble states that "recognition of the inherent dignity and of the equal and inalienable rights of all members of the human family is the foundation of freedom, justice and peace in the world," a sentence that leaves little room for quibbling about territorial jurisdiciton.

We can look elsewhere for evidence that Kuwait must, under international law, respect the rights of stateless persons to peacefully assemble. The International Covenant on Civil and Political Rights (to which Kuwait is a signatory) protects freedom of association and right of peaceful assembly in articles 21 and 22 and the right also shows up in the Migrant Workers Convention and IESCR. However, these rights are proscribed by law, and Kuwait is entitled to regulate them based on national security and public order- an argument they will likely raise to support deportation.

However, the stated intent of the protests is to gain basic human rights. If this is considering a destabilizing or threatening concept to the government, what does this say about Kuwait?

Who are Kuwait's Stateless?

Source: Arabian Business

At the end of a year dominated by a profound upswing in attention to statelessness, Kuwait's stateless Bidoons (alt.  Bedoun, Bidun) have seized the day to protest an untenable situation in their country, one that has stretched almost half a century. Not being well-informed on Kuwaiti history, I would point those interested to the following sources, which I have been following to get information on the continuing protests and legal battles.

• As usual, Open Society is up on any emerging human rights issue seemingly anywhere, and thus this concise introduction to the Bidoon by blogger Sebastian Kohn is a good place to start.

• "Prisoners of the Past: Kuwaiti Bidun and the Burden of Statelessness" a recent report by Human Rights Watch, includes background and recommendations.

• Mona Kareem's blog has great coverage and links from a Kuwaiti Bidun freelance journalist/ poet.

• Lebanon's Daily Star has been following daily developments, as has Arabian Business, and to a lesser extent Al Jazeera.

• And of course, for the most up-tp-date news, you can always turn to the twitter machine: try hashtags #Kuwait, #Bidoon and naturally, #Stateless

Please feel free to leave any additional good sources in the comments. Meanwhile, I offer my solidarity to the stateless Bidoons of Kuwait, and hope that the government and the Kuwaiti people will see the light before anyone else has to get hurt.

Denmark: Points and Palestinians

Denmark's ousted Immigration Minister

For the last few weeks Denmark has been rocked by a political scandal featuring leaked documents, intrepid reporting, a shady minister and... stateless Palestinians?

That's right. Denmark, being a signatory to the 1961 Convention on the Reduction of Statelessness, is required to offer citizenship to children born in the country who would otherwise be stateless. On the contrary, it was recently revealed that a number (36, to be exact) of youngsters of Palestinian heritage had been rejected when they applied for citizenship- and that far more had never been informed about their right to become Danish.

Worse, it turns out that this human rights violation was more than just an oversight. The Immigration Minister, Birthe Hornbech, when questioned earlier in the month about her possible involvement, denied any prior knowledge of the mistake and claimed the rejections occurred under earlier administrations.  However, leaks soon made their way out that confirmed that Hornbech knew about the error- as far back as 2008- and failed to inform anyone. She even asked for and recieved legal advice that directly contradicted Denmark's procedure. Now, being forced to file a report at the prompting of a media investigation, Hornbech has been fired as the government tries to distance itself from her actions. But so long as its just an isolated incident, alls well that ends well, right?

Or, one could see this in the context of further worrying anti-immigrant developments that have been occurring in the country in the last year. For instance, in January the government announced a new point system that would make the country's already strict requirements for foreign spouses even tougher. It requires, among other things, that the Danish spouse put up a large sum of money, that both spouses be 24 years old, and that the foreign-born spouse pass a language and knowledge test. In other words, they are trying to make it extremely difficult for Danes to marry foreigners, and possibly violating the ECHR by interfering in the right to private and family life.

These developments are worrying, and are significant of a larger swing to the right throughout Europe. The question is, to what extent can countries' prior generous human rights commitments restrain them from making the temporarily popular decisions that violate them? Denmark would be a good case to watch.

Iovane on the Universality vs. Relativism of Human Rights

*I will be presenting occasional notes/ reviews of important old and new scholarly articles in migration studies/ law/ political science. When possible I will link to the article*

Article: Massimo Iovane; "The Universality of Human Rights and the International Protection of Cultural Diversity: Some Theoretical and Practical Considerations" (2007)
International Journal on Minority and Group Rights 14.

In this article Iovane explores an apparently unresolvable conflict between two conceptions about morality as it relates to international law.

On the one hand, in order for human rights law to be binding on all sovereign states, it must express to some degree universal conceptions of morality. For example, a prohibition against genocide is considered universally binding because it is agreed upon apart from political or cultural considerations. However, much of human rights law relates to less overarching norms. In fact, they often come from a individualist, western perspective that is hardly uncontroversial. As Iovane states, this conception starts from the position that human dignity is paramount, and moves from there to the belief that individual freedom is the most crucial way to protect human dignity. "Human dignity is thus equated with individual autonomy, and the capacity of independent action is accordingly the only hub and ultimate achievement of human rights."(@232) And this vision is chiefly achieved by states refraining from action that tends to limit individual autonomy. (E.g., not censoring politically sensitive newspapers, not preventing groups from protesting against government policies.)

On the other hand, this vision is not shared by all states. The rise of cultural relativism theory in the 1960's led to the recognition of alternative visions of human rights based on, eg; preservation of tradition, protection of the community interests above those of the individual, and cultural autonomy. This conception may also require a policy of non-intervention: "towards persons with whom we morally disagree, relativist conceptions usually predicate a position of tolerance and non-interference." (@237) But it may also require positive action on behalf of the state such as intervening to protect groups at risk of assimilation.

The problem then arises at how to conciliate these two values. How, for example, do we explain why Female Genital Mutilation (FGM) is a violation of human rights, when it is also a cultural tradition? Further, how do we reconcile a condemnation of a non-western tradition such as FGM but still for allow for widely practiced circumcision of males in the western world? Doesn't this reveal a heavy bias towards western/liberal/ capitalist models?

And continuing with the argument, doesn't the allowance of local, traditional forms of justice and human rights also negate universality? The obvious 'slippery slope' of cultural relativism is a denial of any forms of universal ethical norms, and for individual states and cultures to be able to rationalize any form of abhorrent behavior in the name of cultural relativism. Eek! (Let us, however, also recall here that Western states tend to make exceptions to their support of individual rights when it comes to the overall security of the group, see, for example, the Patriot Act.)

In sum, there are good and bad arguments for both positions, but overall it seems necessary to some degree to find a balance between equality of treatment of individuals and the occasional interference or even discrimination between people to protect minority and group rights.

So, having set up this straw man dichotomy, Iovane strikes it down during the later sections of his article by suggesting that judicial actors, such as the European Court of Human Rights, are best situated to negotiate between these two competing and even mutually exclusive values. As he sees it, several cases addressing linguistic, religious and cultural rights "illustrate the difference between protecting a human right seen from the individual point of view and safeguarding the same right seen as a binding element with a given community"(@256). By being able to make case-by-case decisions, weighing all relevant facts and detaching as much as possible from political considerations, Courts are in a unique position to protect both values while not making overly broad rules that hurt both interests.

I tend to agree with Iovane that Courts are in a better position to make these tough decisions than governments or conventions. However, Courts are also inherently political mechanisms that push the values of the societies they represent, values which may support or crush cultural and political difference. Ultimately, I don't think the very difficult question of how to weigh the rights of the individual with the rights of community is adequately resolved by any Court, but then, what is the alternative institution?

At any rate, this article excellently sums up an interesting dillemma and also has a super bibliography. Can't find a free copy right now, but will post it if I can find one!

Aleinikoff and Kluysmeyer on Migration-friendly Citizenship Policies

*I will be presenting occasional notes/ reviews of important old and new scholarly articles in migration studies/ law/ political science. When possible I will link to the article*
(Also, this review was submitted for a class at my university)

Article: T. Alexander Aleinikoff and Douglas Klusmeyer. Executive Summary: Citizenship Policies for an Age of Migration Except available online at CEPS.

In the Executive Summary for their book Citizenship Policies for An Age of Migration, Aleinikoff and Klusmeyer layout their back-door plan for creating more immigrant friendly societies: adapt humane and pro-immigrant citizenship legislation. By altering citizenship policies, the “tension and anxiety” (3) caused by migration influxes can be partially eased, while avoiding the political landmines of migration politics. While this is likely partially true, this brief overview fails to take into account two factors: first, that processes of determining citizenship are likely to be as political or more so then the other types of national legislation that deals with migrants. Second, the possession of legal citizenship does not necessarily lead to integration, social rights, or a feeling of belonging among migrants, or for that matter, other groups in society.

Many of the policy recommendations outlined by Aleinikoff and Klusmeyer are creative and humane; an accomplishment considering how often progressives are criticized for offering problems but no solution. For instance, the concept of changing the discourse of comparative citizenship by identifying countries policies not by their key requirement but by the practical number of generations required to acquire citizenship is a step towards recognizing the injustice of the traditional systems. It also allows for recommendations common to both to be identified more clearly (such as the concept of 1st generation citizenship for children raised in the host state from an early age.) Even those requirements which are not so creative, such as eradicating barriers to holding dual citizenship, are still certainly proposals that deserve implementation.
However, as the dual citizenship example demonstrates, these are highly controversial and inherently political proposals and do not necessarily present an easy path to integration. For example, the suggestion that parties should “refrain from campaigns that stigmatize ethnic minorities” (9) is something that most people would agree with, and yet sounds hopelessly naieve. Stigmatizing ethnic minorities and immigrants is a long-cherished political tradition that is so widespread that a suggestion to “refrain” from it can hardly be considered a policy proposal. Similarly, the suggestion that citizenship not be regarded as the gateway to welfare and other social benefits is likely to be met by massive skepticism by policy makers.

A nation’s citizenship policies reflect a lot about its conception about itself, and so those policies are bound to be controversial, regardless of how reasonable reforms may be. Even simple shifts can call into question issues of national identity. For instance, the removal of vague requirements like “good moral character” that Aleinikoff and Klusmeyer recommend could awaken a sleeping monster. One can imagine the headlines: “Good Moral Character no longer required to become citizen!” The problem is that reason and fairness has so much less to do with citizenship policies than does that intangible “spiritual principle” described by Renan. If citizens cannot put their finger on what exactly makes them belong, its hard to be rational about what qualities in others should distinguish them enough to join.

Of course, even within a relatively heterogeneous society there are bound to be outsiders of some sort creating tension and anxiety by their presence. These people are not necessarily non-citizens, and citizenship, even with all of the enlightened proposals in the world, does not always eradicate these problems. Ultimately citizenship, even bolstered by the wisest policies unimpeded by political barriers, is only one aspect of the tension and frissures created by diverse modern societies.

These points are more than likely considered by the authors within the full text of their book. And in general, the proposals presented by Aleinikoff and Klusmeyer are refreshingly well-balanced and no doubt effective in achieving the stated goal of promoting inclusion, and a liberal-minded person could almost not help but agree with them. However, the reformation of citizenship policy is not a simple thing. On the contrary, it involves grappling with some of the most fundamental and political questions in any society. It just seems to me that any society that was able to unproblematically implement the reforms suggested in the Executive Summary may not need them anyways.