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How Many Constitutions?

France is generally regarded as the birthplace of democracy in Europe.  Although the 1789 French Revolution is considered by many as the spark that lit the fire of European democratization and the propagation of fundamental concepts such as equality or human rights across the continent, the French Republic itself has had a very turbulent history of trying to maintain its core democratic values and power over the centuries.  When I use the general term “French Republic”, I’m referring to a period in France’s history when it was more or less governed democratically by representatives of the people without any interference from a king, an emperor or an autocrat.  In fact, since the declaration of the “First Republic” in 1792, the French government has actually functioned under five different republics, each governed by different constitutions, with the current republic conveniently known as the “Cinquième République” (Fifth Republic) whose constitution was actually only recently approved in 1958! 

Between these different republics were various periods of crisis and social upheaval, including World War II, two Napoléon emperorships, the restoration of the French Monarchy, the 60s culture wars and general infighting between different political factions who only wanted their strict vision of democracy applied.  In fact, given France’s history, I fully expect to live through the foundation of the Sixth Republic sometime in my lifetime!

Still Going...

Still Going...

Unlike France, the United States still adheres to its original 1789 constitution1 with only a mere twenty-seven amendments added to the text.  And the first ten amendments, the Bill of Rights, don’t count because they were approved at the same time as the original constitution.  Of the remaining seventeen amendments, two amendments (18th and 21st) concerning prohibition of alcohol cancel each other out, so in reality the US constitution has only been modified just fifteen times since it’s original inception!  Other than these fifteen additional amendments, NOTHING has been changed - not one old English phrase has been modified and not one strange looking letter ”S” rewritten!

Founding Fathers Think Things Through...

Founding Fathers Think Things Through...

In fact, simply to propose an amendment to the US constitution requires either 2/3 of both houses of Congress or 2/3 of states legislatures to launch the ratification process.  Then the amendment must be approved by 3/4 of the US states’ legislatures (or a state’s ratifying constitutional convention)!  This is the reason I tell my French friends why it is so difficult to reform anything that is hard coded into the US constitution, such as changing the US presidential election process (which was designed to allow time for delegates to a special “electoral college” to arrive on horseback to designate a president) or to pass any sort of gun control laws (the 2nd amendment explicitly allows the “right to bear arms”).  For my European friends, remember that the US constitution is almost considered a sacred document by most Americans, so even simply the thought of modifying it brings shivers down people’s backs.

The French, however, have no such scruples about changing their constitution.  Changing the constitution only requires 3/5 approval of the current legislature which gives the impression that it is constantly being tinkered with, whether it is to allow France to conform to the latest European Union directive or simply to promote the President’s current program.  In the beginning I found this nonchalant approach to constitutional modifications surprising, but after a while it all turns into background noise until one day soon when the Sixth Republic will be secretly declared…

The history of France’s five periods of republican rule (by the people) is very interesting reading.


Just Another Monarchist Collaborator!

Just Another Monarchist Collaborator!

The First Republic (1792-1804) - The ”First Republic” was declared in 1792 during the turbulent time of the French Revolution and was meant to be a complete rupture with every religious or monarchist convention of the past.  And there’s no better way to force people to obey a new republican constitution than to temporary suspend it, terrify the population into mutual betrayal and then send any suspected traitors to the guillotine2!!  After events calmed down a bit, in 1793 a second constitution was adopted called “La Constitution de l’An I” (The Constitution of Year 1) which established a republican government and also had the unique idea to reorganize the calendar into 12 months3 of 10 day weeks4, and dividing each day into 10 hours, each hour into 100 decimal minutes and each minute into 100 decimal seconds! 

Napoléon - Who needs a Republic when you can have an Emperor?

Napoléon - Who needs a Republic when you can have an Emperor?

In 1795, yet another constitution came into effect, “La Constitution de L’An III” (The Constitution of Year 3), reorganizing the government into two creatively-named legislative bodies called the “Coucil of Elders” (upper chamber) and the “Council of 500″ (lower chamber with, amazingly, 500 representatives).  These bodies were managed by a five person executive committee called the “Directoire”, which, after an internal coup d’état, later became a group of three “Consuls” (The Constitution of Year 8) and finally only ”First Consul for Life” Napoléon Bonaparte  (The Constitution of Year 10), who became Emperor two years later!  With five different constitutions in twelve years, it’s no wonder people so easily accepted Napoléon as their Emperor, if only to simplify government!  Incidentally, Napoléon also abolished the new calendar in 1805…probably because he was so sick of trying to remember the bizarre names of all the months!

French Revolutionary Calendar Months (starting with the first month of autumn):  Vendémiaire (vintage), Brumaire (mist), Frimaire (frost), Nivôse (snow), Pluviôse (rain), Ventôse (wind), Germinal (seed), Floréal (blossom), Prairial (meadow), Messidor (harvest), Thermidor (heat), Fructidor (fruits)


Inter Repubic Period…

  • First Empire (Emperor Napoleon I) - (1804-1815)
  • First Restoration of the French Monarchy (first attempt to reestablish the monarchy) - (1814-1815)
  • The 100 Days (brief return of Napoleon in power) - (1815)
  • Second Restoration of the French Monarchy (King from the ”Bourbons” branch) - (1815 - 1830)
  • July Monarchy (King is from the “Orléans” branch) - (1830 - 1848)

    The Second Republic (1848-1852) - As you can see by the dates, this constitution didn’t last long.  Maybe the founders should have reconsidered when they designed direct presidential elections resulting in Napoleon’s nephew, Louis-Napoléon Bonaparte, as president.  What a surprise when he declared himself Emperor (Napoléon III) during the coup d’état of 1852!  Won’t they ever learn?


    Emperorship of Louis-Napoléon (1852 - 1870)


    The Third Republic (1870-1940) - Currently the longest lasting French constitution, la Troisième Republique (The Third Republic) is considered by many as one of the most stable periods of French republican government.  In a sort of irony, the constitution of the Third Republic was actually just a temporary measure designed to limit executive power (remember all of the recent coup d’états?) before a better one could be agreed on.  However, the temporary solution was actually fairly well balanced and ended up lasting 70 years!   The constitutional power was heavily weighted towards the legislature resulting in a very weak, figurehead president of the Third Republic who was also frequently the butt of many jokes!


    Invasion and Occupation of France by Nazi Germany (1940-1945) - déjà vu?


    Happy New Year from the 2-Headed French Republic!

    Prime Minister Chirac Absolutely Loves President Mitterand!

    The Fourth Republic (1946-1958) - Although executive power was slightly increased, the motto of the Fourth Republic was that government only requires one big happy assembly and there would always be a majority consensus to manage the country.  Unfortunately, if you combine the Algerian War (France’s Vietnam) with the 60s culture crisis and the rise of communism, you have a good recipe for complete governmental gridlock…  Time to make a new constitution!


    The Fifth Republic (1958 - present)- The distinguishing feature of this constitution is the French rediscovery and reinforcement of executive power which the Third and Fourth Republics lacked.  The new presidential powers were meant to arbitrate during periods of crisis, command the armed forces and foreign policy, and basically to maintain the integrity and unity of the French Republic.  Although the French President has the right to dissolve the current national assembly and call elections, it is actually the prime minister (head of the elected assembly) who is in charge of government legislation.  In fact, in the history of the Fifth Republic there have been two periods of “co-habitation” where the President and the Prime Minister were from opposing parties!  This makes for great early evening TV with both men competing against each other for power, prestige and sound-bites (especially in high profile events on the world stage).

    So despite being such an ancient power, the French still haven’t had the same constitution for more than 70 years while the US is still running strongly after 220 years!  Which approach is better?  Did France really have a choice after so many coup d’états, emperors and foreign invasions?  Could it possibly be a better design to allow a consitution conceived before electricy, cars or the telephone to be more easily changed?  Or is it better to not touch a document that has worked relatively well as a basis of government for over 2 centuries?  I guess we’ll see generations from now when the US is still debating whether it’s a constitutional right to machine gun a deer and France has entered it’s Tenth Republic (for better or for worse!).  Until then, Vive La République!   :-)

    Links:

    Wouldn’t it be cool to say you were born on “10 Nivôse CLXXX”?  Click here to convert any normal date into revolutionary French format!

    France isn’t the only place with a constitution.  The European Union is trying desperately to ratify its own supra-national constitution (currently disguised under the name “The Treaty of Lisbon” after the original one was rejected in 2004 by French and Dutch referendums).  In a sort of irony, just the preamble of the proposed European constitution is almost the same length of the entire US constitution!

    Link to the European Constitution Explained by the BBC

    So how many constitutions has France invoked since guillotining their king?  Quite a lot to say the least!!  Here is a definitive list of ALL the French constitutions, including the not so democratic ones…(Napoléon actually reigned under a constitution)

    Here is a list of all of the modifications to the constitution of the current French Fifth Republic since its inception in 1958.  With 24 modifications, it’s almost the equivalent of a constitutional change every other year!


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    1. the country did briefly function under the 1781 “Articles of Confederation” until the final federal constitution was approved []
    2. this period of the French Revolution was known as “La Terreur” (The Reign of Terror) []
    3. every 3 months corresponded to a season []
    4. The 10th day replaced Sunday as the “day of rest” []

    Temples of Reason and Beauty

    Chapelle Saint-Jean - An Enchanted Grove

    Chapelle Saint-Jean - An Enchanted Grove

    It may come as no surprise to hear that France is traditionally a Christian country.  In every corner of France you will see a testament to its historical, Catholic traditions.  Whether it is the huge cathedral completely surrounded by an urban center, the forgotten chapel high up in a hidden mountain village or a crumbling oratory by the side of a forgotten hiking path, the country is teeming with reminders of its Christian past.  Even the towering peaks of the French Alps are frequently marked with huge iron or wooden crosses!

    Alpine Cross

    Alpine Cross

    Pull the Rope, Ring the Bell!

    Pull the Rope, Ring the Bell!

    With Christian signs permeating the daily landscape and many public holidays corresponding to a religious celebration, it is somewhat ironic to see how little modern France really cares about actually living its Catholic culture.  Unlike the US where ~40% of Americans attend church weekly, only ~10%1  of French Catholics regularly go to Sunday services, and I can attest from the occasional experience that most of the time mass here seems one step away from a retirement home.  Vocations for the priesthood are plummeting and many are now shipped in from neighboring Italy or even Africa.  The Church also has an image problem in France where it is frequently associated as a community of rich, bourgeois families and ex-nobility who are out of touch with working-class realities.  And in a more somber note, it has also been accused of Nazi collaboration during World War II.

    Despite such a rich Catholic tradition, there are many reasons for declining participation in the religion.  To begin with, the Catholic church has a virtual monopoly on Christianity in France.  Although in bigger cities Protestant churches do exist, the vast majority of churches in France are Catholic.  Unlike in America where even the smallest towns will have 4-5 different churches and people tend to “shop around” until they find the community that best fits their spiritual needs, in France there is no incentive for the (usually elderly) priest to lighten up on the guilt, fire and brimstone of their sermons and reach out towards people’s real needs or modern issues.  As a result, many people who are searching simply do not feel “fed”, but rather driven away, and just give up on Christianity - after all, where else is there to go?  And the ones that have no religious tradition in their families would have no reason to attend in the first place…

    The Real Faces of Notre Dame Cathedral

    The Real Faces of Notre Dame Cathedral

    France also has a tradition of secular, scientific humanism and direct conflict with the Catholic Church.  During the French Revolution (1789) many churches, abbeys and other religious buildings were burned, sacred tombs were pillaged and priests were brutally executed.  Even the heads of the statues decorating the doors of Notre Dame Cathedral were chopped off, the result of an explosion of pent-up anger at the abuses of power, not only by the King and the nobles, but also the clergy.  Traditionally, high members of the clergy (bishops, etc.) were usually appointed directly from the noble classes and had vast amounts of wealth and power at their disposal.  The Church also levied a hefty tax on all peasants (know as “la dîme”)2, and the local population was frequently exploited.

    Sainte Geneviève du Mont - Church or Temple of Reason?

    Saint Etienne du Mont - Church or Temple of Reason?

    During the French Revolution, the feudal regime was brutally uprooted and transitioned towards a democratic government based on universal principles.  Religion was seen as an obstacle to scientific progress and many churches were reinaugurated as “Temples de la Raison” (Temples of Reason), the goal of which was to bring freedom and equality to all people.  Traditional Christian holidays were renamed and even the Gregorian calendar was replaced with one based on the seasons and 10 day weeks3.

    After the frenzy of the revolution, the French government4 realized that despite their newfound freedoms, most of the country was still very traditional and strongly Catholic, so it was better for civil unrest, not to mention people’s consciousnesses, to make some sort of peaceful compromise with the Church.  The famous “Concordat of 1801″, agreed between Napoleon and Pope Pius VII, returned much of the confiscated property to the Church and also reinstated Catholicism as the majority religion in France while maintaining religious freedom for other sects (Protestants, etc.).  However, it also established government oversight over Church affairs, including such things as nominating bishops and dictating the salary of clergy.  And if your pay now depended on the new French state, it would be wise not to protest too much!!

    An Inspiring Heritage!

    An Inspiring Heritage!

    Fortunately, in modern times, religion is now (more or less) free from state interference in France, but the brutal separation between the church and state during the French Revolution has left scars even to this day.  For example, before you are allowed to be married in a French church, you must first be legally married in the eyes of the French state.  This is why with French weddings, in the morning there is always a legal wedding ceremony at the local town hall presided by the mayor and in the afternoon the traditional church wedding ceremony takes place (if the couple is religious or at least has been baptized…).

    The almost sacred upholding of secular traditions of logical and scientific inquiry also can be seen from the French response to certain religious teachings.  For example, most French cannot understand why the Pope insists on discouraging the use of condoms to fight AIDS, despite all of the scientific evidence showing a high correlation between condom use and successful prevention and control of the epidemic. 

    L'Abbaye de Sénanque

    L'Abbaye de Sénanque

    Another recent example is the controversy over allowing young muslim girls to wear headscarves in public school.  Because a public school is an extension of the French state, it was decided that wearing a headscarf in school was too much of a religious provocation against the pure secularism of the state.  And don’t get me started on the French reactions to what are perceived as ridiculous American debates concerning prayer in school, posting the 10 commandments in front of government buildings or whether evolution really happened!

    Despite the diminishing participation in traditional Catholicism, France still has an incredible heritage of beautiful, inspiring religious sites.  I absolutely love discovering hidden chapels high on distant mountains and often imagine travelers following these ancient routes, struggling up a difficult valley and offering thanksgiving to the local oratory for a safe journey.  There are also countless places of religious pilgrimage, whether it is visiting well-known Lourdes, walking bits of the “chemin de Saint Jacques de Compostelle” (Way of St. James) through the Pyrenees Mountains or discovering sacred relics in the chapel of some canonized hermit’s cave.  Touring active monasteries is also invigorating as they are frequently located in gorgeous countryside with delicious cheese, wine or other specialties to sample or purchase.  Many also have a public vespers, an early evening mass where the monks frequently will sing or chant.  So don’t be afraid to explore those hidden places on the map and try to keep the faith!

    Links

    Those Spooky French Churches!

    Those Spooky French Churches!

    Sainte Geneviève - Although the Da Vinci Code talks about the imposing Saint Sulpice cathedral, one of the strangest, eeriest churches I’ve ever visited in Paris is “Saint Etienne du Mont” (see my photo earlier in this article).  Hidden behind the Pantheon, it is devoted to the patron saint of Paris, Saint Geneviève, who in the year 451  somehow played the central role encouraging the population to defend the city against Attila the Hun (who incidentally decided to head for Orléans at the last minute).  With its strange towers, ancient interior and worn floor you can literally feel the centuries weighing down on you!

    Saint Gervais - There are actually still churches in France with an active, dynamic community, and if you want to participate in an inspiring religious experience where some of the faithful literally walk to the alter on their knees, try out high Sunday mass at St. Gervais in the Marais.  From the outside, this cathedral is dingy and almost unremarkable (in Paris there are cathedrals all over the place) but during the Sunday services the first few rows are full of the singing nuns and chanting priests of the “Fraternité de Jerusalem” (Communities of Jerusalem) - nothing but believers here!

    Abbé Pierre -  Beloved by his countrymen and extremely popular (consistently higher than any French president), in 1949 this dynamic abbot started Emmaus, a foundation devoted to helping the poor and homeless.  Always outspoken and a supporter of government initiatives to help fight poverty, Abbé Pierre was also a controversial figure within the Catholic church, openly supporting the ordination of women, married priests and the use of contraceptives against AIDS.

    http://www.newadvent.org/cathen/04204a.htm - Here is the official take on the “Concordat of 1801″ from the online Catholic encyclopedia.  To summarize, Napoleon held all the cards - basically if the Church wanted its property back, they had to sign on the dotted line!

    http://www.chemindecompostelle.com/ - This site has a lot of useful information about the St. James Way.  I plan on writing more details about this pilgrimage in a future post.


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    1. some estimates place this number even lower! []
    2. ”la dîme” was a tax requiring 10% of the peasant’s agricultural earnings to be given to the Church []
    3. the traditional Sunday ”day of rest” was replaced by “Décaidi”, the tenth day []
    4. at this time France was “governed” by Napoleon []

    Don’t Ask, Don’t Tell - US Dual Citizenship

    It's still better if you're a citizen...

    Liberty, Equality and Brotherhood - But it's still better if you're a citizen...

    Anyone who has lived abroad knows that the favorite past time of all expatriates1 is accumulating official paperwork.  The first major document to acquire when living overseas is generally called a “residency permit”.  In the US, this is known as the famous “green card”2 and allows foreigners to legally stay and work in the country for a long term basis.  In France, it’s called ”la carte de séjour” and every expatriate has a hellish story to tell about the lengthy, unwieldy process of obtaining it (and renewing it).  Without this official identification card, which proves your long term residency is legal, you will have great difficulty opening a bank account, signing a lease, finding a job or even subscribing to cellular phone service.

    In France, once you acquire “la carte de séjour”, it marks the start of a glorious, never-ending scavenger hunt for other official documents including foreign credit cards, insurance contracts, a driver’s license, a social security card and even library cards just to name a few.  And if you’re a long term expat, the ultimate goal may be to collect the holy grail of all foreign documents by acquiring citizenship in your adopted country and finally obtaining a passport!

    C’est Mieux à Deux

    Dual Nationality - The Holy Grail!

    The Holy Grail!

    Before embarking on your quest, be sure to check your native country’s dual nationality laws.  If you are from a country that requires renunciation of your citizenship to acquire another nationality then it’s officially game over.  However, because of rampant globalization, international relationships, children born abroad and the basic fact that foreign governments have a hard time communicating with each other,  many countries turn a blind eye to dual nationals.

    The United States has an ambiguous approach towards dual citizenship.  The basic policy is that “U.S. law does not mention dual nationality or require a person to choose one citizenship or another” - US State Department Website.  Loosely translated, this means the US government implicitly acknowledges an individual’s right to dual citizenship but would rather avoid it if possible.

    There are a number of Supreme Court cases concerning the rights of US dual nationals.  In the 1967 case of Afroyim v. Rusk it was determined that the 14th amendment, originally intended to guarantee citizenship to freed slaves and their descendants, also forbids Congress from making any law depriving an individual of their US citizenship without consent.

    All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. - 14th amendment of the US constitution

    In fact, the only way to lose US citizenship - barring treason or joining a hostile foreign army - is if you explicitly renounce with intent to give it up.  The key word is intent- if you acquire a foreign nationality but would never dream of relinquishing your US citizenship, this is clearly not an intent to renounce3.  And the only way to legally relinquish US citizenship is to leave the country, sign an “oath of renunciation” in front of a US consular officer or diplomat, and then stick your passport down his throat (the last part is optional, but it probably counts as “intent”).

    Death and Taxes - The IRS is Watching You!

    Congress has also passed laws to discourage wealthy US citizens from relinquishing their citizenship.  Unlike most civilized countries where only locally generated income is declared to tax authorities, US citizens are required to declare their global income to the IRS and many of the richest ones are actually subject to double taxation (once in the foreign country and once again to the IRS).  In the past, this was incentive enough to renounce their US citizenship to avoid taxes.  However, under current laws, even if the wealthiest expats relinquish their US citizenship,  they are still liable to the IRS for taxes on their global income for the next ten years…

    Please Remember to Forget

    Ironically, when US green card holders finally become citizens, they are required to say the following oath during their official citizenship “swearing in” ceremony:

    I hereby declare, on oath, that I absolutely and entirely renounce and abjure all allegiance and fidelity to any foreign prince, potentate, state, or sovereignty, of whom or which I have heretofore been a subject or citizen; that I will support and defend the Constitution and laws of the United States of America against all enemies, foreign and domestic; that I will bear true faith and allegiance to the same; that I will bear arms on behalf of the United States when required by the law; that I will perform non-combatant service in the armed forces of the United States when required by the law; that I will perform work of national importance under civilian direction when required by the law; and that I take this obligation freely without any mental reservation or purpose of evasion; so help me God.

    Despite the fact that new citizens officially renounce all allegiance to another foreign country, constitutionally they cannot be forced to give up their native nationality.  An INS4 official once mentioned that to reduce any complications due to double nationality, new citizens should remember to “forget” to bring their foreign passport to the ceremony, otherwise they may have to hand it in.  As a side note, how many immigrants actually understand what the words “abjure” and “potentate” mean (doesn’t one require Viagra…)? 

    Just Say “Oui”

    More photocopies...

    More photocopies...

    Acquiring French nationality is not that difficult if you’re used to dealing with the administration.  The procedure is actually nothing more than simply signing a legal document declaring your French nationality in front of a judge.  A completed application can be submitted to the local “tribunal d’instance”5 after fulfilling a minimum residency requirement depending on your current situation.  In fact, the hardest part of the whole process is gathering all of the required paperwork and translations to show you’re an honest, well-integrated immigrant who is preferably already employed.

    After signing your “declaration of French nationality”, the local police department will then conduct a small investigation, meet with you in person and sometimes even interview your neighbors, to ensure that everything is in order.  A local immigrations official will also verify that you are culturally assimilated and speak a good level of French (sacrebleu!).  If all goes well, you’re called back to the judge one last time and are then officially handed your signed declaration and also your new “French birth certificate” (this is really what it’s called!).  You are now officially “reborn” into the French state.  With your new birth certificate in hand, you can then complete the final application for a French voting card and passport.

    An International Heartache

    Dual nationality is not for everyone, but if you have lived abroad long enough to become fully integrated into your adopted country, started a family, purchased property, made many friends, plan on retiring there and can’t imagine ever moving back to your native country, then it is definitely worth considering.  Remember that until you are a citizen, it is still possible to get kicked out of your host country due to a new immigrations statute or some unforseen technicality (such as inadvertently violating a law, not renewing your residency permit on time, divorce, etc).  With the ease of travel and global interdependence, there are so many immigrants who are split between love towards their native homeland and the profound link to their adopted countries, that not allowing the possibility of dual citizenship in modern times seems like a cruel anachronism.

    And one last word of advice for all US dual citizens - for the love of common sense, please remember to always use your American passport when going through US immigrations (or you may risk several hours of INS interrogation to prove you really didn’t ”intend” to give it up…)!

    Links:

    How to Acquire French Nationality - This link gives all of the different scenarios, prerequisites and administrative hoops for acquiring French nationality depending on your own personal situation.  If you can’t understand the French on this site, it’s probably not worth applying!

    Official French Position on Dual Nationality - Basically, it’s fine with the French if you have another passport.

    Global Citzenship Laws - Click here to see if your native country accepts dual nationality - the list is a bit old, but still very useful.

    Long-haired Depardieu!

    Long-haired Depardieu!

    Official US State Department approach to dual citizenship (details)  - More boring mumbo-jumbo

    Official US State Department procedure for renouncing US Citizenship - If you’re really crazy, here’s how to give up US citizenship.  Not to be taken lightly!

    Richard Wales.Org - I don’t know who this guy is, but his site has links to just about everything imaginable concerning dual citizenship.  It hasn’t been updated in a while and the bare-bones HTML is painful to look at, but it’s a great start for any dual citizenship legal data mining.

    Green Card Movie Trailer - This is the trailer to the cheesy film “Green Card” starring Gérard Depardieu and Andie MacDowell.  I’m not sure if US immigrations officials really ask couples about whether their partner wears briefs or boxers, but the film is not too bad for a chick-flick.

     

     

    Links to the two major US Supreme Court decisions concerning dual nationality, fairly well explained on wikipedia.org:

    http://en.wikipedia.org/wiki/Afroyim_v._Rusk - Concerns the right of the US Congress to revoke US citizenship without consent.

    http://en.wikipedia.org/wiki/Vance_v._Terrazas - Concerns the question of defining what is ”proven intent” to relinquish US citizenship


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    1. a term for someone who is currently living outside of his native country []
    2. a “green card” is not actually green - it is basically a high-tech ID card for foreigners []
    3. The 1980 Supreme Court case of Vance v. Terraza attempts to define what is “proved intent” []
    4. immigration and naturalization service []
    5. regional high court []

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