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Although two bills in the 109th Congress -- H.R. 260 and H.R. 2092 , both proposed by Sheila Jackson-Lee (D-TX) -- proposed to amend the first-mentioned statute (8 U.S.C. 1409), neither bill emerged from committee, and no other changes appear to have been made since Nguyen v. INS was decided in 2001. The Child Citizenship Act of 2000, P.L. 106-395, did amend the adoption statutes, 8 U.S.C. 1431 and 1433; the former concerns the automatic conferral of citizenship, and the latter concerns the application procedures if citizenship is not conferred automatically. But I note that it was enacted before Nguyen was decided. Jol A. Silversmith Associate, Zuckert, Scoutt & Rasenberger, LLP
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