SOLVING LIBERIA’S CITIZENSHIP ISSUE: An Abbreviated Perspective

By Seward Montgomery Cooper*


The Perspective
Atlanta, Georgia
January 11, 2016

                  



 
 
 
 

The largest number of Liberia’s skilled population resides in the Diaspora.  Over the years they have acquired diverse skills and wealth from various countries.  How can we affect them so that within their hearts – the place to which they will always want to return or contribute even after being away for extended periods - will be Liberia?  How can we tap into this latent pool of direly needed skills, this sleeping source of capital, to help resuscitate our country? 

Foreign direct investments have been marginal in most African countries, almost
negligible in Liberia; but remittances from nationals abroad continue to climb.  If we can remove the legal bottlenecks and lift the artificial barriers that inhibit full use of all Liberia’s human resources we could jump-start the economy.  We
therefore must draw from this human reservoir that lives outside to complement the efforts of those who live within our geographical boundaries. 

Part of this can be done speedily and, in the first instance, without the cumbersome entanglements of a Constitutional amendment.  It can be done by statutory adjustments that are clearly within the power of the National Legislature.   The Legislature may repeal portions of the Aliens and Nationality Act especially portions of section 21, 22, and enact new statutes that permit dual citizenship.

More than twenty-three African countries already permit dual citizenships.  Most African countries similarly affected by war permit dual citizenships. These include Angola, Chad, Cote d’Ivoire, Somalia, and Uganda.  Rwanda and Sierra Leone are currently examining draft legislation on this issue.  Nigeria, Africa’s most populous country, expressly permits it in their Constitution.  South Africa, Morocco, Tunisia, Egypt, Ghana and Guinea are among the list of permissive countries.  Liberia ought not to be shortchanged.  It must examine itself.

Let us review briefly the situation. 

Article 27 (a) of the Constitution states:

“All persons who on the coming into force of this Constitution were lawfully citizens of Liberia shall continue to be Liberian citizens.”

Accordingly, if a person did not lose Liberian citizenship under any of the provisions of the Aliens and Nationality Act or for failure to perform an act of renunciation as required under Article 28 of the Constitution, that person continues to be a Liberian citizen.

Article 28 of the Constitution states:

“Any person, at least one of whose parents was a citizen of Liberia at the time of the person’s birth, shall be a citizen of Liberia; provided that any such person shall upon reaching maturity renounce any other citizenship acquired by virtue of one parent being a citizen of another country.  No citizen of the Republic shall be deprived of citizenship or nationality except as provided by law; and no person shall be denied the right to change citizenship or nationality.” (Emphasis supplied.)

The primary indication of the intent of the Constitution is its language. It is a general principle that drafters of a law state in the law what they mean and mean in a law what they state therein.  The drafters of the Liberian Constitution included some of Liberia’s best legal minds, who stated lucidly and with precision in each article the intent of the framers of the Constitution. Where the words of the Constitution are plain, clear and determinate, as in this situation, no interpretation is required.

But even if one asserts stubbornly that the language of Article 28 requires interpretation, which I contend it does not, one would arrive at the same conclusion using rules of interpretation. The provision states that if you have one parent who is a Liberian citizen at the time of your birth then you also are a Liberian citizen.  You are required however at age 21 years to renounce the other citizenship acquired as a result of your other parent’s foreign citizenship, if you are to keep your Liberian citizenship.

No requirement exists for renunciation of Liberian citizenship where both parents at the time of a person’s birth are or were Liberian citizens.  This conclusion derives, among other factors, from rules of interpretation and legal maxims such as expressio unius est exclusio alterius ,  expressio unius personae est exclusio alterius , and permissum videtur in omne quod non prohibitum

This interpretation also arises from a review of the history of the language in the Constitution.  It should be recalled that an earlier draft of a constitution was
submitted in 1983. The 1983 draft had been proposed by a commission chaired by Professor Amos Sawyer.  That 1983 draft was not ratified but was submitted to the constitutional advisory assembly chaired by Dr. Edward Kesselley.  A revised draft evolved from the work of the constitutional advisory assembly.  That revised draft was submitted to the Liberian people in a referendum.  The people adopted the revised draft, thereby making what today is the Constitution of the Republic of Liberia. 

The 1983 proposed draft was modified in several important respects pertaining to the issue of Liberian citizenship.  Below is a comparison of the relevant provisions of the 1983 draft with the Constitution.    I have underlined and italicized language in the 1983 draft that was materially revised by deletion.  I have placed in bold print language inserted, which is now language of the Constitution.

The 1983 draft provided:

Article 28 Any person, at least one of whose parents was at the time of the person's birth a citizen of Liberia, shall be a citizen of Liberia; provided that where such person shall have acquired the citizenship of another country by virtue of having been born in that country or by virtue of one parent being a citizen of another country, that person must, upon attaining the age of eighteen years, renounce any other citizenship so acquired. Such declaration shall be made before a circuit court in Liberia or before a consular officer of the Republic, if made outside Liberia. A failure to make such renunciation within one year after attaining such age shall result in the forfeiture of Liberian citizenship.  […any such person shall upon reaching maturity renounce any other citizenship acquired by virtue of one parent being a citizen of another country.  No citizen of the Republic shall be deprived of citizenship or nationality except as provided by law; and no person shall be denied the right to change citizenship or nationality.
Article 29
(a) No citizen of the Republic shall be deprived of citizenship or nationality of Liberia except as provided herein or by an act of the Legislature consistent with the provisions of this Constitution; and no person shall be denied the right to change citizenship or nationality.   (Please observe that some of the language of this section was revised and made into the final sentence of Article 28 above.)
(b) No Liberian female citizen, who by marriage acquires the citizenship of another country, shall lose her Liberian citizenship unless she renounces it.
Article 30 On application made on behalf of the Republic by an authorized official of Government, the circuit court may deprive a citizen of Liberia of his citizenship, whether he be a Liberian by birth or naturalization, on any one or more of the following grounds, and with such exceptions as set forth below;
(a) acquiring the citizenship of another country; or taking an oath or making an affirmative or other formal declaration of allegiance to a foreign state voluntarily;
(b) exercising a free choice to enter or serve in the armed forces of a foreign state, unless prior thereto such entry or service was specifically authorized by the President or the Legislature;
(c) voting in a political election of a foreign country;
(d) acquiring Liberian citizenship by fraud, misrepresentation, concealment of material facts or any other grossly improper or irregular practice; or
(e) making a formal renunciation of his Liberian citizenship before a diplomatic or consular officer of Liberia in a foreign state.
   

Again, everything underlined and italicized above was deleted and is no part of the Constitution.  Significantly, among the deletions is any reference to renunciation of citizenship acquired by virtue of being born in another country.  Also significant is the complete deletion of what would have been provisions on citizenship in Articles 29 and 30, except for a few words of the proposed draft Article 29(a) that were accepted and included in the last sentence of Article 28 of the Constitution.  

The rejected provisions of the proposed draft Article 30 are similar in many substantive ways to the statutory provisions of the existing Aliens and Nationality Act pertaining to loss of Liberian citizenship.  That Act predates the Constitution and may be subject to successful Constitutional challenge.  It is not unreasonable to assume that the proposed language submitted in the 1983 draft was deleted because the constitutional advisory assembly did not agree to loss of citizenship on those grounds or, and perhaps most likely, considered those details more within the province of the Legislature and unsuited for inclusion in the Constitution – “the supreme and fundamental law of Liberia” .

In view of the history of the Constitution, and in the absence of any Constitutional or statutory prohibition, it follows therefore that any person both of whose parents were citizens of Liberia at the time of the person’s birth and who has not acquired another citizenship by naturalization or acted in a manner proscribed under the existing Aliens and Nationality Act that would cause an automatic loss of citizenship, is a Liberian citizen.  This applies most clearly in circumstances where the other citizenship is acquired by virtue of place of birth (jus soli), such as occurs under the Constitution of the United States of America.   In my professional opinion, this category of persons constitutes Liberian citizens with lawful dual citizenships under Liberian law.

How in the national interest could this pool of Liberians with dual citizenship be expanded? 

 

I submit that this could be accomplished easily by an act of the National Legislature.  I propose for consideration, therefore, the following draft legislation under the Aliens and Nationality Act:

“Subject to Article 28 of the Constitution, a person shall forfeit forthwith his Liberian citizenship if, not being a citizen of Liberia by birth, he acquires or retains the citizenship or nationality of a country, other than Liberia, of which he is not a citizen by birth.  ANY LAW TO THE CONTRARY NOTWITHSTANDING.”

This draft speaks prospectively. 

There remains the issue of the restoration of citizenship on persons who acquired Liberian citizenship at birth and subsequently lost Liberian citizenship by naturalization or by action contrary to the Aliens and Nationality Act then in existence.  Fortunately, there is precedence for the restoration of Liberian citizenship.  The precedent is found in section 21.32 of the Aliens and Nationality Act which declares as a Liberian citizen any woman formerly a citizen of Liberia who under prior law lost her citizenship by marriage to an alien.  A similar provision should be enacted by the National Legislature that could state:

“Any person formerly a citizen of Liberia by birth who under prior law lost Liberian citizenship for reasons other than for conviction for treason in waging war against the State for a foreign enemy State is hereby declared a Liberian citizen effective nunc pro tunc as of the date of loss of citizenship except for forfeited property. ANY LAW TO THE CONTRARY NOTWITHSTANDING.”

This draft for the restoration of Liberian citizenship is based on section 21.32 of the existing Aliens and Nationality Act.  I have modified it to suit the purpose and have inserted an exception relating to a specific form of treason which goes to the most egregious form of infidelity and disloyalty to one’s country.  The suggested provision applicable to forfeited property comes from the existing Act restoring citizenship on Liberian women who had married aliens.  The rationale for that exception, I believe, is the onerous burden such disputes would impose on judicial operations and efficiency.  Of course as earlier stated a holistic statutory approach would require that certain provisions of the existing Aliens and Nationality Act be repealed to avoid confusion.

 

The passage of these into statutes would open the door for new long-term
investors.  It would expand the country’s human and capital resource base, increase investments by nationals, potentially increase revenue arising from the benefit of taxation treaties, augment the flow of remittances, and redound to Liberia’s benefit in a way that would positively affect Liberia’s reconstruction.

 

* Counselor-at-Law, Supreme Court of Liberia; Counselor-at-Law, Supreme Court of Wisconsin; Counselor-at-Law, Supreme Court of the United States of America.  The views expressed are personal and do not represent the views of any organization or institution.  

Art.34 (h) The Legislature shall have the power to establish laws for citizenship, naturalization and residence.

See Black’s Law Dictionary “A maxim of statutory interpretation meaning that the expression of one thing is the exclusion of another.  When certain persons or things are specified in a law, contract, or will, an intention to exclude all others from its operation may be inferred.  Under this maxim, if statute specifies one exception to a general rule or assumes to specify the effects of a certain provision, other exceptions or effects are excluded.”

See Black’s Law Dictionary “The mention of one person is the exclusion of another.”

“All that is not prohibited is a permitted.”

Article 2, Constitution of the Republic of Liberia

This draft is modeled on the Nigerian Constitution of 1999.  It should be noted it allows naturalized persons to keep the citizenship(s) acquired at birth. 

See Black’s Law Dictionary  “Now for then.”

 


Joan George
Joseph Jenkins Roberts and others like him, natural born American Citizens, return to a land they knew little about and were able to settle and rule. We should not use this issue of dual citizenship as an excuse to stop us from returning home and investing in our country whilst at the same time help in getting our people out of poverty.

As a person of negro decent you can own property in Liberia, but if the issue of your loss Liberian Citizenship is that important to you, simply naturalize for now til the issue of dual citizenship is addressed.

Our Constitution is based on the inhuman treatment of slavery. Because of this very history, is why we have American history and African-American history. It is because of this very history that we have Affirmative Action in America today.

Yes we have to seriously consider this matter of dual citizenship but we also have to come together as a people if even just for the sick of our ancestors or parents and help develop Liberia.

I would like to suggest that along with the discussion of dual citizenship, we should also be considering Visa-Waiver between The Republic of Liberia and the United States of America.
Joan George at 01:58PM, 2016/01/11.
DORTU-SIBOE DOE
My. Cooper, being a citizen of a country is determined by the laws of that country. despite the fact there are many skilled or ptofessionals in diaspora who have not lost their Liberian citizenship, the bulk of your "largest skilled population in diaspora" ARE NOT LIBERIANS; THEY ARE FOREIGNERS ACCORDING TO THE LAWS OF LIBERIA! JUST SO YOU KNOW FROM THE ONSET AND RESCIND THAT MISINFORMATION IMMEDIATELY.

Secondly, Mr. Cooper, investors sre all over the country inspite of the laws on sutomatic loss of citizenship! And more ate bound to spread all over the country soonet by the time we start marketing the oil. If this law could prevent investors time would have long told all of us, for this law has been in place for about half a century!

As for your suggestion to abrogste that law and punish others of negro descent who like other negroes have broken the law, we say NO NO NO!
That would be a national prejudice against our fellow negroes! That law is across the board! Cituizenship of origin abandoned can alwsys be regained. Those who have lost their Liberian citizenship can always regain it, once they are no more foreigners! I gurss you know what I mean! Joan made a fine suggestion by embolding you peple to ask your countries to introduce the visa waver program and drop this dual citizrnship talk, for it is impossible! Stlesdt you remember the massive rejection of dual citozrnship during the CRC IN GBARNGA
DORTU-SIBOE DOE at 03:30PM, 2016/01/11.
smith
Cllr. COOPER, you have clearly manifested your brilliance. You are the first to actually proposed a draft of a solution. The rest of the writers are just talking.

Bravo
smith at 05:26PM, 2016/01/13.
Dortu-Siboe Doe
READ BELOW CHAPTER 111 OF THE LIBERIAN CONSTITUTION AND READ CAREFULLY PARAGRAPHS B & C. ALL PERSONS ARE EQUAL BEFORE THE LAW -- WHETHER NATURAL BORN OR NATURALIZED! CITIZENSHIP IS CITIZENSHIP!

Mr. Seward Montogomery Cooper fails to take into account his violation of the fundamental rights of naturalized citizens STIPULATED IN PARAGRAPH B & C OF ARTICLE 11 UNDER CHAPTER 111(FUNDAMENTAL RIGHTS) OF THE LIBERIAN CONSTITUTION WHEN HE PROPOSES:

“Subject to Article 28 of the Constitution, a person shall forfeit forthwith his Liberian citizenship if, not being a citizen of Liberia by birth, he acquires or retains the citizenship or nationality of a country, other than Liberia, of which he is not a citizen by birth. ANY LAW TO THE CONTRARY NOTWITHSTANDING.”

Mr. Cooper a citizen is a citizen whether natural born or mnaturalized. So when you impose such limitations on naturalized citizens, you are violating their fundamental rights as prescribed under Paragraph C of Article 11 under CHAPTER THREE! ALL PERSONS ARE EQUAL BEFORE THE LAW!


CHAPTER III

FUNDAMENTAL RIGHTS
Article 11

a)


All persons are born equally free and independent and have certain natural, inherent and inalienable rights, among which are the right of enjoying and defending life and liberty, of pursuing and maintaining and security of the person and of acquiring, possessing and protecting property, subject to such qualifications as provided for in this Constitution.

b)


All persons, irrespective of ethnic background, race, sex, creed, place of origin or political opinion, are entitled to the fundamental rights and freedoms of the individual, subject to such qualifications as provided for in this Constitution.

c)


All persons are equal before the law and are therefore entitled to the equal protection of the law. AS FOR YOUR SUGGESTION TO ABROGATE ARTICLE 28 AND THE 1973 LAW ON LOSS OF CTIZENSHIP, THAT IS JUST IMPOSSIBLE AS FAR AS THE LIBERIAN PEOPLE HAVE PROVEN IN GBARNGA!
Dortu-Siboe Doe at 06:15AM, 2016/01/14.
George K Fahnbulleh
Mr. Cooper what does the phrase "at least one" mean? Where in the world does that mean only one.

"At least one" means any number equal to or greater than one; the number two meets the criteria of "at least one."
George K Fahnbulleh at 09:33AM, 2016/01/15.
George K Fahnbulleh
Joseph Jenkins Roberts and other were NEVER American citizens. Blacks did not become citizens of the United States until the passage of the 14th Amendment in 1867. The 14th Amendment also states that those born in America who were "under the control of another sovereign" could not claim American citizenship.

Liberia became independent in 1847; thus Roberts and others, being citizens of Liberia, could not claim American citizenship.

Joan George wrote:
Joseph Jenkins Roberts and others like him, natural born American Citizens, return to a land they knew little about and were able to settle and rule. We should not use this issue of dual citizenship as an excuse to stop us from returning home and investing in our country whilst at the same time help in getting our people out of poverty.

As a person of negro decent you can own property in Liberia, but if the issue of your loss Liberian Citizenship is that important to you, simply naturalize for now til the issue of dual citizenship is addressed.

Our Constitution is based on the inhuman treatment of slavery. Because of this very history, is why we have American history and African-American history. It is because of this very history that we have Affirmative Action in America today.

Yes we have to seriously consider this matter of dual citizenship but we also have to come together as a people if even just for the sick of our ancestors or parents and help develop Liberia.

I would like to suggest that along with the discussion of dual citizenship, we should also be considering Visa-Waiver between The Republic of Liberia and the United States of America.


George K Fahnbulleh at 09:38AM, 2016/01/15.
Theodore Hodge


Brilliant article. In my opinion, this article gives a tremendous framework and analysis for the debate at hand. I do concur with most of the premises that form the basis for the argument developed herein, however, I must express some reservation about the conclusion drawn, and the proposition put forth my our learned author here.

After impressively giving his readers enlightenment and elucidation, the author concludes: "I submit that this could be accomplished easily by an act of the National Legislature..."

I find that sentence a bit troubling, and here is why. There is no doubt that the matter at hand is a constitutional issue; the author must agree since he cites the Liberian Constitution over and over in order to develop the major premises of his argument. If we are agreed that the issue is constitutional, then it must require a constitutional fix, rather than a mere legislative act. Here is what the constitution says about amendments:

Article 91
This Constitution may be amended whenever a proposal by either (1) two-thirds of the membership of both Houses of the Legislature or (2) a petition submitted to the Legislature, by not fewer than 10,000 citizens which receives the concurrence of two-thirds of the membership of both Houses of the Legislature, is ratified by two-thirds of the registered voters, voting in a referendum conducted by the Elections Commission not sooner than one year after the action of the Legislature.


In view of the above, based on the constitution itself, the only way to resolve this issue of dual citizenship is through an amendment as specifically stated, not just by a mere legislative act. That is my reading and I beg to have that position considered as we go go forth.
Theodore Hodge at 09:35AM, 2016/01/16.
Dortu-Siboe Doe
Mr.Cooper fails to realize that the Legislature CANNOT PASS AN ACT OR LAW WHICH IS CONTRARY TO THE CONSTITUTION! And so it is not surprising he makes such strange error as:

"I submit that this could be accomplished easily by an act of the National Legislature..." IMAGINE!

And he has the mind to use the phrase "could be EASILY accomplished". Not to talk about his preceeding phrase:
“Subject to Article 28 of the Constitution,..." THE KEY PROVISION!!!

AGAIN, MR. COOPER, THE LEGISLATURE CANNOT PASS ANY LAW OR ACT WHICH IS CONTRARY TO THE CONSTITUTION! IF SUCH BLUNDER IS EVER DONE, SUCH LAW OR ACT SHALL SIMPLY BE A LAW OR ACT WAITING TO BE STRUCK DOWN BY THE SUPREME COURT OF LIBERIA EVEN SUA SPONTE!
Dortu-Siboe Doe at 04:58AM, 2016/01/18.
Charles Cheapo Price
Mr. Dortu S. Doe

Ours is a democracy and so everybody has the right to express his or her opinion. Notwithstanding, having an opinion does not mean that you are always right. Sometimes an individual must weigh his decision against prevailing arguments especially when those arguments come in the face of overwhelming evidence, logic and expert knowledge.

I have read several essays on the dual citizenship debates with excellent comments coming from individuals like Mr. Theodore Hodge, Mr. Ernest S. Maximore, Dr. Emmanuel Dolo, Mr. Seward Montgomery Cooper, Addoulaye W. Dukuly and George H. Nubo; and it appears like the arguments are bending in favor of dual citizenship because of the times that we now live in compounded by certain global dynamics; the circumstances that preceded those times which led to a dispersed Liberian demography and brought the country to the present state.

Mr. Doe, I admire your love for Liberia and the continent of Africa. I saw in one of your commentaries when you referred to Africa in capital and boldface letters and I quote, “MAMA AFRICA.”

Notwithstanding you do not want your love for Liberia to be like a son, who is a medical doctor, has heard that his mother is severely ill and needs some treatment. Because of the emotional ties between them, the son refuses to let any other doctor to assist in diagnosing and finding cure for the illness. Instead he undertakes the task but ends up overdosing his mother and killing her.

I think that you should respect the opinions, facts and suggestions of the other people just like how they respect yours. After all they may have different views on the Liberian constitution and may even err in its interpretations of the dual citizenship issue, but it does not mean that they are disloyal and unpatriotic to the country.




Charles Cheapo Price at 02:45PM, 2016/01/18.
DORTU-SIBOE DOE
Mr. Charles Price Cheapo,

As we underscored in our response to you viz Dr. Dolo's article, the voicing of opposition to an idea or view is the reflex of any intellectual! In other words, it said, "THE CLASH OF IDEAS IS THE SOUND OF FREEDOM!

Notwithstanding, one's view, idea, or opposition to the former must tally with "logic, evidence, and expert knowledge". And from all indications, neither, Dukule's/Nubo's, Maximore's, Cooper's, nor Dolo.'s ideas or views tally with "the logic, evidence, expert knowledge, or in short the constitutionality of the issue or controversy debated.

For example, it is absolutely illogical, non-evidential, alien to expert knowledge, and of course violative of the constitution for Mr. Cooper to suggest that the Legislature should pass a law or act which is contrary to the constitution or inconsistent with the constitution!

It is also totally wrong for Dukule and Nubo to state that the 1973 automatic loss of citizenship law is not a constitutional issue when the constitutional xylem or ligaments of that law is enshrined in Articles 27,28, and 34, of the great Liberian Constitution in both LETTER AND SPIRIT!

Mr. Cheapo, it is also extremely dangerous for Liberia to abrogate strategic laws simply to appease family members who sent money to their own relations during some intermittent crisis! If laws must be abrogated or even amended, it must be as a matter of compelling dictates directly geared towards national security or national interests and never ever personal interests as is the case with this dual citizenship endangerment and threat to our territorial independence, national existence, and sovereign jurisdiction, and the PRIDE, DIGNITY, AND MORALE, OF THE MAJORITY - THE MASSES!
DORTU-SIBOE DOE at 04:33AM, 2016/01/20.
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