The laws of each state determine who is a citizen and therefore, who it will protect. The Michigan Law Review 83 (1984) deals with the problem of dual nationality and how Iran-United States Claims Tribunal (1981) arbitrated claims by dual Iranian-Americans citizens, in their attempt to recover lost property. Iran claimed the duals as Iranian and therefore, under the doctrine of state nonresponsibility, as having no right to reparations, i.e., no right to the protection of the United States.