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United States News
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Title: University of California, Janet Napolitano v DHS, DACA Complaint
Source: [None]
URL Source: [None]
Published: Sep 14, 2017
Author: nolu chan
Post Date: 2017-09-14 18:33:55 by nolu chan
Keywords: None
Views: 3036
Comments: 20

University of California, Janet Napolitano v DHS, DACA Complaint

nolu chan
September 14, 2017

http://universityofcalifornia.edu/sites/default/files/UC-DACA-Complaint.pdf

University of California v. U.S. Department of Homeland Security, CAND 3-17-cv-05211, Doc 1, (8 Sep 2017), COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

Plaintiffs are The Regents of the University of California, and Janet Napolitano, in her official capacity as President of the University of California.

1. This lawsuit, brought under the Due Process Clause of the Fifth Amendment to the United States Constitution and the Administrative Procedure Act (“APA”), 5 U.S.C. § 706, challenges Defendants’ unlawful decision to rescind the Deferred Action for Childhood Arrivals (“DACA”) program, which protected from deportation nearly 800,000 individuals brought to this country as children, known as Dreamers. Under DACA, the Dreamers, who came to the United States through no choice of their own, who have clean records, and who have lived continuously in the United States since 2007, were permitted to live, work, and study in this country without fear of deportation. The United States, and the University, have benefited enormously from the presence of the Dreamers, accomplished young men and women who are our students, and colleagues, and neighbors. They are Americans, a fact that Defendants’ precipitous decision cannot change.

There are only two paths to American citizenship:

  • a natural born citizen, one who becomes a citizen at birth.

  • a naturalized citizen

protected from deportation nearly 800,000 individuals brought to this country as children, known as Dreamers ILLEGAL ALIENS.

There, fixed it.

From the DACA implementing memorandum of June 15, 2012, by none other than then-DHS Secretary Janet Napolitano herself,

This memorandum confers no substantive right, immigration status or pathway to citizenship. Only Congress, acting through its legislative authority, can confer these rights.

All DACA-eligible persons were/are illegal aliens.

None is a natural born citizen of the United States.

Whether they evaded immigration officials altogether, or overstayed a lawful but time-limited visa, they are not lawfully present in the country.

https://www.irs.gov/individuals/international-taxpayers/immigration-terms-and-definitions-involving-aliens

Illegal Alien

Also known as an "Undocumented Alien," is an alien who has entered the United States illegally and is deportable if apprehended, or an alien who entered the United States legally but who has fallen "out of status" and is deportable.

Whether the illegal alien never had status, or has fallen out of status, the only legal path available to attain lawful status is to exit and return lawfully (or some special action by Congress to cange the law).

Those who evaded immigration officials enjoy no municipal status. As a legal fiction, for immigration purposes, they are not considered to have entered the country. The only thing they can do to attain status is to leave the country and return legally.

To be eligible for naturalization one must be:

  • an alien

  • lawfully present in the United States

Persons not lawfully present in the United States are not eligible for naturalization. Normally, aliens lawfully present can petition for naturalization. In her DACA implementing memorandum, Ms. Napolitano recognized that it would take legislative authority to confer immigration status or a pathway to citizenship for these illegal aliens. It is because they are illegal aliens, and have no lawful status, that current law provides them no pathway to United States citizenship.

As Ms. Napolitano documented with her DACA implementing memo. neither she nor the President of the United States had the authority to convert aliens, unlawfully present in the United States, into United States citizens, or to grant or regulate their immigration status.

They are Americans, a fact that Defendants’ precipitous decision cannot change.

They may be Americans in the generic sense of being citizens of someplace in North or South America other than the United States of America.

The apparent, and deceptive nature of the statement to imply that these illegal aliens are of the United States of America, is but a lie. By the very terms of the DACA policy, they must be from a foreign country.

RELATED:

http://libertysflame.com/cgi-bin/readart.cgi?ArtNum=52708

Trump Illegal Alien Executive Orders - Follow the Litigation Bouncing Ball

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Begin Trace Mode for Comment # 7.

#3. To: All (#0)

This is the 5th Circuit DAPA opinion, which affirmed the killing of DAPA and the expansion of DACA. SCOTUS tied 4-4 on this one while the Court only had eight justices. That result left this 5th Circuit opinion stand. The rationale seems applicable to DACA, and in several places, the Court said as much. Now Justice Gorsuch is at SCOTUS to break any 4-4 tie.

[footnotes omitted]

Texas et al v. U.S., 15-40238 (5th Cir. 9 Nov 2015, Rev. 28 Nov 2015)

REVISED November 25, 2015

IN THE UNITED STATES COURT OF APPEALS
FOR THE FIFTH CIRCUIT

At 2:

[*2]

No. 15-40238

Before KING, SMITH, and ELROD, Circuit Judges.

JERRY E. SMITH, Circuit Judge:

The United States appeals a preliminary injunction, pending trial, forbidding implementation of the Deferred Action for Parents of Americans and Lawful Permanent Residents program (“DAPA”). Twenty-six states (the “states”) challenged DAPA under the Administrative Procedure Act (“APA”) and the Take Care Clause of the Constitution; in an impressive and thorough Memorandum Opinion and Order issued February 16, 2015, the district court enjoined the program on the ground that the states are likely to succeed on their claim that DAPA is subject to the APA’s procedural requirements. Texas v. United States, 86 F. Supp. 3d 591, 677 (S.D. Tex. 2015).

The government appealed and moved to stay the injunction pending resolution of the merits. After extensive briefing and more than two hours of oral argument, a motions panel denied the stay after determining that the appeal was unlikely to succeed on its merits. Texas v. United States, 787 F.3d 733, 743 (5th Cir. 2015). Reviewing the district court’s order for abuse of discretion, we affirm the preliminary injunction because the states have standing; they have established a substantial likelihood of success on the merits of their procedural and substantive APA claims; and they have satisfied the other elements required for an injunction.

[*3]

I.

A.

In June 2012, the Department of Homeland Security (“DHS”) implemented the Deferred Action for Childhood Arrivals program (“DACA”). In the DACA Memo to agency heads, the DHS Secretary “set[] forth how, in the exercise of . . . prosecutorial discretion, [DHS] should enforce the Nation’s immigration laws against certain young people” and listed five “criteria [that] should be satisfied before an individual is considered for an exercise of prosecutorial discretion.” The Secretary further instructed that “[n]o individual should receive deferred action . . . unless they [sic] first pass a background check and requests for relief . . . are to be decided on a case by case basis.” Although stating that “[f]or individuals who are granted deferred action . . . , [U.S. Citizenship and Immigration Services (“USCIS”)] shall accept applications to determine whether these individuals qualify for work authorization,” the DACA Memo purported to “confer[] no substantive right, immigration status or pathway to citizenship.” At least 1.2 million persons qualify for DACA, and approximately 636,000 applications were approved through 2014.

[*4]

Dist. Ct. Op., 86 F. Supp. 3d at 609.

In November 2014, by what is termed the “DAPA Memo,” DHS expanded DACA by making millions more persons eligible for the program10 and extending “[t]he period for which DACA and the accompanying employment authorization is granted . . . to three-year increments, rather than the current two-year increments.” The Secretary also “direct[ed] USCIS to establish a process, similar to DACA,” known as DAPA, which applies to “individuals who . . . have, [as of November 20, 2014], a son or daughter who is a U.S. citizen or lawful permanent resident” and meet five additional criteria.12 The Secretary stated that, although “[d]eferred action does not confer any form of legal status in this country, much less citizenship[,] it [does] mean[] that, for a specified period of time, an individual is permitted to be lawfully present in the United States.” Of the approximately 11.3 million illegal aliens in the United

[*5]

States, 4.3 million would be eligible for lawful presence pursuant to DAPA. Dist. Ct. Op., 86 F. Supp. 3d at 612 n.11, 670.

“Lawful presence” is not an enforceable right to remain in the United States and can be revoked at any time, but that classification nevertheless has significant legal consequences. Unlawfully present aliens are generally not eligible to receive federal public benefits, see 8 U.S.C. § 1611, or state and local public benefits unless the state otherwise provides, see 8 U.S.C. § 1621.15 But as the government admits in its opening brief, persons granted lawful presence pursuant to DAPA are no longer “bar[red] . . . from receiving social security

[*6]

retirement benefits, social security disability benefits, or health insurance under Part A of the Medicare program.”

16 That follows from § 1611(b)(2)–(3), which provides that the exclusion of benefits in § 1611(a) “shall not apply to any benefit[s] payable under title[s] II [and XVIII] of the Social Security Act . . . to an alien who is lawfully present in the United States as determined by the Attorney General . . . .” (emphasis added). A lawfully present alien is still required to satisfy independent qualification criteria before receiving those benefits, but the grant of lawful presence removes the categorical bar and thereby makes otherwise ineligible persons eligible to qualify.

“Each person who applies for deferred action pursuant to the [DAPA] criteria . . . shall also be eligible to apply for work authorization for the [renewable three-year] period of deferred action.” DAPA Memo at 4. The United States concedes that “[a]n alien with work authorization may obtain a Social Security Number,” “accrue quarters of covered employment,” and “correct wage records to add prior covered employment within approximately three years of the year in which the wages were earned or in limited circumstances there-after.”17 The district court determined―and the government does not dispute―“that DAPA recipients would be eligible for earned income tax credits once they received a Social Security number.”18

As for state benefits, although “[a] State may provide that an alien who is not lawfully present in the United States is eligible for any State or local public benefit for which such alien would otherwise be ineligible under

[*7]

subsection (a),” § 1621(d), Texas has chosen not to issue driver’s licenses to unlawfully present aliens.19 Texas maintains that documentation confirming lawful presence pursuant to DAPA would allow otherwise ineligible aliens to become eligible for state-subsidized driver’s licenses. Likewise, certain unemployment compensation “[benefits are not payable based on services performed by an alien unless the alien . . . was lawfully present for purposes of performing the services . . . .”20 Texas contends that DAPA recipients would also become eligible for unemployment insurance.

B.

The states sued to prevent DAPA’s implementation on three grounds. First, they asserted that DAPA violated the procedural requirements of the APA as a substantive rule that did not undergo the requisite notice-and-comment rulemaking. See 5 U.S.C. § 553. Second, the states claimed that DHS lacked the authority to implement the program even if it followed the correct rulemaking process, such that DAPA was substantively unlawful under the APA. See 5 U.S.C. § 706(2)(A)–(C). Third, the states urged that DAPA was an abrogation of the President’s constitutional duty to “take Care that the Laws be faithfully executed.” U.S. CONST. art. II, § 3.

At 47-50: [footnotes omitted]

The DACA and DAPA Memos purport to grant discretion, but a rule can be binding if it is “applied by the agency in a way that indicates it is binding,”136 and there was evidence from DACA’s implementation that DAPA’s discretionary language was pretextual. For a number of reasons, any extrapolation from DACA must be done carefully.137

First, DACA involved issuing benefits to self-selecting applicants, and persons who expected to be denied relief would seem unlikely to apply. But the issue of self-selection is partially mitigated by the finding that “the [g]overnment has publicly declared that it will make no attempt to enforce the law against even those who are denied deferred action (absent extraordinary circumstances).” Dist. Ct. Op., 86 F. Supp. 3d at 663 (footnote omitted).

Second, DACA and DAPA are not identical: Eligibility for DACA was

-47-

- - - - - - - - - -

restricted to a younger and less numerous population,138 which suggests that DACA applicants are less likely to have backgrounds that would warrant a discretionary denial. Further, the DAPA Memo contains additional discretionary criteria: Applicants must not be “an enforcement priority as reflected in the [Prioritization Memo]; and [must] present no other factors that, in the exercise of discretion, makes the grant of deferred action inappropriate.” DAPA Memo at 4. But despite those differences, there are important similarities: The Secretary “direct[ed] USCIS to establish a process, similar to DACA, for exercising prosecutorial discretion,” id. (emphasis added), and there was evidence that the DACA application process itself did not allow for discretion, regardless of the rates of approval and denial.139

Instead of relying solely on the lack of evidence that any DACA application had been denied for discretionary reasons, the district court found pretext for additional reasons. It observed that “the ‘Operating Procedures’ for implementation of DACA contains nearly 150 pages of specific instructions for granting or denying deferred action to applicants” and that “[d]enials are

-48-

- - - - - - - - - -

recorded in a ‘check the box’ standardized form, for which USCIS personnel are provided templates. Certain denials of DAPA must be sent to a supervisor for approval[, and] there is no option for granting DAPA to an individual who does not meet each criterion.” Dist. Ct. Op., 86 F. Supp. 3d at 669 (footnotes omitted). The finding was also based on the declaration from Palinkas that, as with DACA, the DAPA application process itself would preclude discretion: “[R]outing DAPA applications through service centers instead of field offices . . . created an application process that bypasses traditional in-person investigatory interviews with trained USCIS adjudications officers” and “prevents officers from conducting case-by-case investigations, undermines officers’ abilities to detect fraud and national-security risks, and ensures that applications will be rubber-stamped.” See id. at 609–10 (citing that declaration).

As the government points out, there was conflicting evidence on the degree to which DACA allowed for discretion. Donald Neufeld, the Associate Director for Service Center Operations for USCIS, declared that “deferred action under DACA is a . . . case-specific process” that “necessarily involves the exercise of the agency’s discretion,” and he purported to identify several instances of discretionary denials.140 Although Neufeld stated that approximately 200,000 requests for additional evidence had been made upon receipt of DACA applications, the government does not know the number, if any, that related to discretionary factors rather than the objective criteria. Similarly,

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- - - - - - - - - -

the government did not provide the number of cases that service-center officials referred to field offices for interviews.141

Although the district court did not make a formal credibility determination or hold an evidentiary hearing on the conflicting statements by Neufeld and Palinkas, the record indicates that it did not view the Neufeld declaration as creating a material factual dispute.142 Further, the government did not seek an evidentiary hearing, nor does it argue on appeal that it was error not to conduct such a hearing. Reviewing for clear error, we conclude that the states have established a substantial likelihood that DAPA would not genuinely leave the agency and its employees free to exercise discretion.

...

-50-

At 56-60: [footnotes omitted]

Congress has enacted an intricate process for illegal aliens to derive a lawful immigration classification from their children’s immigration status: In general, an applicant must (i) have a U.S. citizen child who is at least twenty-one years old, (ii) leave the United States, (iii) wait ten years, and then (iv) obtain one of the limited number of family-preference visas from a United States consulate.167 Although DAPA does not confer the full panoply of

-56-

- - - - - - - - - -

benefits that a visa gives, DAPA would allow illegal aliens to receive the benefits of lawful presence solely on account of their children’s immigration status without complying with any of the requirements, enumerated above, that Congress has deliberately imposed. DAPA requires only that prospective beneficiaries “have . . . a son or daughter who is a U.S. citizen or lawful permanent resident”—without regard to the age of the child—and there is no need to leave the United States or wait ten years168 or obtain a visa.169 Further, the INA does not contain a family-sponsorship process for parents of an LPR child,170 but DAPA allows a parent to derive lawful presence from his child’s LPR status.

The INA authorizes cancellation of removal and adjustment of status if, inter alia, “the alien has been physically present in the United States for a continuous period of not less than 10 years immediately preceding the date of such application” and if “removal would result in exceptional and extremely unusual hardship to the alien’s spouse, parent, or child, who is a citizen of the United States or an alien lawfully admitted for permanent residence.” 8 U.S.C. § 1229b(b)(1)(A) (emphasis added). Although LPR status is more substantial than is lawful presence, § 1229b(b)(1) is the most specific delegation of authority to the Secretary to change the immigration classification of removable aliens that meet only the DAPA criteria and do not fit within the specific

-57-

- - - - - - - - - -

categories set forth in § 1229b(b)(2)–(6).

Instead of a ten-year physical-presence period, DAPA grants lawful presence to persons who “have continuously resided in the United States since before January 1, 2010,” and there is no requirement that removal would result in exceptional and extremely unusual hardship. DAPA Memo at 4. Although the Secretary has discretion to make immigration decisions based on humanitarian grounds, that discretion is conferred only for particular family relationships and specific forms of relief—none of which includes granting lawful presence, on the basis of a child’s immigration status, to the class of aliens that would be eligible for DAPA.171

The INA also specifies classes of aliens eligible172 and ineligible173 for work authorization, including those “eligible for work authorization and deferred action”―with no mention of the class of persons whom DAPA would make eligible for work authorization. Congress “‘forcefully’ made combating the employment of illegal aliens central to ‘[t]he policy of immigration law,’”174 in part by “establishing an extensive ‘employment verification system,’ designed to deny employment to aliens who . . . are not lawfully present in the

-58-

- - - - - - - - - -

United States.”175

The INA’s careful employment-authorization scheme “protect[s] against the displacement of workers in the United States,”176 and a “primary purpose in restricting immigration is to preserve jobs for American workers.”177 DAPA would dramatically increase the number of aliens eligible for work authorization, thereby undermining Congress’s stated goal of closely guarding access to work authorization and preserving jobs for those lawfully in the country.

DAPA would make 4.3 million otherwise removable aliens eligible for lawful presence, employment authorization, and associated benefits, and “we must be guided to a degree by common sense as to the manner in which Congress is likely to delegate a policy decision of such economic and political magnitude to an administrative agency.”178 DAPA undoubtedly implicates “question[s] of deep ‘economic and political significance’ that [are] central to this statutory scheme; had Congress wished to assign that decision to an agency, it surely would have done so expressly.”179 But assuming arguendo that Chevron applies and that Congress has not directly addressed the precise

-59-

- - - - - - - - - -

question at hand, we would still strike down DAPA as an unreasonable interpretation that is “manifestly contrary” to the INA. See Mayo Found., 562 U.S. at 53.

...

-60-

At 64-66: [footnotes omitted]

...

DAPA is far from interstitial: Congress

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- - - - - - - - - -

has repeatedly declined to enact the Development, Relief, and Education for Alien Minors Act (“DREAM Act”),199 features of which closely resemble DACA and DAPA.

Historical practice that is so far afield from the challenged program sheds no light on the Secretary’s authority to implement DAPA. Indeed, as the district court recognized, the President explicitly stated that “it was the failure of Congress to enact such a program that prompted him . . . to ‘change the law.’”200 At oral argument, and despite being given several opportunities, the attorney for the United States was unable to reconcile that remark with the position that the government now takes. And the dissent attempts to avoid the impact of the President’s statement by accusing the district court and this panel majority of “relying . . . on selected excerpts of the President’s public statements.” Dissent at 24, 33 n.41.

The dissent repeatedly claims that congressional silence has conferred on DHS the power to act. E.g., Dissent at 46–47. To the contrary, any such inaction cannot create such power:

“[D]eference is warranted only when Congress has left a gap for the agency to fill pursuant to an express or implied ‘delegation of authority to the agency.’” Chevron[,] 467 U.S. at 843–44[]. To suggest, as the [agency] effectively does, that Chevron step two is implicated at any

-65-

- - - - - - - - - -

time a statute does not expressly negate the existence of a claimed administrative power . . . is both flatly unfaithful to the principles of administrative law . . . and refuted by precedent. . . . Were courts to presume a delegation of power absent an express withholding of such power, agencies would enjoy virtually limitless hegemony, a result plainly out of keeping with Chevron and quite likely with the Constitution as well.

Ethyl Corp. v. EPA, 51 F.3d 1053, 1060 (D.C. Cir. 1995).

Through the INA’s specific and intricate provisions, “Congress has ‘directly addressed the precise question at issue.’” Mayo Found., 562 U.S. at 52. As we have indicated, the INA prescribes how parents may derive an immigration classification on the basis of their child’s status and which classes of aliens can achieve deferred action and eligibility for work authorization. DAPA is foreclosed by Congress’s careful plan; the program is “manifestly contrary to the statute”201 and therefore was properly enjoined.202

At 67-70: [footnotes omitted]

...

Finally, the government reasonably speculates that the injunction burdens DAPA beneficiaries and

-67-

- - - - - - - - - -

their families and discourages them from cooperating with law-enforcement officers and paying taxes. But those are burdens that Congress knowingly created, and it is not our place to second-guess those decisions. The states have also sufficiently established that “an injunction will not disserve the public interest.” Sepulvado, 729 F.3d at 417 (quoting Byrum, 566 F.3d at 445). This factor overlaps considerably with the previous one, and most of the same analysis applies.204 The main difference is that, instead of relying on their financial interests, the states refer to the public interest in protecting separation of powers by curtailing unlawful executive action.

Although the United States cites the public interest in maintaining separation of powers and federalism by avoiding judicial and state interference with a legitimate executive function, there is an obvious difference: The interest the government has identified can be effectively vindicated after a trial on the merits. The interest the states have identified cannot be, given the difficulty of restoring the status quo ante if DAPA were to be implemented.205 The public interest easily favors an injunction.

IX.

The government claims that the nationwide scope of the injunction is an abuse of discretion and requests that it be confined to Texas or the plaintiff

-68-

- - - - - - - - - -

states. But the Constitution requires “an uniform Rule of Naturalization”;206 Congress has instructed that “the immigration laws of the United States should be enforced vigorously and uniformly”;207 and the Supreme Court has described immigration policy as “a comprehensive and unified system.”208 Partial implementation of DAPA would “detract[] from the ‘integrated scheme of regulation’ created by Congress,”209 and there is a substantial likelihood that a geographically-limited injunction would be ineffective because DAPA beneficiaries would be free to move among states.

Furthermore, the Constitution vests the District Court with “the judicial Power of the United States.”210 That power is not limited to the district wherein the court sits but extends across the country. It is not beyond the power of a court, in appropriate circumstances, to issue a nationwide injunction.211

-69-

“We expect Congress to speak clearly if it wishes to assign to an agency decisions of vast ‘economic and political significance.’” Util. Air, 134 S. Ct. at 2444 (citation omitted). Agency announcements to the contrary are “greet[ed] . . . with a measure of skepticism.” Id.

The district court did not err and most assuredly did not abuse its discretion. The order granting the preliminary injunction is AFFIRMED.

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Footnote 14 at pp. 4-5 is noteworthy:

Although “[a]s a general rule, it is not a crime for a removable alien to remain present in the United States,” it is a civil offense. Arizona v. United States, 132 S. Ct. 2492, 2505 (2012); see 8 U.S.C. §§ 1182(a)(9)(B)(i), 1227(a)(1)(A)–(B). This opinion therefore refers to such persons as “illegal aliens”:

The usual and preferable term in [American English] is illegal alien. The other forms have arisen as needless euphemisms, and should be avoided as near-gobbledygook. The problem with undocumented is that it is intended to mean, by those who use it in this phrase, “not having the requisite documents to enter or stay in a country legally.” But the word strongly suggests “unaccounted for” to those unfamiliar with this quasi-legal jargon, and it may therefore obscure the meaning.

More than one writer has argued in favor of undocumented alien . . . [to] avoid[] the implication that one’s unauthorized presence in the United States is a crime . . . . Moreover, it is wrong to equate illegality with criminality, since many illegal acts are not criminal. Illegal alien is not an opprobrious epithet: it describes one present in a country in violation of the immigration laws (hence “illegal”).

BRYAN A. GARNER, GARNER’S DICTIONARY OF LEGAL USAGE 912 (Oxford 3d ed. 2011) (citations omitted). And as the district court pointed out, “it is the term used by the Supreme Court in its latest pronouncement pertaining to this area of the law.” Dist. Ct. Op., 86 F. Supp. 3d at 605 n.2 (citing Arizona v. United States, 132 S. Ct. 2492, 2497 (2012)). “[I]legal alien has going for it both history and well-documented, generally accepted use.” Matthew Salzwedel, The Lawyer’s Struggle to Write, 16 SCRIBES JOURNAL OF LEGAL WRITING 69, 76 (2015).

nolu chan  posted on  2017-09-14   18:37:28 ET  Reply   Untrace   Trace   Private Reply  


#7. To: All (#3)

https://www.supremecourt.gov/opinions/11pdf/11-182.pdf

Arizona v. United States, 132 S. Ct. 2492 (2012). (Slip op.)

At 5: (Opinion of the Court)

Agencies in the Department of Homeland Security playa major role in enforcing the country’s immigration laws. United States Customs and Border Protection (CBP) is responsible for determining the admissibility of aliens and securing the country’s borders. See Dept. of Homeland Security, Office of Immigration Statistics, Immigration Enforcement Actions: 2010, p. 1 (2011). In 2010, CBP’s Border Patrol apprehended almost half a million people. Id., at 3. Immigration and Customs Enforcement (ICE), a second agency, “conducts criminal investigations involving the enforcement of immigration-related statutes.” Id., at 2. ICE also operates the Law Enforcement Support Center. LESC, as the Center is known, provides immigration status information to federal, state, and local officials around the clock. See App. 91. ICE officers are responsible “for the identification, apprehension, and removal of illegal aliens from the United States.” Immigration Enforcement Actions, supra, at 2. Hundreds of thousands of aliens are removed by the Federal Government every year. See id., at 4 (reporting there were 387,242 removals, and 476,405 returns without a removal order, in 2010).

The correct legal terminology is determined by the United States Supreme Court, not La Raza, or a bunch of dingbats in California, and certainly not by illegal aliens themselves.

nolu chan  posted on  2017-09-14   18:47:25 ET  Reply   Untrace   Trace   Private Reply  


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