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  1. Would Excluding All Muslim Immigrants Violate The Constitution? Roger Algase

    Unthinkable as it may have seemed only a week or two ago, Donald Trump's latest proposal to bar all Muslim immigrants from entering the United States has now taken America back to the point of having to interpret late 19th Century Supreme Court Decisions regarding the notorious Chinese Exclusion Laws to see if such a ban would be permitted by the Constitution.

    As is well known, but most Americans would prefer to forget, the Supreme Court ruled, most notably in Chae Chan Ping v. US, 130 U.S. 581 (1889) that excluding immigrants on the basis of race did not violate the US Constitution, which give the federal government "plenary power" over immigration.

    In that decision, using openly racist language that was typical of that era, Justice Field, writing for the Court, referred to the power of the federal government to protect the nation against "aggression and encroachment" from "vast hordes of its [a foreign nation's] people crowding in among us." He stated, in words that have become infamous in America's legal history:

    " If, therefore, the government of the United States, through its legislative department, considers the presence of foreigners of a different race in this country, who will not assimilate with us, to be dangerous to its peace and security, their exclusion is not to be stayed..."

    The notion that this 126 year-old decision, representing one of the darkest periods of prejudice ever known in America, could even be looked to a precedent for determining the Constitutionality of any law regarding entry into the US today, is disturbing enough. But in the opinion of one legal scholar, Natsu Taylor Saito, a professor of law at Georgia State University and expert on the legal history of race and plenary power in immigration law, a ban on Muslim immigrants might be permissible on the basis of the Chae decision, even though if the exclusion is phrased in terms of religion rather than race.

    Huffington Post
    quotes Professor Saito as follows, referring to Trump's proposal in relation to the Chinese Exclusion laws :

    "I don't think this is significantly different...It is targeting people on the basis of religion rather than national origin. But we all know that this particular targeting of Muslims is highly racialized and tied to national origins. So I think it is similar."

    Huffington Post also cites Stephen Legomsky, former USCIS general counsel, as agreeing that the Supreme Court's decision under the Chinese Exclusion Act would be authority of upholding a Trump-style ban on Muslim visitors - it is not clear whether Legomsky meant all immigrants - if Congress were to enact such a law. See:

    The above raises two important questions: First, since the Chae Chan Ping case also makes clear that plenary power over immigration rests with the federal government only, and that it is an area over which the states have no power, would this decision not be authority for throwing out the lawsuit by Texas and 25 other states seeking to block President Obama's DAPA and DACA extension initiatives?

    Would the same decision not be even stronger authority for dismissing the lawsuit by Texas seeking to bar the federal government from relocating Syrian refugees in that state?

    Second, and perhaps most importantly, since free exercise of religion is expressly protected and establishment of religion is prohibited by the Constitution, would there not be a distinction between Trump's proposal and the notorious Chinese exclusion laws?

    Is Trump's proposal to discriminate among immigrants purely on the basis of religion not going beyond even the Chinese exclusion laws themselves in raising question as to Constitutionality?

    These questions will be explored in more detail in an upcoming post.
    Roger Algase is a New York immigration lawyer and a graduate of Harvard College and Harvard Law School. He has been helping mainly skilled and professional immigrants from many parts of the world obtain work visas and green cards for more than 35 years. Roger's email address is

    Updated 12-09-2015 at 12:30 PM by ImmigrationLawBlogs

  2. Neo-Nazi Says "Heil" to Trump's Proposal To Bar All Muslim Immigrants. Roger Algase

    Update: December 8, 3:23 pm

    For a legal argument to the effect that Donald Trump's proposal to bar all Muslim immigrants and visitors from entering the US would not violate the US Constitution (no matter how much it would please the Neo-Nazis) see the Huffington Post article cited immediately below. This argument is based on the proposition that the 19th Century Supreme Court decisions upholding the infamous Chinese exclusion laws have never been overruled and are still valid today. See:

    What this says about the foundations of our current immigration laws is a matter which deserves discussion in a future comment.

    My original post follows:

    Huffington Post reports that Andrew Anglin, publisher of the neo-Nazi website Daily Stormer has greeted Donald Trump's proposal to bar all Muslims from coming to the US as immigrants or visitors with the following comment:

    "Heil Donald Trump THE ULTIMATE SAVIOR"

    Under the headline:

    "Glorious Leader Calls For Complete Ban on All Muslims"

    Anglin wrote:

    "Finally: someone speaks sense...Make America White Again!"

    Evidently, as shown by the above, the reaction to Trump's proposal has not been entirely negative, even though no other Republican presidential candidates have supported this radical idea, and three of them, Marco Rubio (FL), Lindsey Graham (SC), and John Kasich (OH) have even been able to find the courage to criticize Trump directly over this issue.

    Huffington Post also reports that the Daily Stormer had already previously endorsed Trump for president. One has to wonder whether Trump's proposal to send a special force to round up unauthorized immigrants for deportation might have appealed to the publisher of a site with the name The Stormer (obviously named after the notorious Nazi publication Der Stuermer led by Julius Streicher, who was later executed as a war criminal).

    However, Trump has also reportedly said that he is not in favor of rounding up Muslim US citizens and sending them to "relocation" camps, as was done with Japanese-Americans during WW2. Maybe he should not be so sure of The Stormer's continuing support.

    The Huffpost story is available at:
    Roger Algase is a New York immigration lawyer and a graduate of Harvard College and Harvard Law School. For more than 35 years, he has been helping primarily skilled and professional immigrants obtain work visas and green cards.

    His main areas of practice are H-1B skilled worker and O-1 artist and professional work visas; and green cards through labor certification, extraordinary ability, and opposite sex or same sex marriage. Roger's email address is

    Updated 12-08-2015 at 03:23 PM by ImmigrationLawBlogs

  3. Calif. Tried To Bar Vietnamese Then. Texas Is Doing It To Syrians Now. Roger Algase

    Update: 9:48 pm. December 7

    No, this does not appear to be part of any comedy or reality show that I have ever heard of. Trump actually wants to cut off all immigration - for all Muslims. Period.

    Let us hope that Trump has finally had his self-destruct moment that all the other Republican candidates and the rest of the nation have been waiting for. It is time for America to tell Trump: "You're fired."

    This post has been revised and updated as of 10:32 am, December 7:

    President Obama, in his December 6 speech to the nation about the terror threat in the US, misstated the immigration category that the female San Bernardino terrorist, Tashfeen Malik, used to enter the US.

    The president incorrectly said that she came in with a visa waiver. In reality, she came in with a K-1 fiancee visa. The president also promised to take a closer look at the visa waiver program. This may, intentionally, or otherwise, have been his way of rejecting the jingoistic, demagogic calls by Donald Trump and other anti-immigrant ideologues to tamper with or abolish the fiance visa.

    The president had little to say specifically about admitting refugees, other than that there should be no religious test for doing so. One might have hoped for a stronger statement against exploiting fear or bigotry against refugees from Syria or other Muslim countries, as Texas is attempting to do in its lawsuit referred to below, and as some 30 state governors are doing in their illegal and un-Constitutional threat to bar Syrian refugees from their states.

    However, the president did make clear that he will not give into calls to discriminate against American Muslims, or Muslim immigrants in general.

    A slightly revised version of my original comments follows below:

    This past weekend, I ran into a friend who grew up in Texas and whose parents, who came to the US as Vietnamese refugees, still live in that state. Texas is now the plaintiff in a highly controversial lawsuit aimed at usurping federal power over immigration and violating equal protection and anti-discrimination guarantees by barring all Syrian refugees from that state, as contended by the defendant International Rescue Committee in that case.

    Attempts by Texas governor Greg Abbott to keep Syrian refugees out of Texas have also been strongly condemned by editorials in many local newspapers throughout that state. See:

    Details of the arguments in that lawsuit, which is now before a federal district judge in Dallas, will be discussed in an upcoming comment.

    My friend was born in the US, but knows a good deal about the Vietnamese refugee experience from her family and their community. We got to talking about the parallels between attitudes that Vietnamese refugees faced when they came to America in the 1970's and those that Syrian refugees are encountering today in trying to settle in America.

    Few, if any, people would raise any serious doubt that today, the Vietnamese communities in Texas and other states are among America's most successful and well-regarded immigrant communities. Vietnamese immigrants are especially known for their entrepreneurial spirit and their tendency to vote Republican! according to Alicia Campi of the Immigration Policy Center, writing a few years ago in See: From Refugees to Americans: Thirty Years Of Vietnamese Immigration To The United States,0313-campi-shtm

    However, Vietnamese refugees were initially far from welcome in the US. Many Americans looked on Vietnamese as potential Communist agents then, just as Syrian Muslim refugees are being stigmatized as alleged security threats today.

    None other than Jerry Brown, governor of California today, tried to keep Vietnamese refugees out of his state when he was also governor of that state 40 years ago, in 1975. See:

    Gov. Jerry Brown 1975: Don't 'Dump Vietnamese' refugees on California (July 2, 2014)

    According to

    "In 1975, Jerry Brown complained that the federal government wanted to 'dump Vietnamese' on California...

    The new governor of California, Jerry Brown, was very concerned about refugees settling in his state. Brown even tried to prevent planes carrying refugees from landing at Travis Air Force Base near Sacramento...the secretary of health and welfare, Mario Obledo, felt that this addition of a large minority group would be unwelcome in California. And he said they already had a large population of Hispanics, Filipinos blacks and other minorities."

    According to the same (not necessarily neutral) site, prominent liberals, such as former Democrat presidential candidate George McGovern and today's Vice President Joe Biden, also opposed bringing large numbers of Vietnamese refugees to the US.

    Vietnamese refugees were also smeared as being Viet Cong (Communist) infiltrators, as Seattle Times columnist Tranh Tan describes was the case with her own father. Together with the Vietnamese community of his county, he brought a defamation lawsuit as a result which dragged on for 10 years. See:

    Admitting refugees from Vietnam or anywhere else has never been popular with the American public. Pew Research reports that in a 1975 Harris Poll, 49% of Americans were opposed to admitting Vietnam war refugees, with only 37% in favor.

    In 1979, when President Jimmy Carter began accepting 28,000 "boat people" refugees per month (!) from Vietnam, Laos and Cambodia, 62% of the American public disapproved, according to a CBS/New York Times poll.

    Most Americans were also opposed to letting in Hungarian refugees in the 1950's, Cuban refugees in the 1980's and Haitian refugees in the 1990's. See:

    Every time there is a new influx of refugees hoping to enter the United States, there are always new excuses for keeping them out, in addition to the old, tried and true ones that they will become criminals, drain public assistance resources, and take good jobs away from American workers (usually the latter two charges are made together at the same time).

    In the case of Vietnamese refugees, the charge was that they would be infiltrated by communists. In a country where communists had become so successful, popular and numerous that they defeated the United States of America, the most powerful country in the world, in a conventional war, how could this possibility have been ruled out?

    Yet, according to the above Pew Research article, between 1980 and 1990, almost 590,000 Indochinese refugees were admitted to the United States.

    Under the complex, or even almost impossible to meet security standards which would be imposed by anti-refugee bills now pending in the House and Senate (especially the Senate bill), it is unlikely that even a single Vietnamese refugee would ever have been admitted to this country. The conversation that I had this past weekend with the Vietnamese American whom I mentioned above would never have taken place.

    Just as her parents fled from America's communist enemies some forty years ago, the Syrian refugees, Muslim and Christian alike, are fleeing from the terrorists who want to harm the United States through attacks such as the one in San Bernardino, in which no evidence of involvement by any refugee (from any country) has so far turned up.
    Roger Algase is a New York immigration lawyer and a graduate of Harvard College and Harvard Law School. For more than 35 years, he has been helping mainly skilled and professional immigrants obtain work visas and green cards. He does not practice in the area of asylum or refugee law, but he believes that it is important to combat prejudice or discrimination aganst any group of immigrants in order to protect the rights of all immigrants.

    Roger's email address is

    Updated 12-08-2015 at 01:48 PM by ImmigrationLawBlogs

  4. Scapegoating Immigrant Spouses, Refugees, Continues After Attack Pt. 1. Roger Algase

    Update: December 5, 1:51 pm

    Huffington Post has now published the most complete information I have seen so far about the background of Tashfeen Malik, the female terrorist (and I see nothing inappropriate about using that word for someone who killed 14 innocent people in cold blood and, allegedly, also posted allegiance to ISIS on Facebook, even if the US government is still hesitating to use that word).

    The question, for purpose of my comments, is whether there was anything in her known background that could have triggered a warning sign on the part of a US visa officer doing a security check in connection with her application for a K-1 fiancee visa.

    According the Huffpost (in a December 5 article coincidentally written by a lead reporter with a somewhat similar name, Mehreen Zahra-Malik), Tashfeen Malik was born in the Punjab area of Pakistan but brought to Saudi Arabia as a toddler by her father Gulzar, who was described by a family member as becoming "more deeply religious, more conservative and more hardline" after his move to Saudi Arabia, which, even though it receives huge amounts of arms from the United States and is considered one of America's more reliable "allies" in the Middle East, is not exactly known as a bastion of human rights, religious tolerance or equality for women.

    Tashfeen Malik later returned to the same area of Pakistan as an adult to study pharmacy. According to a former Pakistani ambassador to the US, that area, including the city of Multan, where her university was located, and where her father had also built a house where he stays on visits to Pakistan, is known as a center for radical Islamist groups.

    Gulzar, evidently, had also had a dispute over a house, among other matters, with his family and was totally estranged from them. After coming to the US with the fiancee visa, getting married to Farook and having a young infant child, Tashfeen Malik evidently did not have much of an online presence, other than her Facebook profile established under an alias which was deleted for praising or promoting "acts of terror". Her name was also attached to an online gift registry for her baby.

    There does not seem to be very much in this history which would have been the basis for denial of a visa, even though perhaps, with hindsight, the Facebook post could have drawn more attention.

    There is clearly nothing in this history that would justify suspending or questioning the entire fiancee visa program, which is used only by people who are engaged to marry American citizens, or a variety of other visa programs which anti-immigrant ideologues such as Sen Jeff Sessions (R-Alabama) and other Republicans have long been attacking for any reasons they can possibly think of.

    Nor is there anything in this history that would give the State of Texas, which also happens to be the lead plaintiff in the lawsuit by 26 states seeking mass deportation of millions of Mexican and other Latino immigrants, any legal basis for its utterly groundless lawsuit seeking to bar the Federal government from resettling any Syrian refugees in that state.

    Details of that lawsuit will be discussed in Part 2 of these comments.

    The full Huffpost story can be found at:

    My previous comments and update appear below.

    Update: December 4, 3:08 pm

    A late report from the LA Times says that Syed Farook, one of the San Bernardino mass killers, had contact with two terror organizations overseas, one in Syria (Nusra Front) and one in Somalia (Shabab). The massacre is now being investigated as a terror attack.

    This will no doubt increase right wing political pressure to delay or deny visas in many categories to thousands, if not millions, of innocent applicants who have no connection with terrorism, and to stigmatize and scapegoat innocent Muslims and other minority immigrants and American citizens in the United States. See:

    Update: December 4, 11:48 am

    Huffpost, in a breaking story, reports that Tashfeen Malik, the female San Bernardino mass killer, allegedly pledged allegiance to ISIS on Facebook using an alias and then deleted the messages before the attack. While, this report, if true, would indicate that she and her husband became radicalized somewhere along the line, a possibility that no one has ever ruled out and which has been under investigation, according to news reports, there is still no indication that ISIS was actually involved in the attack.

    However the fact that Farook and Malik, by all indications that are known so far, appear to have been lone wolves, however radicalized, will certainly not deter the Islamophobes, nativists and other immigrant haters from trying to make hundreds of thousands of refugees and other would-be immigrants, who have every reason in the world to loathe and detest ISIS and radical Islam, scapegoats for the horrible crime that took place in San Bernardino - one that could very possibly have been prevented by effective gun control laws. See:

    My original post follows:

    No one should underestimate the seriousness of the December 2 San Bernardino attack which killed 14 people during a holiday party at a center for disabled people and caused terrible panic and carnage. Nor is it possible at this stage to rule out the possibility of a connection with Islamist terrorists or terrorist groups.

    It appears that the couple involved in the killing, Syed Rizwan Farook and his wife, Tashfeen Malik, evidently managed to stay below the radar of federal law enforcement officials responsible for tracking terrorists in the US and overseas. But as the Los Angeles Times reports in its outstanding coverage of the attackers' background, far more thorough and detailed than that of any other media I have seen so far:

    "But the cache of pipe bombs and ammunition that the authorities found after the couple were killed by police suggested a single-minded and long-standing focus on violence."

    It is reasonable to assume that an impromptu reaction to an argument that might have broken out at the holiday party this was not. The LA Times was also one of the first, if not the first, media to report fully on the background of the couple.

    Farook was a US citizen, born in Chicago to a Pakistani immigrant father, and Farook was apparently a devout Muslim with no history of violence whatsoever. But he grew up in a home with an abusive father.

    He met Malik, who was born in Pakistan but lived most of her life in Saudi Arabia, online and traveled to Saudi Arabia for nine days in the summer of 2014, bringing her back to the US with a legal fiancee visa, one which requires full security background checks.

    There was, apparently, no history of terrorist connections or radicalization either during Farook's brief stay in Saudi Arabia or after his return. The LA Times also reports that Farook's older brother, Syed Raheel, served in the navy and was awarded two medals for service in the "Global War on Terrorism".

    The couple also had a six-month old baby and they seemed like normal parents of new-born child, even to the point of considerately leaving their baby with its grandmother before setting off on their horrific killing spree.

    For the full report, see:

    Based on the above history, it is difficult to see how even the most intensive security background checks and vetting could have turned up any indication that this couple could turn into mass killers or terrorists along the lines of "Bonnie and Clyde" (my comparison - I have not seen it yet anywhere in the media).

    But even though checking them for possible terrorist or jihadist connections apparently came up blank, there is one small detail that would have shown that this was not an ordinary suburban couple and that something very big and dangerous, possibly even much worse that the mass killing which actually took place, might have been afoot.

    This minor little detail was that the couple had manged to amass an arsenal of weapons which the LA Times, in the above report, describes as follows:

    "San Bernardino police chief Jarrod Burguan says officers found 1,400 assault rifle rounds and another 200 handgun rounds in the couple's rental car. Inside the pair's apartment, authorities recovered an additional 2,000 handgun rounds, 2,500 assault rifle rounds, a dozen pipe bombs and hundreds of tools for bomb making."

    If America had realistic and decent gun control laws, like most of the rest of the world, surely this couple would not have been able to amass such a potentially destructive arsenal undetected. Bells would have undoubtedly begun to ring somewhere.

    But for our politicians, especially within the Republican party, even mentioning the words "gun control" is absolutely off limits, totally unthinkable, no matter how many thousands of Americans die in gun violence each year, far more even than the number who died in the 9/11 attacks almost 15 years ago. What is their formula for protecting the American people from further violence and mass, killings, therefore?

    It is to continue scapegoating immigrants by restricting or eliminating visas that have been used by millions of innocent, law abiding people up to now, especially fiance and refugee visas.

    The LA Times reports (early on December 4) that Dan Stein, president of the Federation for Immigration Reform (FAIR), which has a long and vocal record of opposing virtually all immigration, is now attempting to use the San Bernardino attack as pretext to suggest that all visas, including fiance visas, should be looked at as potentially dangerous to US security because "proper screening and not always possible." See:


    The above story also quotes Reshma Samasunder, executive director of the California Immigrant Policy Center, as responding with a call for reason and tolerance. In her words:

    "We call upon all Californians to stand against scapegoating and ensure that the horrible actions of a few are not used to scapegoat entire communities who are a fundamental part of our state and nation."

    On the same day, Sens. Ted Cruz (R - Texas) and Jeff Sessions (R - Alabama), who have also been consistently against just about every from of immigration, legal and illegal, went even further in using San Bernardino as an excuse to scapegoat millions of immigrants who are unlikely ever to have even the remotest connection with Islamist radicalism.

    The following is an extract from their December 3 letter to the Secretaries of the US Department of Homeland Security and Department of State, as well as the Attorney General:

    "In our struggle against terrorism, we are dealing with an enemy that has shown it is not only capable of bypassing US screening, but of recruiting and radicalizing Muslim migrants after their entry into the United States. The recruitment of terrorists in the US is not limited to adult migrants, but to their young children and their US-born children - which is why family immigration history is necessary to understand the nature of the threat."

    Let us look at for a moment at the amazing implications of the above statement. The Senators are not talking here about individual responsibility, which has always been at the heart of American law, but of family responsibility, at least where possible terrorism is concerned.

    Based on the logic of this letter, Syed Farook's Pakistani-born father, who has never been connected with any terrorism or violence whatsoever, and whose older son has received two medals for his service in the US navy in support of the War on Terrorism, should never have been allowed into the United States because his (as yet unborn) younger son would one day become a mass killer.

    Based on this logic, one can also expect that Farook and Malik's six month-old American-born baby (or possibly her future children or grandchildren) will be under close observation for possible jihadist sympathies when she grows up.

    To be continued.
    Roger Algase is a New York immigration lawyer and a graduate of Harvard College and Harvard Law School. For more than 35 years, he has been helping mainly skilled and professional immigrants obtain work visas and green cards. He believes that immigration law not only depends on technical rules, but also involves issues of basic human rights, fundamental fairness and equal justice under the law.

    Rogers's email address is

    Updated 12-05-2015 at 03:37 PM by ImmigrationLawBlogs

  5. Should Fiance Visas Be Abolished Due To San Bernardino Shooting? By Roger Algase

    Update: December 3, 4:05 pm

    An even later LA Times report says that Syed's Farook's wife or companion, Tashfeen Maiik, was in the US on a visa from Pakistan (it does not say what kind), and that the couple had made one or more trips to Pakistan, which could mean anything. There is still no report of any terror organization being involved in the mass shooting at San Bernardino.

    Update, December 3, 3:04 pm.

    The information about the two San Bernardino shooting suspects, Syed Rizwan Farook and his companion (or wife) Tashfeen Malik, continues to be confusing. A late report from the LA Times says that she may have originally been from Pakistan, not Saudi Arabia. The report also says that Syed (a US born American citizen) apparently grew up with an abusive father.

    This might indicate a personal motive for the mass shooting attack, but on the other hand, as police officials have pointed out, there seems to have been a good deal of advance paramilitary style preparation.

    So far as I am aware, no terrorist group has claimed any involvement or responsibility in this incident.

    The LA Times report is at:

    My previous update and original post follow:

    While it is far too soon to make any definitive comment about the motives for the horrendous mass shooting which killed 14 people in San Bernardino, California on December 2, the Los Angeles Times reports that the two killer suspects, both Muslims, were husband and wife, with a 6-month old baby. The husband, Syed Riswan Farook, was reportedly an American-born US citizen, who met his wife, Tashfeen Malik, online and traveled to Saudi Arabia to see her in person.

    While there has been no mention in the press about her immigration status, it would seem to be possible that she may have come to the US with a K fiancee visa, or that if they married in Saudi Arabia, she might have come to the United States as a lawful US permanent resident based on the marriage.

    Neither scenario would lend any support to the latest current attempts to scapegoat and demonize immigrants, namely the calls for barring Syrian refugees from the United States and the movement to carry out mass deportations against unauthorized Mexican and mainly Latin American immigrants.

    Whether there is a possible connection with ISIS or some other jihadist terrorist organization is still under investigation. No such organization has as yet claimed responsibility for this attack, which is reported to be the 355th mass shooting in America this year.

    It is not likely that the haters and xenophobes will lose any time in blaming all Muslim immigrants, or all Muslims and all immigrants, for this horrific attack. Do not hold your breath waiting for anyone to blame all Christians or other non-Muslims for the 354 other mass shootings in America so far this year. The double standard is still in effect.

    Most of all, do not spend any time waiting for our politicians to do anything about the easy access to guns which has enabled shooting attacks to take place in America more times in 2015 than there have been days in this year so far.

    The LA Times report is available at

    I have also been critical of two bills now pending in Congress, one in the Senate and the other in the House, which would place additional security check barriers in the way of Syrian refugees which are obviously intended either to create a long delay or to make it virtually impossible for these refugees to come to the United States at all.

    In the wake of yesterday's latest mass shooting, I would now be willing to support these two bills with one change: instead of requiring the lengthy, enhanced and cumbersome (if not totally impossible to comply with) additional background checks for Syrian refugees, these background security checks should apply to anyone seeking to buy a gun in the United States.

    Then we might be able to save more than 10,000 American lives each year that are now being lost to uncontrolled gun violence committed by people of whatever religion, belief, or immigration/citizenship status.
    Roger Algase is a New York immigration lawyer and a graduate of Harvard College and Harvard Law School. For more than 35 years, he has been helping mainly skilled and professional immigrants obtain work visas and green cards. Roger does not practice in the fields of refugee or asylum law, but he believes that all immigrants are entitled to basic human rights, including fair treatment and equal justice before the law.

    Roger's email address is

    Updated 12-03-2015 at 04:06 PM by ImmigrationLawBlogs

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