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    by , 10-09-2013 at 09:50 AM (Chris Musillo on Nurse and Allied Health Immigration)
    by Chris Musillo
    The issues described in this MU Visa Advisor are complex and very much driven by the facts of your case. Please do not hesitate to contact MU Law if you have any questions about these issues.

    The Federal Government Shutdown has caused the Department of Labor to furlough about 80% of its workforce. As a result the DOL’s iCert System, which is the manner through which LCAs are filed, has been turned off. It is impossible to file LCAs, leading to many questions from H-1B employers.

    Background: The LCA System

    The Labor Condition Application (LCA) is the centerpiece of the H-1B program. It serves two primary functions. First, it forces the H-1B employer to certify that the wage that it is offering to pay the H-1B worker is not lower than similar US workers. Second, the LCA includes a mandatory mechanism whereby H-1B employers must notify potential US workers of their right to contact the Department of Labor (DOL) if they believe that the H-1B employer is engaging in prohibited behavior.

    There are two ways that the LCA is utilized in the H-1B process. First, new H-1B petitions must be submitted with an LCA that has been certified by the DOL. Second, if an employee is going to change worksites, the employer must provide new Notice to the workers at this new worksite. In some instance, the H-1B employer must file a new LCA with the DOL and wait the seven days for the DOL to certify the new LCA. In other instances, the H-1B employer must not only obtain a new certified LCA but must also file a new H-1B.

    The Government Shutdown

    Unfortunately with the government shutdown the DOL has shuttered the LCA system. It is impossible to file LCAs. The DOL has not given the public any guidance on how to handle new H-1B petitions nor how to handle new situations where a new LCA is required.

    On account of the fact that LCAs cannot be filed, H-1B employees should not change worksites in instances where a new LCA would normally be required. This is the safest approach. Once the government shutdown ends, H-1B employers can file an LCA and the employee can move once the new LCA is certified and in place.

    On the bright side there are some instances when a new LCA is not required.

    1. When H-1B workers change worksites, but the new worksite is still within the prior LCA metropolitan area, a new LCA is not required. An H-1B employer must still post notice at the new worksite.

    2. The LCA rules allow H-1B employees to work at new worksites when the new worksite is peripatetic or very short-term. For example a new certified LCA is not required if an H-1B employee is attending meetings for a few days in a new location.

    If business needs demand that an H-1B must change worksites, then the H-1B employer must be aware that it may be technically violating law, although a legal argument could be made that compliance with the law was impossible on account of the shutdown. Penalties can range from $1,000 - $35,000 per violation. Debarment from the H-1B program could also occur. After considering these potential penalties, an H-1B employer still feels compelled to move the H-1B worker, we urge that H-1B employers take all three of these additional measures to mitigate risk:

    · Make sure to post LCA posting. Even though we would not be able to file an LCA, we would still be able to post Notice at the destination worksite. We can prepare the Notice Posting for you.
    · File an LCA at the conclusion of the shutdown.
    · File an amended H-1B at the conclusion of the shutdown and the certification of the new LCA.

    Read the Musillo Unkenholt Healthcare and Immigration Law Blog at or You can also visit us on Facebook and follow us on Twitter.
  2. Bordering on the Absurd: Immigration Expertise Lacking at U.S. Border Agency

    by , 10-09-2013 at 09:15 AM (Angelo Paparelli on Dysfunctional Government)

    [Blogger's note: Today's post offers a shocking analysis of how the decision by Congress some ten years ago to combine the functions of U.S. Customs, Immigration and Agricultural inspectors into a single agency, U.S. Customs and Border Protection (CBP), has led to disastrous consequences for applicants seeking admission to the U.S. under our nation's immigration laws. Written by a senior DHS official, now retired, shows how the supremacy of Customs over Immigration has created an error-prone, inexperienced corps of immigration officers within CBP]

    Bordering on the Absurd: Immigration Expertise Lacking at U.S. Border Agency
    By Incognito

    Once upon a time there was a government agency called the Immigration and Naturalization Service (INS), which many people hated. INS critics called upon Congress to restructure the agency, thinking that all faults would go away if that happened. Congress finally did a major restructuring, creating the Department of Homeland Security and abolishing INS. A funny thing happened on the way to restructuring, as Congress did what Congress meant to do, and not exactly as the INS critics meant for Congress to do.

    The INS inspections function transferred to the Office of Field Operations (OFO) in a new agency called U.S. Customs and Border Protection (CBP). An unintended consequence was that the observed level of immigration expertise has dropped alarmingly in CBP’s new OFO. How may this have happened?

    With any merger, there must be a melding of corporate cultures. Immigration inspectors had been part of the Department of Justice, Customs inspectors had been part of the Treasury Department, and Agriculture inspectors had been part of the Agriculture Department. With the common goal envisioned by DHS, the expectation that within a relatively short period, perhaps 1 – 3 years but not more than 5 years, the several cultures would unite into one common purpose.

    Relatively quickly, with political backing, agriculture inspectors reestablished themselves and their mission as being unique. Their critical mission has thrived in the new agency, as better resources and inspection techniques have allowed this OFO/CBP component to better protect against invasive species.

    On Day One, March 1, 2003, it was clear, however, that the former U.S. Customs Service had won the decades-old tension with INS over which agency’s culture and structure was better suited to take over the border inspections program. Ninety per cent or more of OFO/CBP’s top managers came from Customs. The expectation was that the Customs and Immigration missions would be performed adequately by the same officers. Ten years later, this realistic expectation has not been met, as observed by immigration practitioners.

    Consider this:

    In the beginning, the attitude among legacy Customs people was that the reason there was DHS restructuring was because INS had admitted alien terrorists who had carried out the 9/11 atrocities. As Congress had abolished INS as an agency, the perceived judgment was that all things Customs were good, and all things INS must be bad and not to be trusted. Also, if INS had not let “those aliens” into the country, terroristic activities would not have happened. The solution appeared obvious – just don’t let aliens into the country. However, that simple answer didn’t work, given the hundreds of millions of visitors to the country each year. Therefore, the new CBP culture fostered the idea of figuring out some reason, any reason, to not admit an alien. This culture also fit the mind-set of the INS cowboys who had made up a sub-set of the INS inspections program.

    There were a certain number of INS district, regional, and headquarters personnel who transferred to CBP. The question became, what should be done with them? After all, Customs had operated since 1789 without that resource. In that way, former INS managers, who previously had managed port of entry operations, found themselves suddenly stripped of wide-ranging responsibilities and assigned duties of little importance. Not fired, and not particularly valued, their presence was merely tolerated by the dominant culture of the new agency. Although many (especially younger field supervisors) have survived the new culture, some transferred to other agencies, and more retired when that option became available. CBP failed to stem the loss of that valuable immigration resource, with the predictable result that the quality of meaningful oversight of immigration decisions has lessened greatly.

    Similar things happened to the attorney resource that transferred from INS to CBP. The overwhelming perception from attorneys who transferred was that CBP’s Office of Chief Counsel (OCC) did not value them as attorneys knowledgeable about immigration issues, but merely as positions that could eventually be filled with the personnel that Customs wanted all along in those slots. Part of that thought came from the reality that the journeyman grade for an INS attorney was GS-14, while journeymen Customs attorneys were only GS-13s. OCC welcomed the higher graded positions, but not the incumbents. Attrition worked its toll, through transfers and retirements, quickly resulting in diminished immigration expertise in OCC. Not to worry though, because when responsibility for legal counsel on immigration inspections issues was transferred to OCC, OCC attorneys attended a two hour briefing. Emerging from the briefing, OCC deemed themselves competent to advise on all immigration complexities. Contributing to the problem, as GS-14 and -15 level former INS attorneys left CBP, they were not replaced with experienced OCC (government) attorneys, but with new kids just out of law school. Bright people, but, nonetheless, new kids on the block having no experienced immigration attorneys to mentor them.

    Are things better now? At least one field office of Associate Chief Counsel, when presented with an immigration question, simply declines to answer but refers the issue to Headquarters OCC. More than one former immigration attorney from the former INS/DOJ structure who transferred to the DHS structure has deplored the alarming lack of immigration competence in CBP’s OCC. From this, a casual observer may conclude that if OCC ever had a goal of maintaining or developing immigration expertise, it has fallen short of realizing that goal.

    Lack of knowledgeable oversight has made meaningful decision-making review more difficult. In the old INS structure, the entire chain of command, from port of entry management, to the INS district, regional, and headquarters offices, consisted of career immigration officers. The chain of command managers had the knowledge to discern weaknesses in cases when apparent ineligibilities had developed at lower levels. With expertise gained through time had come the additional experience of making decisions involving discretionary authorities. In the new CBP environment, top managers were most likely (90%) to have come from legacy Customs and had neither the experience nor the expertise to spot weaknesses in questionable immigration cases. Also, with the old INS cowboys contributing their version of law and procedure, their attitude of “The only good alien is a refused alien” gained greater dominance.

    Nor were the former Customs managers comfortable exercising discretionary authorities. The Customs culture, dealing with goods and merchandise, had developed a “good or bad” mentality. If something was good, or permitted, it was allowed entry. If something was bad, it either was not permitted entry, or penalized in some way. Therefore, the concept of detecting an inadmissible alien, but permitting that person to continue into the United States, was difficult to adjust to. Much easier just to send the inadmissible alien home, rather than take a chance of having a discretionary decision questioned by that manager’s chain of command, or agonizing whether the person who had been allowed to travel may commit some further sin.

    Contributing to the reluctance of offering discretion is the Customs culture of hanging officers out to dry for the slightest perceived infraction. Over decades, this culture had trained the Customs chain of command to pass the buck when a decision was even slightly out of the ordinary. Not having been trained to make discretionary decisions, and, in fact, having been trained to not make discretionary decisions, it is little wonder that exercising discretion was such a difficult concept to embrace.

    Over the years, criticism of discretionary decisions is no longer limited to those from the chain above. Line officers have made reports to internal affairs that supervisors are abusing discretion authority in favor of aliens thought to be inadmissible by line officers. First and second line supervisors are now damned if they do and damned if they don’t, both by chain of command or internal affairs second guessing.

    Faced with diminishing immigration expertise in OFO/CBP, and with increasing negative publicity about poor decisions at ports of entry, former Commissioner Basham asked a Headquarters working group why “immigration” seemed to be such a dirty word. The answer should have come easily from OFO/CBP’s top managers, many of whom had developed well-deserved reputations in Customs of having little regard for immigration issues and immigration personnel. Although publicly articulating allegiance to the combined immigration and customs missions, their actions spoke loudly in exposing their prejudices against that “immigration” dirty word. Is it any wonder then that line officers, trained observers as they are, pick up on the non-verbal clues noticed by Commissioner Basham when he asked why “immigration” seemed to be such a dirty word in OFO/CBP? It takes a truly determined effort for any individual officer to develop immigration expertise on the officer’s own initiative when doing so takes the officer outside the dominant agency culture.

    Note also how CBP has eliminated the term “immigration” whenever possible, largely replacing discussions of “immigration” issues with “admissibility” issues. One “Day One” proposal was that the best use of officers historically assigned to immigration secondary would be to reassign that resource to more intensive baggage examinations. There have even been top-level questions of whether OFO/CBP wasn’t now past using the term “immigration officer." Those questions eased only when reminded that Congress had chosen to keep the term “immigration officer” in the INA. After all, if OFO/CBP had no one designated as immigration officers, who would make decisions about eligibility/ineligibilities under the INA?

    Also note the mid-level field manager who recently commented, “I came from Customs, and I just don’t get this Immigration stuff.” But now we’ve gone ten years down the road in the new agency, and managers still haven’t learned to properly apply Immigration issues. If legacy Customs managers still haven’t learned, where is the fault – with the manager for refusing to learn about Immigration complexities, or for the agency for not providing training and holding managers responsible for faulty chain of command decisions on immigration issues?

    The Customs culture is alive and well. The Customs culture does not hold OFO top field managers responsible for poor decisions about immigration issues. There is a cultural lack of emphasis on developing or retaining immigration expertise, in the officer corps, among OFO managers, and in OCC. Poor decisions are supported by the attitude that OFO/CBP officers’ immigration decisions are considered, in the first instance, to be correct, in spite of the numerous examples, both publicized and not, of incorrect decision making.

    CBP’ Office of Field Operations must correct its inadequacies. Immigration practitioners can help by continuing to bring cases to OFO/CBP’s attention for correction and corrective training. If these efforts fail, there may be opportunities for reform through judicial review. Eventually, Congress may step in, again.

    Updated 10-09-2013 at 09:21 AM by APaparelli

  3. Eight Congressmen Arrested at DC Immigration Protests

    by , 10-08-2013 at 04:16 PM (Greg Siskind on Immigration Law and Policy)
    There's a popular media narrative that immigration reform is dead. But don't be fooled. Things are heating up again. Today's protest on the Capitol Hill mall is the latest example. The large protest resulted in more than 200 civil disobedience arrests including several Democratic members of Congress (Lewis, Ellison, Grivalva, Crowley, Green, Gutierrez, Schakowsky, Rangel, according to Elise Foley at Huffington Post) and immigration organizers like Frank Sharry of America's Voice. Several Republican members of Congress were spotted at the protests as well. Huffington Post has coverage of today's activity.

    Updated 10-08-2013 at 05:13 PM by GSiskind

  4. Forget the Dream Act - Just Grant Them Asylum

    It seems that advocates for "Dreamers"--young foreigners who would benefit from the Dream Act--are trying a new tactic: Leaving the country and then returning to seek asylum. Not long ago, I wrote about the Dream 9, who presented themselves at the U.S./Mexico border and requested asylum. They were released and will have to appear before Immigration Judges, who will decide their cases. Now, we have the Dream 30, who have done pretty much the same thing. This new tactic holds promise and risk, both for themselves and for other asylum seekers.

    "Dreamers" might be a particular social group, but I am not so sure about "dreamboats."

    Asylum, of course, is a legal tool that has been used and expanded by creative lawyers. When the modern asylum system was created by the Refugee Act of 1980, many people who routinely receive protection today--victims of female genital mutilation, LGBT individuals, victims of domestic violence--would likely have been ineligible for asylum. To the extent that their actions are not simply a type of civil disobedience, the Dreamers seem to be seeking to expand the category of protected individuals to include people who grew up in the U.S., and who face threats in their home countries because they are viewed as "American." This strategy raises two basic questions: (1) Will it work? and (2) How will it affect other asylum seekers?

    First, will it work? I think it might, at least in some cases. I've represented several asylum seekers who made claims similar to the Dreamers: A lesbian who had not been to her home country of Sudan since she was young, Afghan women (and a few men) who studied in the U.S. and who are viewed by extremists as "Westernized," an Iraqi woman whose family was associated with the U.S. These applicants were successful (or their cases are still pending), but my guess is that their claims are stronger than most of the Dreamers' claims. Nonetheless, the principle is the same.

    A broader--and more radical--solution for the Dreamers might be if the Obama Administration defined them as a particular social group for asylum purposes. There is precedent for such a move: In 2009, DHS issued a brief in Matter of LR where it stated, "DHS accepts that in some cases, a victim of domestic violence may be a member of a cognizable particular social group.... This does not mean, however, that every victim of domestic violence would be eligible for asylum." Prior to the end of DOMA, I (clumsily) advocated a similar approach to help LGBT couples.

    If DHS agrees that deported Dreamers are a particular social group (defined as "young, Americanized Mexicans," for example), they would then need to demonstrate that they face persecution in their home country based on their social group. DHS could potentially make a blanket determination that members of this social group would face persecution in Mexico, El Salvador or wherever, and - Voila! - Dreamers get asylum, and you effectively pass the Dream Act without Congressional action (and they could apply for asylum without leaving the U.S.).

    Of course, there would be consequences to such an approach, which brings us to the second question: How will it affect other asylum seekers?

    For one thing, unless significant resources were re-allocated, giving asylum to the Dreamers would completely overwhelm the asylum system. That system has already been ground to a halt by a few extra thousands arrivals at our border, so it certainly could not handle millions of new cases.

    In addition, it would be very expensive. There are no government fees for asylum applications. Presumably, if the Dream Act becomes law, Dreamers will pay a fee to regularize their status. In general, USCIS is operated based on filing fees (that is why it has not been closed by the government shutdown), so these fees would be needed to adjudicate the Dreamers' cases.

    Third--and this for me is the real problem--it will harm (or destroy) the integrity of the asylum system. Asylum, by definition, is an individualized form of relief. While one person from a particular country may have a strong asylum case, another may have no case at all. To view these cases collectively sets a very bad precedent. Worse, to grant asylum to an entire group (i.e., Dreamers), many of whom probably would not otherwise qualify, turns the asylum system into a political tool for avoiding the normal legislative process (i.e., passing the Dream Act). Such a move would do great damage to the asylum system, a system that is supposed to be free from political influence.

    Asylum as a blanket solution to the Dreamers' dilemma is certainly not the best way to solve the problem. It would obviously be much better for Congress (specifically the House of Representatives) to pass the Dream Act and Comprehensive Immigration Reform. But as a strategic approach, perhaps the "threat" of giving asylum to all Dreamers might provide an incentive for the House to take up immigration reform. After all, the language of nihilism, self destruction, and ends-justifies-the-means is the only language that the House of Representatives seems to understand.

    Originally posted on the Asylumist:
    Tags: asylum, dream act Add / Edit Tags
  5. Could the Debt Ceiling Dispute Lead to an Immigration Meltdown? By Roger Algase

    Update, October 9, 12:55 pm:

    According to reports in both the Huffington Post and Politico, House Speaker John Boehner met this morning with House Democratic leaders Nancy Pelosi and Steny Hoyer about the debt ceiling. Also, the Huffpost reports that the head of Heritage Action, one of the main instigators of the debt ceiling disaster, may be about to bail out on his opposition to raising the debt ceiling too.
    Even though it is too early to tell, the GOP may be looking for a way out. If this happens, immigration in America, which depends on a healthy economy and a functioning democracy, may have dodged a bullet.

    Update, October 9, 8:05 am:

    As of Wednesday morning, the House GOP leadership line appears to have hardened again, at least on the basis of a Washington Post op-ed by House Majority Leader Eric Cantor (R-VA) with the cynical title: Bipartisan negotiations required.

    Negotiations at gunpoint, that is.

    When were the House Republicans ever interested in negotiations on the health care law before it was passed? And why are they doing everything in their power to avoid a Senate - House conference on immigration reform?

    The Tea Party is staking everything on its hope that Obama will continue to be a weak president and cave in to their demands which, sooner or later, will inevitably include gutting immigration reform and putting state and local officials such as Joe Arpaio back in the immigrant persecution business, as well as tossing out 14th amendment birthright citizenship for all US-born children.

    As I will argue in more detail in a subsequent post, the only way that Obama will be able to save immigration reform is by finally becoming a strong president and using his full executive powers to implementing Plan B and suspend all deportations.

    In the same way, he will need to use his 14th Amendment power to raise the debt ceiling, as well as the president's inherent national security power, which the Republicans were so anxious to support under George W. Bush, to save America from the Tea Party's attempt to overthrow our democracy and destroy our economy.

    Update, October 8, 12:47 pm:

    Just a few minutes ago, Politico reported that House Speaker John Boehner announced that there were "no lines in the sand" on the debt ceiling, and that "nothing is on or off the table". Politico describes this as a radical shift in tone from his previous statements.

    Could this mean that sanity is finally coming to prevail within the GOP, and that the Republican leadership is realizing the consequences of giving in to the Tea Party madness?

    Also, maybe if the House GOP comes to its senses on the debt ceiling and the government shutdown issues, perhaps it will do the same on immigration reform too. Or would this be asking too much?

    My original post from earlier this morning follows.

    First, immigration supporters were worried that Congressional focus on the government shutdown and debt ceiling issues during October would divert attention away from immigration reform this month. This would make it even less likely that the House will take up immigration reform this year, before what promises to be one of the most divisive and polarized Congressional election campaigns in our history gets under way to put CIR on the farthest away of media and legislative back burners in 2014.

    However, now that the Tea Party's government shutdown has been under way for the past week, there is an even more immediate worry: all immigration that involves the US Labor Department has also been shut down. This means no new H-1B's (even for people not already affected by the annual cap), no H-1B transfers or extensions and no PERM Labor Certifications. This punches a big hole in the entire employment-based immigration system.

    As if that were not enough, no one knows how much longer it will be before overseas US consular posts start running out of money to process visas, even though this has evidently not happened yet.

    To be sure, these are very serious disruptions, which could be enough to render a large part of the legal immigration system dysfunctional over time, unless the parts of the immigration benefits system which are still operating come up with some creative stopgap solutions.

    For example, USCIS could decide to accept and approve H-1B petitions without an LCA - subject to the condition that a certified LCA must be submitted within a reasonable amount of time after the DOL reopens, or the H-1B approval will be automatically revoked. Perhaps something like this could even be worked out for I-140 petitions based on clearly approvable Permanent Labor Certification Applications while the DOL is shut down.

    If the visa issuing system closes down through lack of money, possibly the CBP (Customs and Border Protection) might be able to parole in people who are prima facie eligible for visas but prevented from receiving them because the consular posts are not functioning. These ideas may seem far fetched, but if the shutdown looks likely to go on for several months, rather than hopefully only only a few days or weeks more at the most, it might be necessary to consider them seriously. One should not underestimate the Tea Party's destructiveness, not to mention its hatred of immigration.

    But immigration disruptions caused by the shutdown are only the tip of the iceberg compared to what could happen to America's legal immigration system if the debt ceiling is not raised on or before October 17.

    If the Tea Party Radicals and their supporters in Congress succeed in blocking the debt ceiling increase and making it impossible to America to pay all its bills, as they show every sign of having as their immediate goal, most experts believe that America's, if not the world's, entire financial system could be devastated.

    I am not an economist, and I know very little about financial markets. Nor is a site that focuses on economic issues. But, according to what is available on the Internet, about 30 percent of the federal government's budget is made up of borrowed money.

    If the US government is no longer able to borrow, either it will default on its Treasury bonds, which are at the heart of the international financial and US banking systems, or it will have to make unimaginable cuts in its expenses. To mention only one point, even though USCIS does not depend on Congressional appropriations, there might be an irresistible temptation for the government to raid USCIS filing fees in order to pay for other, non-immigration related expenses, such as Social Security, Medicare, defense, etc.

    Is it realistic to think that in the midst of a US and world wide financial crisis, there would be enough money available for USCIS to operate normally? This idea seems delusional.

    But this is the lesser of the twin threats to immigration as we know it that could result from a refusal to raise the debt ceiling. The most dangerous threat of all could be the destruction of America's entire system of democracy and its replacement by a far right wing, anti-immigrant, Tea Party dictatorship.

    These are strong words, but they are not at all inappropriate to describe what America may be facing after October 17, if the Tea Party gets its way.

    Update: October 8, 2:55 pm

    First, look at what the Tea Party Republicans reportedly want in return for agreeing to raise the debt ceiling. According to House debt ceiling bill shows why compromise is unthinkable (September 26) their list of demands is almost endless:

    "From Jonathan Strong's report at NRO, what Republicans want in exchange for not agreeing to default on the national debt is a one-year delay of Obamacare, Paul Ryan's tax reform, the Keystone XL pipeline, partial repeal of the Clean Air Act. partial repeal of bank regulation legislation, Medicare cuts, cuts in several anti-poverty programs, making it harder to launch medical malpractice lawsuits, more drilling on federal land, blocking net neutrality, and a suite of changes designed to make it harder for regulatory agencies to crack the whip."

    In short, virtually the entire Republican platform, which was resoundingly defeated by the voters in 2012, could be forced into becoming the law of the land through the extortion of threatening to bankrupt America, risk causing a catastrophic recession and essentially making this country ungovernable if these demands were not met.

    This is not democracy; it is more like a coup without the tanks.
    But suppose that the Democrats, who actually won last year's election (including gaining more total votes for House candidates than the Republicans) were to agree to some or all of these demands in order to avoid financial and governmental disaster?

    Then what would there be to stop the Tea Party extortionists from saying:

    "Oh, but we just have a few more little items - criminalize every single immigration violation, even the most technical, give the states back the immigration enforcement powers which the Supreme Court took away from them (at least in part) in 2012, and cancel birthright citizenship for any once whose parents are in the country illegally (or have one parent without status, or whose parents are legal but without green cards, or whose parents are not both US citizens - you name it) - and, by the way, before we forget, lets put in a one year moratorium on all immigration."

    The point is that once democracy and majority rule go out the window, there would be no limit to the types of immigration restrictions that a small minority of Tea Party fanatics could force on the rest of America.

    However, even this might only be a prelude to something equally drastic, namely impeaching President Obama over the debt ceiling no matter what he does, and replacing him with 100 per cent anti-immigrant, self-deportation supporting president such as Mitt Romney had promised to be if elected.

    There already is a possible legal strategy in place for using the debt ceiling as an excuse to impeach President Obama - something that right wing Republicans have been dying to do since America's first black president was elected in 2008.

    More about this in my next post.

    Updated 10-09-2013 at 11:57 AM by ImmigrationLawBlogs

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