Matthew Kolken on Deportation And Removal

ICE Agents File Suit to Block Deferred Action Initiative

Officers of Immigration and Customs Enforcement (ICE) have filed suit in the United States District Court for the Northern District of Texas against their boss, John Morton, and Department of Homeland Security Secretary Janet Napolitano.  

The suit challenges the legality of Secretary Napolitano's June 15, 2012, directive entitled “Exercising Prosecutorial Discretion with Respect to Individuals Who Came to the United States as Children” commonly referred to as DACA.  They are seeking injunctive relief that if granted will prevent the implementation of what they characterize as an "unlawful and unconstitutional Directive."

The lawsuit specifically "seeks to prevent law enforcement officer Plaintiffs from being forced to either violate federal law if they comply with the unlawful Directive or risk adverse employment action if they disobey the unlawful orders of the DHS Secretary. This lawsuit alsoseeks to preserve the balance of legislative and executive powers established by the United States Constitution."

They argue that:

The Directive commands ICE officers to violate federal law... commands ICE officers to violate their oaths to uphold and support federal law, violates the Administrative Procedure Act, unconstitutionally usurps and encroaches upon the legislative powers of Congress, as defined in Article I of the United States Constitution, and violates the obligation of the executive branch to faithfully execute the law, as required by Article II, Section 3, of the United States Constitution.

The Plaintiffs believe that if they follow the Directive, they will be violating their oath of office, as well as violating several laws of the United States. The claim that if they follow the requirements of federal law, contrary to the “Directive,” and arrest an alien or issue an alien an Notice to Appear (NTA) in removal proceedings, they will be disciplined or suffer other adverse employment consequences.

Here are the plaintiffs:

• Plaintiff Christopher L. Crane is an ICE Deportation Officer. He serves in Enforcement and Removal Operations at the Salt Lake City Field Office at 2975 Decker Lake Drive, Stop A, in West Valley City, Utah. He is also the President of the ICE Agents and Officers Union, AFGE Council #118. As an ICE Deportation Officer, Crane is authorized by law to, inter alia, arrest aliens for administrative immigration violations or for any criminal offense against the United States and execute administrative and criminal arrest warrants. 

• Plaintiff David A. Engle is an ICE Immigration Enforcement Agent. He serves in Enforcement and Removal Operations at the Dallas Field Office at 8101 N. Stemmons Freeway, in Dallas, Texas. As an ICE Immigration Enforcement Agent, Engle is authorized to, inter alia, arrest aliens for immigration violations, arrest any person for felonies regulating the admission or removal of aliens, and execute administrative arrest warrants for aliens.

• Plaintiff Anastasia Marie Carroll is an ICE Immigration Enforcement Agent. She serves in Enforcement and Removal Operations at the El Paso Field Office at 1545 Hawkins Boulevard, in El Paso, Texas. As an ICE Immigration Enforcement Agent, Carroll is authorized to, inter alia, arrest aliens for immigration violations, arrest any person for felonies regulating the admission or removal of aliens, and execute administrative arrest warrants for aliens.

• Plaintiff Ricardo Diaz is an ICE Immigration Enforcement Agent. He serves in Enforcement and Removal Operations at the El Paso Field Office at 1545 Hawkins Boulevard, in El Paso, Texas. As an ICE Immigration Enforcement Agent, Diaz is authorized to, inter alia, arrest aliens for immigration violations, arrest any person for felonies regulating the admission or removal of aliens, and execute administrative arrest warrants for aliens.

• Plaintiff Lorenzo Garza is an ICE Immigration Enforcement Agent. He serves in Enforcement and Removal Operations at the Port Isabel Detention Center at 27791 Buena Vista Boulevard, in LosFresnos, Texas. As an ICE Immigration Enforcement Agent, Garza is authorized to, inter alia, arrest aliens for immigration violations, arrest any person for felonies regulating the admission or removal of aliens, and execute administrative arrest warrants for aliens.

• Plaintiff Felix Luciano is an ICE Immigration Enforcement Agent. He serves in Enforcement and Removal Operations at the San Diego Field Office at 880 Front Street, Suite B- 2232, in San Diego, California. As an ICE Immigration Enforcement Agent, Luciano is authorized to, inter alia, arrest aliens for immigration violations, arrest any person for felonies regulating the admission or removal of aliens, and execute administrative arrest warrants for aliens.

• Plaintiff Tre Rebstock is an ICE Immigration Enforcement Agent. He serves in Enforcement and Removal Operations at the Houston Field Office at 7405 C-1 Highway 75 South, in Huntsville, Texas. As an ICE Immigration Enforcement Agent, Rebstock is authorized to, inter alia, arrest aliens for immigration violations, arrest any person for felonies regulating the admission or removal of aliens, and execute administrative arrest warrants for aliens.

• Plaintiff Fernando Silva is an ICE Immigration Enforcement Agent. He serves in Enforcement and Removal Operations at the El Paso Field Office at 1545 Hawkins Boulevard, in El Paso, Texas. As an ICE Immigration Enforcement Agent, Silva is authorized to, inter alia, arrest aliens for immigration violations, arrest any person for felonies regulating the admission or removal of aliens, and issue administrative arrest warrants for aliens.

• Plaintiff Samuel Martin is an ICE Immigration Enforcement Agent. He serves in Enforcement and Removal Operations in the El Paso Field Office at 8915 Montana Avenue, in El Paso, Texas. As an ICE Immigration Enforcement Agent, Martin is authorized to, inter alia, arrest aliens for immigration violations, arrest any person for felonies regulating the admission or removal of aliens, and execute administrative arrest warrants for aliens.

• Plaintiff James D. Doebler is an ICE Deportation Officer. He serves in Enforcement and Removal Operations in the Dover Sub-Office at 1305 McD Drive, in Dover, Delaware. As an ICE Deportation Officer, Doebler is authorized by law to, inter alia, arrest aliens for administrative immigration violations or for any criminal offense against the United States and execute administrative and criminal arrest warrants.

Click here to read the full text of the complaint.

USCIS Won't Share the Information Provided on DACA Applications with ICE... UNLESS they decide to Deport You.

It appears that when the Obama administration said they will not share the information provided in Deferred Action for Childhood Arrivals (DACA) applications with ICE, what they really meant to say was they won't share your information UNLESS they decide to deport you.

Here is what I found in the recently updated USCIS DACA Frequently Asked Questions:

Will the information I share in my request for consideration of deferred action for childhood arrivals be used for immigration enforcement purposes?

Information provided in this request is protected from disclosure to U.S. Immigration and Customs Enforcement (ICE) and U.S. Customs and Border Protection (CBP) for the purpose of immigration enforcement proceedings UNLESS the requestor meets the criteria for the issuance of a Notice To Appear or a referral to U.S. Immigration and Customs Enforcement under the criteria set forth in USCIS’s Notice to Appear guidance (www.uscis.gov/NTA).  [Emphasis added]

The link in the USCIS FAQ brings you to the November 7, 2011, policy memorandum that establishes criteria for consideration of whether an individual is an immigration enforcement priority that should be targeted for deportation. The memo specifically prioritizes the deportation of individuals that have been found to have committed fraud through the submission of an immigration application.

This policy has been reinforced in the DACA FAQ:

What steps will USCIS and ICE take if I engage in fraud through the new process?

If you knowingly make a misrepresentation, or knowingly fail to disclose facts (i.e., you leave something out that you think will result in the denial of your application), in an effort to have your case deferred or obtain work authorization through this new process, you will be treated as an immigration enforcement priority to the fullest extent permitted by law, and be subject to criminal prosecution and/or removal from the United States. 

Fraud is not the only thing that may result in the institution of removal proceedings after the submission of a DACA application.  The Obama administration has created a new term of art called a "significant misdemeanor."

It has been defined as follows:

Any misdemeanor as defined by federal law (specifically, one for which the maximum term of imprisonment authorized is one year or less but greater than five days) and that meets the following criteria:

1. Regardless of the sentence imposed, is an offense of domestic violence; sexual abuse or exploitation; burglary; unlawful possession or use of a firearm; drug distribution or trafficking; or, driving under the influence; or,
2. If not an offense listed above, is one for which the individual was sentenced to time in custody of more than 90 days. The sentence must involve time to be served in custody, and therefore does not include a suspended sentence.

Also be aware that just because you don't have a criminal record does not in any way prevent the Government from denying your application and sharing your information with ICE for the purpose of instituting removal.

They added the following catchall:

Notwithstanding the above, the decision whether to defer action in a particular case is an individualized, discretionary one that is made taking into account the totality of the circumstances. Therefore, the absence of the criminal history outlined above, or its presence, is not necessarily determinative, but is a factor to be considered in the unreviewable exercise of discretion. DHS retains the discretion to determine that an individual does not warrant deferred action on the basis of a single criminal offense for which the individual was sentenced to time in custody of 90 days or less.

Translation: they can deny your DACA application and deport you if they decide to... and by the way, their decision is final.

So what does this mean?  If you have a conviction, regardless of the seriousness (i.e., it has no immigration consequences), USCIS can deny your application and have ICE institute removal proceedings. Alternatively, even if you don't have a conviction, but have criminal charges that did not result in convictions, your DACA application may be denied in the exercise of discretion, and ICE may be notified for the purpose of instituting removal proceedings.

So here is the bottom line, when you are submitting a DACA application DO NOT be fooled into thinking that there is no chance that you will be deported.  The fine print that keeps being added to the process clearly permits the institution of removal proceedings for almost any reason, or no reason.

I am not saying that you shouldn't submit a DACA application if you believe that you are both eligible, and a low priority risk.  You can decide that for yourself after consulting an immigration lawyer that is experienced in deportation defense.  

What I am saying is that anyone that tells you that there is no/minimal risk of deportation when applying for DACA is lying to you.

USCIS: Misrepresentation, or Knowing Failure to Disclose Facts on a DACA or Work Authorization Application will result in Treatment as an Immigration Enforcement Priority

From USCIS website, updated on August 15, 2012:

What steps will USCIS and ICE take if I engage in fraud through the new process?

If you knowingly make a misrepresentation, or knowingly fail to disclose facts, in an effort to have your case deferred or obtain work authorization through this new process, you will be treated as an immigration enforcement priority to the fullest extent permitted by law, and be subject to criminal prosecution and/or removal from the United States. 

I am VERY concerned that this deferred action initiative is a ticking time bomb for many people.

The people who are claiming that this is a simple straight forward process simply do not understand the complexities of immigration law.  This process is so much more than simply filling out a form. 

I see issues relating to the admission of fraudulent use of a social security number, as well as potential false claims to United States citizenship on I-9 attestation forms that very well may result in the institution of removal proceedings, and deportation with no waiver available.

It is patently irresponsible for politicians to be stating that there is no need for an immigration lawyer in these applications.  The one thing I can say with absolute certainty is that you are going to need an immigration lawyer the moment this administration determines you are an enforcement priority.

Talking Points on Why Deferred Action is NOT Amnesty

If you find yourself being interviwed by any media source feel free to use the following talking points to answer the inevitable claims that Deferred Action for Childhood Arrivals is amnesty.

1. Contrary to the misinformation being spewed all over the media, President Obama has NOT issued an executive order.  DHS Secretary Napolitano has issued a nonbinding policy directive that does not have the full force of law, and may be ignored by adjudicating officers at their election.

If past results are any indicator there is not much to be optimistic about.  The last policy memorandum issued by John Morton only resulted in a favorable exercise of prosecutorial discretion in 1.9% of all reviewed cases.  We have absolutely no idea at this point how the new memo will be implemented. As such, there clearly is no guarantee that just because a deferred action application is submitted that discretion will be favorably exercised.

2. The deferred action initiative is temporary (two-years), and may be cancelled at any time for any reason, or for no reason.

3. We have no idea how long it will take for the current administration to issue decisions.  It is assumed that at a minimum it will take months, and decisions may not be issued until after the November election.   If denials come pouring in after the election there is little likelihood that the program will be renewed even if Obama wins.

4. Despite official statements to the contrary, there is no guarantee that the biographical information being provided on applications won't be used at some point in the future as a basis to institute removal proceedings. Given the current administration's approximately 1.5 million deportations in 3.5 years, I tend to be cautiously pessimistic.

5. If prosecutorial discretion IS favorably exercised applicants are NOT guaranteed to receive a work permit.  To receive one you must establish economic necessity for employment.  Who knows how that will be interpreted. The work permit will presumably be valid for two years, and must be renewed.  As stated above there is no way of knowing if subsequent permits will be issued.

6. If prosecutorial discretion is denied you have no right to due process to seek an appeal of the denial.  As stated above denials may be completely arbitrary and without justification, and there is nothing an applicant can do about it.

7. True immigration reform may only be accomplished through an act of Congress so we must continue to fight for reform. Our mission has NOT been accomplished.  

So there you have it.  If you hear someone claim that Obama has created an illegal amnesty through executive order you are now armed with a response.

Good luck!

You've been patient; now be prudent, By Lory Rosenberg

A is for August 15th and Applications are being accepted for DREAMers who qualify for deferred action according to the standards and conditions that have been announced and explained by USCIS. One critical area involves certain minor traffic violations and minor (non-significant) misdemeanor convictions.

Given USCIS's reservation of the right to consider all offenses in a DREAMER's record as a matter of discretion in adjudicating DACA applications, I would prepare these cases as though the applicant was applying for a statutory form of discretionary relief from removal with respect to providing evidence explaining remorse, rehabilitation, re-education, and some indicia of assurance that the client will not be a repeat offender.

I would go beyond a sworn declaration from the applicant and the documents pertaining to the incident, and provide corroborating evidence from teachers, employers, doctors, counselors, community figures, ministers, rabbis or priests, or other adults or leaders who have interacted with the DREAMer and know her character overall.

I also would include objective data that relates to the nature of the violation or offense. Such evidence might include local/national reports concerning the prevalence or problems caused by the activity underlying the violation or offense, expert studies on age-related or incident-related conduct and recidivism, and even an individual expert forensic psychological evaluation that would constitute a professional assessment of that DREAMer's law abiding nature, lack of dangerousness, and degree of social adjustment.

It would be prudent to provide such supporting evidence whether the purpose is to demonstrate that the offense is not a minor misdemeanor at all, e.g., a traffic offense, or that it is a minor, non-significant misdemeanor.

It seems to me that in light of the discretionary latitude that USCIS has reserved, the burden is on the DREAMer to establish that her application contains no basis for a finding of ineligibility or denial. This is a strategy call, of course, and while it may seem to be excessive to so comprehensively document the incidence of a single violation or minor offense, it is worth considering - at least on a case by case basis - given the absence of any motion to reopen or appeal.

Undocumented immigrants line up for relief from deportation

Legal Immigrant Spared Self-Deportation

CNN Money has reported that legal immigrant Lauren Gray has been granted a two-year reprieve that will permit her to remain in the United States presumably under President Obama's recently announced deferred action initiative.  The article didn't provide specifics about the reprieve.  

Here is what I do know.  Lauren, a citizen of the United Kingdom, came to the United States as a four-year-old child with her parents in 1995 on a valid E-2 visa. She is a college graduate, speaks with an indistinguishable American accent, and looks as American as apple pie.

Her parents came to the United States to invest in a hotel and restaurant in a small town in Missouri.  She has maintained lawful status for every second that she has been in the United States.

Despite the fact that she has always followed the law, on August 8, 2012, she was facing the very grim prospect of either having to leave the country or becoming undocumented, which would result in the accrual of unlawful presence in the United States.  This would preclude her ability to apply for the Green Card that she has been patiently waiting for, or any other type of temporary immigration status.  Moreover, if she accrues either more than 180 days or one-year of unlawful presence she would automatically trigger a three or ten year bar to readmission respectively should she leave the country.

Her immigration crime you may ask?  Her 21st birthday.

The 21st birthday for most born in American is a date of liberation and is the first step towards true adulthood.  It is a day of celebration.  For Lauren, there was nothing to celebrate, as her 21st year resulted in her no longer being entitled to derivative status under her parents' E-2 treaty investor visa. 

For Lauren, it was time for her to either pack her bags and leave the country that has been her home for 17 of her 21 years, the country that she earned her college degree, the country where her family will continue to live, or having to step into the shadows under the stigma of being an undocumented immigrant.

In simple terms she was stuck between a rock and an immigration hard place.

Lauren and her family have been trying for nine years to legally fix this problem, but due to severe visa backlogs there simply is no immediate solution for her.  In 2003, her mother was sponsored for a Green Card under the family based 3rd preference category as a married daughter of a United States citizen.  According to the most recent visa bulletin individuals that have had immigrant 3rd preference petitions filed on their behalf on May 15,  2002, are now finally at the front of the line to apply for lawful permanent residence.

For Lauren, and for tens of millions of other people that are patiently waiting in line for their visa, the law is both unforgiving and punishing. Thankfully, Senator Claire McCaskill (D-MO) intervened on Lauren's behalf, and she has been given a temporary two-year reprieve by the Obama administration.

The time is long overdue for our leaders in Washington to seriously address comprehensive immigration reform, not just for the people who are here illegally due to no fault of their own, but for the people that are being punished for following the law.

It would be nice if our President could at least acknowledge the complexity of the immigration reform problem by including it as an important issue on his campaign website.  His opponents have.  Although admittedly it would be little more than a token gesture, it at least would be a pledge that the President will aggressively work with Congress to form a bi-partisan solution should he win reelection.  That is what he promised last time around.

At the very least President Obama needs to release a working framework of a reform plan to start the dialogue.

Isn't that what leaders do?

Click here for the original source of this story.

Campaign Ad Attacks Obama on his Deportation Record.

American Principles in Action has released the following campaign ad attacking President Obama's immigration record.  The ad was not authorized by any candidate, or any candidate's political action committee.

Lory Rosenberg: DREAMers Do Need Lawyers

The following was written by the greatest mind we have in the field of immigration law.  For those who are not aware, Lory Rosenberg is a former member of the Board of Immigration Appeals, and is responsible for writing the most thoughtful, and insightful decisions on immigration law that I have ever had the good fortune to read.  

While on the BIA she wrote opinions responding to literally thousands of appeals from removal and asylum decisions of US Immigration Judges.  Her analysis has shaped the very core of my legal philosophy.  My law partner and I consider her a national treasure in the field of immigration law, and it is both a privilege and an honor to be able to publish her words on this blog.

Thank you Ms. Rosenberg, for everything that you do.

A Rude Awakening

Dreamers should not be discouraged from consulting with responsible, knowledgeable, and ethical immigration lawyers who have comprehensive experience with the immigration laws. However well-intended Mssrs. Durbin's and Gutierrez's video message of August 6, 2012 may be, it is a gross distortion to suggest that immigration lawyers who offer legal services to Dreamers who are applying for deferred action are taking advantage of them. It is patently inaccurate to say, as Mr. Durbin states in the video, that all but a very few Dreamers will need to use lawyers, and it is misleading to suggest that lawyers and notarios are one and the same with respect to presently perpetrating "scams" or even charging fees for deferred action representation and related legal work.

Dreamers do need lawyers. What they do not need is mixed messages, overgeneralizations, or misguided efforts to insulate them from fraud that inadvertently leaves them at a disadvantage in reaching their dreams.

"Don't Hire a Lawyer" – What?

Immigration lawyers with comprehensive immigration law knowledge and practical experience are informed, honest, forthright and ethical in consulting with and representing potential Dreamer deferred action candidates. We are bound to zealously represent the best interests of our clients and our clients receive enormous value from us. Some of us work in private practice and some work in non-profit organizations, and most all of us provide pro bono services, sometimes at the request of Mssrs. Durbin and Gutierrez for their constituents. Our comprehensive understanding of the complex provisions of the entire immigration statute permits us to identify and grapple with real and potential problems - often before they can cause permanent damage - and allows us to develop creative and effective legal solutions for our clients. Furthermore, the quality representation we provide discourages and counteracts fraud and delivers the real benefits to which Dreamers may be entitled.

With all due respect for their commitment and years of concrete efforts to pass the Dream Act legislation and other needed immigration reform, Mssrs. Durbin and Gutierrez are doing a serious disservice to those Dreamers whom they hope to help, not to mention perpetuating an undeserved and insulting confusion between licensed immigration lawyers who are dedicated to their clients, and notarios who are practicing law without a license or may be engaged in defrauding Dreamers. It is precisely because of the risk of harm from nefarious scammers and the importance of each Dreamer's future with respect to all immigration benefits for which s/he may qualify that individual consultation and representation by responsible, knowledgeable and ethical immigration lawyers is so critical and should be promoted.

No Second Chances

The reality is that no one can know the number or proportion of cases in which legal counsel will not only be needed, but essential to securing deferred action status under the program. Individual obstacles that may exist and issues that may arise in adjudication of a deferred action application must be identified, addressed, and resolved, and this can best be done with the help of an experienced immigration attorney, before the Dreamer comes forward, presents himself or herself to USCIS, and submits an application for deferred action. In reality, the process may be simple and straightforward only for those who prepared by first consulting with counsel.

The reality is that USCIS has made clear that those who do not qualify fall under an exception to the guarantee of confidentiality that accompanies the deferred action program and they will be referred to ICE for removal hearing write-ups. Accordingly, the advent of this temporary deferred action program necessitates, at the very least, an initial professional legal consultation and evaluation to determine whether a potential Dreamer qualifies for the benefits sought in the application and to highlight any defects that need to be addressed and corrected before s/he applies.

The reality is that later will be too late. A Dreamer candidate must establish that s/he possesses the necessary qualifications and has one opportunity to do so. A plethora of questions still exist as to what type and amount of evidence will be sufficient to satisfy each of the qualifiers, ranging from proof of presence in the United States and school enrollment records, to the absence of "significant misdemeanors" and the characterization of "minor" misdemeanors and driving offenses. Nonetheless, the strict rules announced by USCIS do not permit either motions to reopen or appeals.

Value Added

Nothing prevents a Dreamer candidate from handling his or her own individual application for deferred action. Self-assessment, however, has its pitfalls. Wouldn't it be preferable for that Dreamer candidate to engage experienced counsel for the benefit of his or her insights and expertise? Doesn't it seem important to review collateral issues such as taxes, use of social security numbers, and related factors that may need to be resolved? Moreover, wouldn't it be valuable for a Dreamer to know whether s/he might be eligible for other, additional immigration benefits? Wouldn't it be "worth it," given the impact on a Dreamer's future.

Most knowledgeable, responsible and ethical immigration attorneys would balk at the notion of providing anything less than a comprehensive consultation to examine all aspects of a Dreamer candidate's background, and current status, as well as possible eligibility for any and all benefits under the INA. Although the deferred action program provides a temporary status, a potential Dreamer also may be able to demonstrate eligibility for a status of a more permanent or enduring nature. These circumstances warrant a full and complete legal consultation. In fact, early accounts indicate that Dreamer consultations with expert immigration counsel have resulted in the identification of the candidates' eligibility for U, T, and other visas, and even include a case in which U.S. citizenship was determined to exist!

As Mssrs. Durbin and Gutierrez emphasize in their video, there are "narrow" requirements that accompany the deferred action program and not every student will qualify. It would be naive to assume the deferred action adjudication process will be wholly benevolent and forgiving, or to ignore DHS's track record in other discretionary programs, particularly given the outspoken opposition from representatives of some employees within the agency. This reality underscores the need for involvement at the outset of expert immigration counsel with proven experience evaluating eligibility, establishing qualifications, and documenting applications to satisfy evidentiary standards that will be subject to close scrutiny.

In my view, every individual Dreamer intending to make contact with USCIS and apply for deferred action should consult with an expert immigration lawyer for an overall status and eligibility assessment, as well as an evaluation of where s/he stands at present in relation to his/her goals. The potential issues are serious and consequences can be long lasting. The value that experienced immigration counsel brings to a lawyer-client relationship with a Dreamer candidate more than supports payment of appropriate legal fees for services that may be rendered, and indeed, can prove to be priceless. Now, did someone mention lawyers and notarios in the same breath?

Detained Immigrants Being Used as Slave Labor

It has been reported that detained immigrants are being paid $1 a day while held in privately run detention centers awaiting deportation.

Northwestern University Professor Jacqueline Stevens sums it up quite nicely:

"People who are being detained only while they await an immigration court audience and not for punitive reasons are being forced to work for a dollar a day and this not only seems to violate the minimum wage laws, but also the 13th Amendment against slavery."

The Obama administration counters that these programs are voluntary and that when an individual is confined their labor does not constitute employment.

The ACLU of Georgia begs to differ explaining that food provided in detention centers is substandard and that detained immigrants work so that they are able to supplement their diet with food purchased from the in-prison vendor, as well as to purchase telephone cards to be able to keep in touch with loved ones.  As such, their "employment" is a necessity, and is anything but voluntary.  

Anyone else see the irony in the fact that many/most of these immigrants are in detention facing deportation because they did not have authorization to work, and yet the Obama administration permits them to be hired at a slave's wage to do a job that a Citizen could be doing at a reasonable rate of pay?  To add to the cruel irony is the fact that the dollar a day they are being paid ends up going right back into the pockets of their captors.

And why is this happening you may ask?  Profit of course.

In the words of the fictional Gordan Gekko: "Greed, for lack of a better word, is good."

More "Change" you can believe in.

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