By: Selena Rincon

Selena Rincon is a second-year student in the MAIA program with a specialization in Diplomacy. She is passionate about immigrant rights and hopes to work for the U.S. State Department after graduation.

Abstract:

Opposition to immigration (and immigrants) has become an important issue all over the world. In the United States, there is a long history of anti-immigrant sentiments that have affected Irish, Chinese, Mexican, and many more communities. For over two hundred years, there have been individuals, organizations, or government institutions that have taken action against immigration, both with successes and failures. In order to fully understand the different movements within the umbrella of anti-immigration, it is important to differentiate between legal and illegal immigration. While some individual actors may support some forms of legal immigration, that is not the case for many of the most prominent anti-immigrant organizations.

Background:

To have a clear view of anti-immigrant movements throughout this country’s history, one must understand the history of immigration. The reasons behind immigration to the United States, before and after its independence in 1776, have varied throughout centuries. For example, in the 1600s the Pilgrims sought religious freedom while the Irish migration in the 1800s occurred because of a potato famine. For as long as immigration has existed, there has been anti-immigrant sentiment.

The Alien and Sedition Acts of 1798 were an early sign of anti-immigrant views by the United States. At the time, the Federalist party supported a stronger national government, a national bank, and a good relationship with Great Britain. U.S. President John Adams, a member of the Federalist party, passed the four laws as a reaction to American fear of the impending war with France. [1] The four laws were the following: the Naturalization Act, the Alien Act, the Alien Enemies Act, and the Sedition Act. The first law increased the residency requirement for American citizenship from five to fourteen years.[2] The second law allowed the deportation of immigrants that were deemed to be “dangerous to the peace and safety of the United States”.[3]  The third law allowed the deportation of citizens from an enemy nation during war.[4] The final law limited freedom of speech and banned the publication of “any false, scandalous and malicious writing.”[5] These laws demonstrate that the Federalist government considered immigrants a threat, a sentiment that continues to exist among anti-immigrant groups.

 A century later, the number of immigrants continued to increase at a rapid speed, particularly immigrants from Eastern European countries. This led to an increase in the number of white Americans who supported the concept of nativism, an early form of anti-immigrant sentiment. It was the belief that native-born Americans deserved more rights that foreigners.[6] This did not include the indigenous communities, rather the descendants of European settlers. The concept of nativism continued to play a role in the evolvement of the anti-immigrant movement throughout the 19th and 20th centuries. There were periods of high anti-immigrant sentiments and time periods in which the United States was in urgent need of immigrants. The Immigration Act of 1924 created a quota for the number of European immigrants that could enter the United States while excluding Asian immigrants. A few decades later, the 1965 Hart-Celler Act ended the restrictive laws and led to a significant increase in immigrants.[7] This was a pivotal moment for the modern anti-immigrant movement. While the anti-immigrant movement was gaining popularity and shifting its tactics, the white supremacist movement was increasing in popularity due to the failure of the Vietnam War.

In order to delve into the complexities of the anti-immigrant movement, it is necessary to understand its connection to the zero-population growth (ZPG) and white supremacist movements. They might share similar ideas and its members may participate in multiple organizations, but they are separate movements. The zero-population growth movement gained popularity in the 1960s and 1970s and is defined as a population that does not grow or decline. The rate of immigration and emigration affect the overall growth rate of a country. Even if there is a balance between the death and birth rate, if there is a higher number of immigration than emigration, then the growth rate of a specific country is not balanced.[8] This concept allows the debate about immigration to be centered on the well-being of a state in terms of its population, rather than it being a racist or xenophobic way of thinking. If a government wants to have a stable population, then it would need to strictly control its immigration. Similarly, the white supremacist movement was not necessarily focused on being anti-immigrant, rather it focused on the belief that white people are superior. Presently, the movement has made changes to their name and attempted to distance themselves from a strictly anti-immigrant movement.

Kathleen Belew believes that the membership of the Ku Klux Klan increased primarily as a consequence of the war, making anti-immigrant sentiments, populism, and poverty less important factors.[9] Yet, that did not prevent the white supremacist movement from using the tactics that they had learned during the war to torment immigrants. Louis Beam, a prominent white nationalist helped train KKK members and implemented the Klan Border Watch that targeted immigrants crossing the Texas-Mexico border.[10] This began occurring throughout all the border, not just Texas. And has influenced border vigilantes that exist today.

Aside from the sporadic actions of those opposed to immigration, the creation of four prominent organizations is the basis of the current anti-immigrant movement. All of these organizations were established directly by or with the help of John Tanton.

Important Actors:

John Tanton was president of ZPG from 1975 to 1977, a period in which he used population control as a tool for establishing anti-immigrant rhetoric and becoming a prominent activist in the field. Following his departure from ZPG, he established the Federation for American Immigration Reform (FAIR) in 1979.[11] FAIR identifies itself as a non-partisan organization with 7 principles: ending illegal immigration, no amnesty, protecting wages of American citizens, improving interior enforcement, ending the abuse of the asylum system, and implementing a pause to immigration.[12] The organization’s website (and its supporters) pride themselves on not being a racist organization, just one that protects the United States from the negative consequences of immigration. Yet, its founder has been involved in multiple white supremacist organizations and received monetary donations from the Pioneer Fund.[13]

FAIR has succeeded in becoming an important actor in the anti-immigrant movement while protecting its image in a way that encourages the main-stream media to use them as a legitimate source and advocate. In the past few decades, FAIR has focused largely on being an advocate and using tools such as lobbying, rallies, and media to spread their message. The Center for Immigration Studies (CIS) plays a different role and focuses on the supposed research that is meant to back up the claims that FAIR makes. Interestingly, they were both founded by the same person. CIS began as a research branch of FAIR and later on, became an independent think tank. Tanton helped Roy Beck found NumbersUSA in 1996, another organization that promoted itself as anti-immigrant, but not racist. All three organizations have worked together to spread misinformation in order to promote their agenda.

At the same time, there has been a more proactive approach in the anti-immigrant movement through the form of border vigilantes. Similar to their predecessors, the KKK, these vigilantes have focused their efforts on the U.S.-Mexico border with various groups focusing on different states. One group in particular stands out for its use of “tours” as a tool for publicity. Larry Mitchell Hopkins founded the United Constitutional Patriots (UCP), also known as the Guardian Patriots, in an effort to decrease the number of immigrants crossing the border. Members of this organization go to the border to detain immigrants as they attempt to cross and then proceed to call patrol agents to apprehend them. Many of their actions have been livestreamed on social media.[14] This paramilitary organization has a clear leadership structure and takes on a more aggressive stance towards anti-immigration, one that prefers to focus on the influx of immigrants entering from the U.S-Mexico border rather than from other regions of the world. They differ from Tanton’s organizations in their tactics and immediate goals. Although, in the end both actors want a country without any undocumented immigrants and a limited number of legal immigrants.

Tanton can be considered a major actor in the founding of the current anti-immigrant movement but there are not many recent actors with as much fame and support as former President Trump. In his infamous 2015 speech, he referred to Mexican immigrants as criminals and rapists.[15] This anti-immigrant rhetoric launched a presidential campaign founded on anti-immigrant and racist ideologies. Unfortunately, in the media it seemed that his words resonated with a large American population, and the results of the 2016 election partially proved it. Although an immigration poll conducted in 2016 shows that 36% of individuals approved of the current immigration situation and 36% wanted to decrease immigration, a number that has not changed significantly in the past decade.[16] Regardless, Trump’s words inspired anti-immigrant movements who supported many of his immigration policies, such as the zero-tolerance policy and the decrease in the annual refugee resettlement cap. Trump became a symbol for the white supremacist movement and the anti-immigrant movement, another sign of their interconnectedness. As his presidency continued to support anti-immigration, the number of hate crimes rose. Immigrants do not only have to worry about organizations that lobby against their rights, but the individuals who are influenced by them. For example, a Trump supported was charged with a hate crime after pushing a Mexican man onto train tracks in New York City on April 20, 2018.[17] The FBI reported that hate crimes against Latinos rose more than 21% in 2018.[18] The success of Trump’s presidential campaign, and his subsequent presidential term, gave a voice to the movement and its supporters the strength to voice their opinions, verbally and physically, without remorse. The Biden administration has begun but the long-lasting effects of Trump’s presidency are yet to be seen.

Strategies:

The anti-immigrant movement has used various repertoires of contention in order to promote their ideas. John Stanton created a coalition of organizations that have been able to gather media attention, support, and have led to the implementation of anti-immigrant laws. FAIR, CIS, and NumbersUSA were incredibly successful during the Trump Administration while lobbying for an end to DACA and Temporary Protected Status. The Western States Center has spent the last thirty years researching the rise in anti-immigrant sentiments in the United States and they believe that the vast majority of organizations and prominent activists in the movement stem from one player, John Tanton.[19] The only exception in their research is the Remembrance Project, founded by Maria Espinoza, and even then, although this specific organization was not founded by or with the help of Tanton, Espinoza holds a strong relationship with FAIR. The creation of a coalition benefits them because they work together to create their data and they can exchange strategies that have succeeded in different parts of the country. This has also helped them get financing for their different projects and political campaigns.

Larry Hopkins also used coalitions as a tool for his anti-immigrant actions. In October 2018, his border vigilante organization joined forces with Patriots of the Constitution and Mountain Minutemen as a response to the migrant caravan from Honduras, although they disbanded in 2019. The UCP has gained media attention because of their use of social media and the tours that they have given along the border.[20] Initially, this benefited them because they received funding through platforms like Venmo and PayPal but their increased notoriety has led to them getting banned. By livestreaming their actions, they gained a large audience and other anti-immigrant individuals decided to participate in their tours or donate. Despite the fact that they are now banned on funding platforms, there will continue to be ways for them to receive donations.

John Tanton and Larry Hopkins have played different roles in the anti-immigrant movement but their desires stem from the same interest: to see a United States with less immigrants, with a special interest in the decrease of immigrants coming from Central and South America.

Successes

Throughout different time periods, the movement has had many successes in the form of anti-immigration laws being implemented, militias being able to instill fear in immigrants, and more recently, the successful presidential campaign of a nativist politician. A major success for the movement occurred in 1996 when President Clinton signed the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA). The reform included many changes to immigration laws, including removing discretionary relief for long-term lawful permanent residents (LPRs) who were convicted of an aggravated felony.[21] It also created the 3-year, 10-year, and permanent bars, punishments for immigrants who had resided in the United States without legal status. For example, if an individual lived in the United States illegally between 180 to 365 days, left the US, then tried to return, they would receive a 3-year ban. A person with multiple deportations would be permanently barred from entering the country legally. This law created a strict punishment system for immigrants and set stricter standards of behavior, which pleased the anti-immigrant community slightly. There were still activists who believed that the law is not strict enough for illegal immigrants and does not do enough in regards legal immigration. Mark Krikorian, the Executive Director of Center for Immigrant Studies in 2007, believed that there needed to be a significant decrease in legal immigration. He shared Barbara Jordan’s sentiments that “Those who should get in, get in; those who should be kept out, are kept out; and those who should not be here will be required to leave”.[22] Although a success in damaging the overall well-being of immigrants and instilling fear to decrease immigration, this law was only one step towards achieving the larger goals of the anti-immigrant movement. Next, there needed to be stricter deportation laws, as well as limits to legal immigration.

Another success for the movement is the effect that militias have had on immigrants, the southern border, and their overall popularity. As previously mentioned, the United Guardians have used social media to gain popularity among anti-immigrant individuals. This leads to donations that allow them to continue monitoring the border and detaining immigrants as they attempt to cross into the U.S. These militias have succeeded in creating fear among both immigrant communities and communities of color. In 2009, Raul and Brisenia Flores were shot and killed by 3 members of the Minuteman American Defense.[23] They father and daughter were in their home at the time of their deaths, but other militia members have participated in the assault, false imprisonment, and kidnapping of immigrants as they attempt to cross the desert. Today, environmental factors and wild animals are no longer the only fears about making the dangerous journey into the United States. There are now militarized anti-immigrant activists who also pose a danger.

The anti-immigrant movement had a large success when the White House was under the control of multiple nativist leaders: Donald Trump, Steve Bannon, and Jeff Sessions. Political scientist Cas Mudde defines the American definition of nativism as “xenophobic nationalism”[24] and although he describes Trump as inconsistent with his ideologies, Bannon and Sessions are considered nativists and have had a large influence on Trump. When Trump realized that nativist rhetoric would increase his number of supporters, he began to incorporate it more in his campaign speeches.[25] Trump has consistently shown that he is willing to change his opinions to please his followers. At the end of the day, it is difficult to know what he truly believes in and what he does not. Whether or not he is truly a nativist is irrelevant when many of the policies created during his administration could be described as such, such as the travel ban that affected mostly Muslim and/or Arab immigrants. They catered to a group of Trump supporters who voted for him because they believed that he would prioritize America and its people, except that their definition of “American” includes white, protestant, and multi-generational U.S. born individuals. Eric Kaufmann, a political scientist at the University of London’s Birkbeck College, believes that Trump’s supporters identify with him because they are nativists and view immigration as damaging to the United States.[26]  In 2016, 59% of the GOP voters who believed that immigrants were threatening U.S. values, felt very warmly towards Trump. In comparison, 14% of the GOP voters who believe immigrants strengthen U.S. values, felt very warmly towards him.[27] The use of nativism became a win-win situation for Trump and his followers. He gained more votes, enough to become President, and his followers gained a president who limited immigration.

Failures:

Despite the previous mentioned successes, the anti-immigrant movement has failed in many ways, to the benefit of the immigrant community and communities of color. While Trump was able to win the 2016 presidential election, he failed to be reelected. Initially, Trump’s anti-immigration opinions could have gained the support of moderate voters but as his nativist rhetoric worsened, those who were more open to immigration saw his points as too xenophobic. The percent of individuals that think immigrants are good for the U.S has risen for Republican, Democratic, and Independent voters from 2018 to 2020.[28] Trump’s actions attracted the attention of voters who already shared his beliefs but were potentially holding back their opinions. Seeing a president willing to speak so openly in xenophobic and racist ways allowed others to feel like they could do the same. In that way, he was a success for the anti-immigrant movement. He failed the movement because his disturbing speeches and his strict policies did not stop the number of immigration supporters from increasing. Since he failed to be reelected, there is hope that the new administration will be able to reverse his extreme policies and potentially, create more immigrant friendly policies.

Another failure in the movement is the restoration of Deferred Action for Childhood Arrivals (DACA). DACA, implemented during the Obama administration, prevents the deportation of certain undocumented immigrants who were brought to the U.S. as children and grants them work permits. During Trump’s administration, he tried to end the program in September 2017.[29] As an attempt to phase out the program, the new policy stopped accepting new applications for individuals who now qualified. His actions led to outcries from NGOs, immigrant advocacy groups, and even some members of the Republican party that are more supportive of immigration. Fortunately, in December 200 U.S. District Judge Nicholas G. Garaufis restored the program and ordered the Department of Homeland Security to begin accepting first-time applications again.[30] For anti-immigration activists who see DACA as a form of amnesty that allows thousands of illegal immigrants to remain in the country, this decision was a major failure.

Pro-Immigrant Movement Recommendations:

Rather than focusing on anti-immigrant movements and the way they can improve so they can achieve their goals, this paper will focus on how pro-immigrant groups can help prevent the previously mentioned movement from succeeding. To prevent the anti-immigrant movement from gaining more success in the future, it is imperative that organizations that support immigrants be more proactive in helping individuals and lobbying the government to take legal action in favor of immigrants. There are two main groups that need to be addressed: the immigrants and the government. In reaching out to the immigrant community, organizations can build better relationships with the individuals they are trying to protect and can educate individuals in the ways they can protect themselves. In terms of the government, organizations should pressure them to take a stronger stance against hate crimes. Overall, it is recommended that pro-immigrant movements do these three things: Educate immigrant communities about law enforcement and their protections against hate crimes, increase accountability for news media to accurately represent both immigrants and the organizations that spout hate towards them, and lobby the government to take a hard stance against xenophobia and to show it through their enforcement of anti-hate crime laws.

Both international and national organizations should focus on educating immigrant communities in the U.S. and communities abroad that have high rates of emigration. Locally, many immigrant communities (and communities of color) do not trust law enforcement. They do not know that the police exist to protect their rights, regardless of their legal status. If there is a hate crime committed against them, immigrants should know that they can receive help without repercussions, they may even receive a form of legal aid depending on the crime. For those immigrants that become U.S. citizens and have the right to vote, the community should try to show them why it is important that they do so. They may live in communities full of people of color and not realize the extent of the damage that anti-immigrant organizations can cause. If immigrants do not believe that the number of xenophobic voters can directly affect their lives, they might be less inclined to vote. It would help them to also be prepared to know how to react when exposed to racism and anti-immigrant sentiments. Internationally, education is also important because individuals continue to migrate to the U.S., and they need to know what rights they have as soon as they reach the border. The reality is that when someone decides to cross into the U.S, they may not change their minds regardless of what they hear but having the basic understanding of how the legal system works will protect them from the dangers of militias. Knowing the risks that come with crossing illegally will also help them make informed decisions.

Pro-immigrant groups should also work towards holding the media accountable for their portrayal of immigrants and the use of information that comes from think tanks like CIS. If news outlets want to report on the number of immigrants arriving at the border, they should use reliable information, not an organization that has been tied with white supremacist groups and that has consistently been shown to use false statistics. Some steps that can be taken are social media campaigns, boycotts of certain news outlets, and petitions. If news outlets want the support of diverse audiences, then they should make the effort to accurately report on immigration. This would not focus on news outlets that have already taken a clear stance against immigration, rather on the organizations that label themselves as moderate, neutral, or more left leaning. If they want to educate the public on issues pertaining to immigration, they need to do a better job with their methods. An example of this is the previously mentioned confusion between FAIR, CIS, and NumbersUSA. It should be clear that all three organizations are related and have used false data multiple times. If they are to be used as a source for immigration, they should be seen as one rather than separate entities that have arrived at the same conclusion.

Another recommendation for immigration activists is to focus on lobbying the government, both local and federal, so that they take a harder stance against xenophobia and are stricter in enforcing their anti-hate crime laws. President Biden, the members of his administration, and directors of government programs must make it clear that they are against xenophobia, are pro-immigrant, and will not follow the path of their predecessors. It is no longer acceptable to just announce that you are appalled by a specific hate crime that has occurred, as with the death of the Flores family, but vehemently state that all forms of xenophobia, racism, and mistreatment of immigrants is unacceptable. Activists should pressure the government to take these steps. It is also important to hold Biden accountable for the promises that he made to the immigrant community and that helped get him elected. He must create a path for citizenship for DACA recipients and activists should make sure the administration does not “forget” their promises. Calling representatives and senators to make it clear what the community wants is one way to help with this.

Conclusion:

The anti-immigrant movement has had a strong hold in American society and their visibility increased during the Trump administration, but the numbers show that Americans continue to support immigration. Regardless of the successes that the anti-immigration movement has had in the past, if immigration activists continue to fight against xenophobic organizations and racists politicians, the United States can become a country that welcomes immigrants.

 

 

 

[1] Carl L. Bankston and Danielle Antoinette Hidalgo, Issues in U.S. Immigration: 2 Volume Set, vol 2 (Ipswich, MA: Salem Press, 2015. Accessed May 4, 2021. ProQuest Ebook Central, 43.

[2] U.S. Laws, Statutes, Etc. An act supplementary to, and to amend the act intitled “an act to establish an uniform rule of naturalization; and to repeal the act heretofore passed on that subject”. Approved-. John Adams, President of the United States Philadelphia, 1798. Philadelphia, 1798. Pdf. https://www.loc.gov/item/rbpe.22400500/.

[3] Virgina. General Assembly, House of Delegates. Alien and Sedition Laws. Washington, Govt. print.off, 1912. Pdf. https: https://www.loc.gov/item/12035929/.

[4] U.S. Laws, Statutes, Etc. An act respecting Alien Enemies. Approved- John Adams, President of the United States Philadelphia, 1798. Philadelphia, 1798. Pdf. https://www.loc.gov/law/help/statutes-at-large/5th-congress/session-2/c5s2ch66.pdf

[5] U.S. Laws, Statutes, Etc. An Act in addition to the act, entitled “An act for the punishment of certain crimes against the United States”. Approved-. John Adams, President of the United States Philadelphia, 1798. Philadelphia, 1798. Pdf. https://www.loc.gov/law/help/statutes-at-large/5th-congress/session-2/c5s2ch74.pdf

[6]  Bankston and Hidalgo, 619.

[7] Muzaffar Chishti et al, “Fifty Years On, the 1965 Immigration and Nationality Act Continues to Reshape the United States,” Migration Policy Initiative, March 2, 2017, https://www.migrationpolicy.org/article/fifty-years-1965-immigration-and-nationality-act-continues-reshape-united-states.

[8] Lindsey Bailey, “What is Zero Population Growth, or ZPG?” Population Education, May 6, 2014, https://populationeducation.org/what-zero-population-growth-or-zpg/.

[9] Kathleen Belew, Bring The War Home: The White Power Movement and Paramilitary America, (Cambridge, Harvard University Press, 2018), 20.

[10] Belew, 34.

[11] Sebastian Normandin and Sean A. Valles, “How a network of conservationists and population control activists created the contemporary US anti-immigration movement,” Endeavour 39, no. 2 (2015): 95, https://doi.org/10.1016/j.endeavour.2015.05.001

[12] “7 Principles of True Comprehensive Immigration Reform,” Federation for American Immigration Reform, accessed March 22, 2021, https://www.fairus.org/7-principles-true-comprehensive-immigration-reform.

[13] Heidi Beirich, “The FAIR Files: Working With the Pioneer Fund,” Southern Poverty Law Center, May 12, 2010, https://www.splcenter.org/hatewatch/2010/05/12/fair-files-working-pioneer-fund.

[14] “United Constitutional Patriots,” Southern Poverty Law Center, accessed March 22, 2021, https://www.splcenter.org/fighting-hate/extremist-files/group/united-constitutional-patriots.

[15] “Mainstreaming Hate: The Anti-Immigrant Movement in the U.S.,” Anti-Defamation League, November 2018, https://www.adl.org/the-anti-immigrant-movement-in-the-us, 11.

[16] “Immigration,” Gallup.com (Gallup, March 31, 2021), https://news.gallup.com/poll/1660/Immigration.aspx.

[17] “Mainstreaming Hate: The Anti-Immigrant Movement in the U.S”, 27.

[18] Brad Brooks, “Victims of Anti-Latino Hate Crimes Soar in U.S.: FBI Report,” Reuters (Thomson Reuters, November 12, 2019), https://www.reuters.com/article/us-hatecrimes-report-idUSKBN1XM2OQ.

[19] “Network Archive,” The Plot Against Immigrants, Western States Center, accessed March 22, 2021, https://plotagainstimmigrants.com/network/.

[20] Debbie Nathan, “A Vigilante Militia Defends an Imaginary Border,” The Intercept, May 18, 2019, https://theintercept.com/2019/05/18/border-militia-texas-mexico-guardian-patriots/.

[21] Kathleen R. Arnold, ed., Anti-Immigration in the United States: A Historical Encyclopedia (Santa Barbara, Calif: Greenwood, 2011), 260 – 261.

[22] Mark Krikorian, “Shortfalls of the 1996 Immigration Reform Legislation,” Center for Immigration Studies, April 20, 2007, https://cis.org/Shortfalls-1996-Immigration-Reform-Legislation.

[23]Raul A Reyes, “The U.S.-Mexico Border Isn’t Protected by Militias, It’s Patrolled by Domestic Terrorists.,” NBCNews.com (NBCUniversal News Group, April 22, 2019), https://www.nbcnews.com/think/opinion/u-s-mexico-border-isn-t-protected-militias-it-s-ncna997056.

[24] Uri Friedman, “What Is a Nativist?,” The Atlantic (Atlantic Media Company, April 12, 2017), https://www.theatlantic.com/international/archive/2017/04/what-is-nativist-trump/521355/.

[25] Ibid.

[26] Ibid.

[27] Bradley Jones and Jocelyn Kiley, “More ‘Warmth’ for Trump among GOP Voters Concerned by Immigrants, Diversity,” Pew Research Center, May 30, 2020, https://www.pewresearch.org/fact-tank/2016/06/02/more-warmth-for-trump-among-gop-voters-concerned-by-immigrants-diversity/.

[28] “Polling Update: Americans Continue to Resist Negative Messages about Immigrants, but Partisan Differences Continue to Grow,” National Immigration Forum, September 18, 2020, https://immigrationforum.org/article/polling-update-americans-continue-to-resist-negative-messages-about-immigrants-but-partisan-differences-continue-to-grow/.

[29] Maria Sacchetti, “Federal Judge Restores DACA, Orders DHS to Accept First-Time Applications from Immigrants,” The Washington Post, December 4, 2020, https://www.washingtonpost.com/immigration/daca-restored-dreamers/2020/12/04/37254908-367a-11eb-8d38-6aea1adb3839_story.html.

[30] Ibid.