Tuesday, April 24, 2012
From UC San Diego:
The 28th Meeting of the Politics of Race, Immigration, and Ethnicity Consortium (PRIEC)
Friday, May 8th, 12:00 - 7:30pm
The Village at Torrey Pines, 15th Floor
The Center for Comparative Immigration Studies
Department of Political Science
12:00-12:30pm LUNCH AND INTRODUCTION
12:30-2:45pm PANEL 1
Alisan Anoll, Stanford University, Dissipating Cuban Distinctiveness: A Study of the Increasing Homogeneity of Latino Political Participation Among Post-1980 Immigrant and U.S. Born Cubans
Zoli Hajnal and Michael Rivera, UCSD, Attitudes Toward Latinos and the White Vote
Chris Haynes, University of California Riverside, Calling All Empathizers: How Empathy Moderates the Effect of Empathic Capacity on Immigration Policy Preferences
Brad Jones, UC-Davis, Anchor Babies and Aliens: What’s in a Name?
Neil Visalvanich, UCSD, An Experimental Manipulation: Candidate Race, Information, and Vote Choice
2:45-3:00pm COFFEE BREAK
3:00-5:15pm PANEL 2
Melissa Michelson, Menlo College, Nativity and Mobilization: Field Experiments in Immigrant Voter Mobilization
Sergio Garcia-Rios, University of Washington, From Defined to Refined: A Theory of Identity Formation among Latinos/a
Joel Fetzer and Michael Weisshar, Pepperdine University, Generic Prejudice and Public Attitudes toward Immigration in Argentina
Kristina Victor, UC Davis, The Ties that Bind: Experimental Evidence on the Effects of Ethnic Cues
Jane Lily, UCSD Sociology, Identity and Protest: How the 2006 Immigration Protests Shaped Identity Among Latinos Living in the United States
Soomi Lee, University of La Verne, Racial Hetereogeneity and Medicaid Expenditure in the U.S. States: A Longitudinal Analysis
* To RSVP, please contact Peggy Chang at firstname.lastname@example.org
In policy debates, Biometric ID cards often are held out as the "magic bullet" in enforcement of employer sanctions under the U.S. immigration laws. A new report, released by the Chief Justice Earl Warren Institute on Law & Social Policy at UC Berkeley School of Law, finds that a biometric ID card would not only have a price tag of over $40 billion in initial costs, but also $3 billion in ongoing annual expenditures. The study also finds that such a card would infringe on Americans’ civil liberties, and fail to stop the employment of undocumented immigrants.
Monday, April 23, 2012
Ground Control to Arizona, Alabama, South Carolina, Etc.: Net Migration from Mexico Falls to Zero—and Perhaps Less
It is only Monday but the immigration news week -- including on ImmigrationProf -- already has been flooded by reports about the upcoming oral arguments in the potential blockbuster Supreme Court case of Arizona v. United States. Still, when it comes to immigration and immigration enforcement, people often think immediately of immigration from one nation -- Mexico. I hope that this Pew Hispanic Center Report (Net Migration from Mexico Falls to Zero—and Perhaps Less by Jeffrey Passel, D’Vera Cohn and Ana Gonzalez-Barrera) does not get lost in the news. It concludes that the largest wave of immigration in history from a single country to the United States has come to a standstill. After four decades that brought 12 million current immigrants—more than half of whom came illegally—the net migration flow from Mexico to the United States has stopped—and may have reversed.
I now introduce to you ImmiLounge, the first social network that connects Immigrants with the American dream. The creators of the website are immigrants who were having a hard time living in America just like most of the Immigrant population. They then decided to come up with a social network for immigrants, where the immigrants help each other, and other organizations that target immigrants log in to help and support the immigrant community. Be it immigration attorneys, immigration information, immigration papers, job search, insurance, etc; immilounge connects Immigrants with all this information with just one click.
I am an immigrant who has lived in America for almost one year now, and so far life has been a very big struggle of survival. I still remain in America because just like every other immigrant, I see America being the land of opportunities. Dreams do come true in America. The main problem I have been going through is connecting with other people like me and finding useful help regarding my immigrant life. I looked hard but nothing seemed to be helping, until I got introduced to one of the co-founders of ImmiLounge. He helped me find what I was looking for and helped me make numerous immigrant friends from all over the world. He then stated how he was going to create a social network that will connect all these immigrants together to form an online immigrant community, and here it is. Just to show you how the member home page looks like, here is an example.
ImmiLounge is a very good start if you are a new immigrant, "fresh of the boat." In immilounge, you can find other immigrants located near you and they can connect you with jobs, schools and much more. Also, if you are looking for health insurance, grants and other necessities, immilounge is connected with other organizations so as to give you what you need instantly. The community is growing on a day by day basis and it is definitely a community to join if you are: an immigrant/foreigner in America, a foreigner looking to migrate to America or a foreigner with family in America.
The site is still new, but it is bound to help millions of immigrants in their pursuit of happiness in America. If you are an immigrant looking to connect with family at home, find help or help other immigrants, find resources that will affect your immigrant life, immilounge is the place to be. Consider it as a Facebook but one that is mainly for immigrants and that is devoted to help them as much as possible. Visit ImmiLounge now at http://www.immilounge.com or contact email@example.com for more information. Trust me, this is going to be the next facebook.
By Alex Ngujiri
Arizona’s merits briefs preview the line of argument that Paul Clement will likely take on Wednesday, when he seeks to overturn the preliminary injunction of four provisions of S.B. 1070. Arizona bases its defense of the controversial law on the notion that the enjoined provisions “parallel” the federal immigration scheme, and that the state merely seeks to assert its “inherent authority” to enforce congressional policy with more vigor than the feds. Not only would implementation of these provisions impermissibly encroach on federal plenary power; it would also be problematic because the premise of parallelism is itself deeply flawed.
In an amicus brief on behalf of the Leadership Conference et al., to which we contributed, we offered several arguments to dispel the mistaken notion that the enjoined provisions “parallel” the federal regime. As we show, the enjoined provisions undermine congressional policy for many groups, such as those eligible for TPS, asylum seekers, victims of domestic violence and trafficking, and those eligible for adjustment of status. The provisions of the Arizona law assume a binary system of immigration status that simply fails to account for federal policy. We also show how Arizona’s laws present serious risks for United States citizens.
In addition, we zero in on Section 3, the provision criminalizing failure by unauthorized immigrants to register with the federal government under 8 U.S.C. 1302(a). This section epitomizes Arizona’s thorough misapprehension of federal immigration law. Arizona and Clement mistakenly presume the existence of a comprehensive federal registration scheme that simply does not exist. It is as if Arizona is legislating in a time warp. Instead of “paralleling” today’s federal registration scheme, Section 3—if it parallels anything at all—actually parallels the scheme of the 1940’s and 50’s, when the federal government was primarily concerned with identifying and deporting Communist sympathizers. For fifty-two years, federal regulations have largely limited registration forms (and requirements) to immigrants who are eligible for specified forms of status. This has been clear at least since the Eisenhower Administration, which promulgated a list of registration forms aimed at lawful residents and visitors. Even the post-9/11 “special registration” imposed by the Attorney General on particular groups did not cover those who entered without inspection (“EWIs”).
So why has Arizona attempted to resurrect vestigial language from the Alien Registration Act of 1940? Perhaps—as some commentators have concluded—this is an attempt to finagle back-door criminalization. Since EWIs will have no way to comply with this phantom registration requirement, Section 3 will de facto criminalize their presence in this country. This directly conflicts with Congress’s decision not to criminalize mere presence (notably, all legislative proposals to criminalize presence have failed). Most EWIs, while subject to civil removal proceedings, are simply not subject to criminal penalties under the federal scheme. Although illegal entry constitutes a misdemeanor, it is governed by the federal five-year statute of limitations. That means that the 90+% of unauthorized immigrants who entered before 2005 are not chargeable under this provision.
Dissatisfied with a mostly civil federal immigration system and in the name of “attrition,” Arizona has plucked language from the anachronistic Alien Registration Act in order to create its own permanent criminal dragnet for EWIs. This approach exemplifies Arizona’s misapprehension of longstanding federal immigration policy.
By Natasha Rivera-Silber and Jordan Wells
There has been an incredible amount of commentary in recent days about Arizona v. United States, with the Supreme Court in two days hearing oral arguments and considering the constitutionality of Arizona's S.B. 1070. Long an advocate of increased state invoilvement in immigration matters, see Peter J. Spiro, The States and Immigration in an Era of Demi-Sovereignties, 35 Va. J. Int'l L. 121 (1994), law professor Peter Spiro has an op/ed in the N.Y. Times that opines about what we should hope for as to the fate of S.B. 1070:
"Such laws are misguided at best, mean-spirited and racially tainted at worst. The conventional wisdom among immigration advocates is that immigrant interests will be best served if the Supreme Court makes an example of Arizona’s law by striking it down.
But in the long run, immigrant interests will be better helped if the Supreme Court upholds S.B. 1070. Laws like Arizona’s are such bad policy that, left to their own devices, they will die a natural death — and their supporters will suffer the political consequences."
I am not sure what to think about leaving intact a law that admittedly is "at best, mean-spirited and racially tainted at worst." But shouln't we consider the human impacts of allowing S.B. 1070 to be enforced, with state and local law enforcement allowed to engage in profiling of Latina/s as suspected "illegal aliens"? It seems to me that the civil rights impacts of the enforcement of laws like S.B. 1070 should not be ignored while we hope that such "mean-spirited" or "racially tainted laws" "will die a natural death."
Immigration Article of the Day: Immigrant Laws, Obstacle Preemption and the Lost Legacy of McCulloch by Lauren Gilbert
In light of the fact that the Supreme Court is hearing oral arguments in Arizona v. United States later this week, the following article on federal preemption of state immigration enforcement laws could not be more topical: Immigrant Laws, Obstacle Preemption and the Lost Legacy of McCulloch by Lauren Gilbert, St. Thomas University School of Law, Berkeley Journal of Employment and Labor Law, Vol. 33, No. 1, 2012. Here is the abstract:
With Congress’ perceived failure to enforce the immigration laws as a backdrop, this paper explores how the Supreme Court’s recent decision in Chamber of Commerce v.Whiting upholding the Legal Arizona Workers Act exposes some of the tensions and contradictions in modern preemption doctrine. Examining the relationship among express, field, impossibility and obstacle preemption, I explore three emerging trends, all evident in Whiting. The first is an increasing reluctance of the Court to find implied obstacle preemption. The second is an inclination to expand the scope of impossibility preemption beyond the physical impossibility cases. The third is a tendency to no longer explicitly apply the presumption against preemption, and in some cases, to do exactly the opposite: presume preemption. The Court’s decision in Whiting is a harbinger of things to come, as challenges to state and local laws regulating immigrants make their way to the Court and a growing number of states adopt their own versions of Arizona’s S.B. 1070 and the Legal Arizona Workers Act.
I first offer an overview of preemption jurisprudence, focusing on the nearly-forgotten legacy of McCulloch v. Maryland in planting the roots of obstacle preemption. I also examine recent case law showing a tendency on the Court’s part to substitute impossibility and obstacle preemption with a “direct conflict” or “logical contradiction” test. I then address the implications for S.B. 1070 and state and local copycat laws of the Supreme Court’s and lower federal courts’ apparent willingness to uphold state laws modeled after federal law when enacted to redress a gap in federal enforcement. I conclude that the Supreme Court’s adoption of a new direct conflict test as the standard for conflict preemption would be a dramatic paradigmatic shift that would provide lower courts with the means to uphold state and local laws regulating immigrants and immigration to the extent that these laws track federal enforcement measures.
From the Bookshelves: Presumed Incompetent: The Intersections of Race and Class for Women in Academia
Presumed Incompetent: The Intersections of Race and Class for Women in Academia Edited by Gabriella Gutiérrez y Muhs, Yolanda Flores Niemann, Carmen G. González, Angela P. Harris
"Women in academia still face obstacles built up over centuries, but the contributors to Presumed Incompetent have taken a leap toward liberation. Their revelations will enrage you—and open minds and hearts." —Gloria Steinem
"Presumed Incompetent is undeniably a path-breaking book full of stories of resilience and survival. The editors of this magnificent collection attest to the power of storytelling and add to the testimonios of women in academia such as Telling to Live and Paths to Discovery. Each and every one of the authors survived and in telling their stories they offer hope and solace for young women scholars entering the academy." —Norma E. Cantú
"This book felt so painfully familiar I almost could not read it. Those of us who started our careers as firsts and onlys have had to forget much about the cruelty hidden in academic enclaves. Forgetting, a means of surviving, buries pain and erases history, leaving us morally and intellectually flimsy. Thanks to these women for taking the harder path of truth-telling." —Mari Matsuda
"Exploding the myth that we live in a "post-identity" world, Presumed Incompetent provides gripping first-hand accounts of the ways in which women faculty of color are subjected to stereotypes, fears and fantasies based on the intersection of race, gender, and class. It reminds us that the mere passage of time is not enough to create equitable workplaces for anyone facing institutional subordination." —Kimberlé Crenshaw
Presumed Incompetent is a pathbreaking account of the intersecting roles of race, gender, and class in the working lives of women faculty of color. Through personal narratives and qualitative empirical studies, more than 40 authors expose the daunting challenges faced by academic women of color as they navigate the often hostile terrain of higher education, including hiring, promotion, tenure, and relations with students, colleagues, and administrators. The narratives are filled with wit, wisdom, and concrete recommendations, and provide a window into the struggles of professional women in a racially stratified but increasingly multicultural America.
From the Bookshelves: Intimate Migrations Gender, Family, and Illegality among Transnational Mexicans by Deborah A. Boehm
Intimate Migrations Gender, Family, and Illegality among Transnational Mexicans by Deborah A. Boehm 188 pages April, 2012. Deborah A. Boehm has often asked individuals: if there were no barriers to your movement between Mexico and the United States, where would you choose to live? Almost always, they desire the freedom to “come and go.” Yet the barriers preventing such movement are many. Because of the United States’ rigid immigration policies, Mexican immigrants often find themselves living long distances from family members and unable to easily cross the U.S.-Mexico border. Transnational Mexicans experience what Boehm calls “intimate migrations,” flows that both shape and are structured by gendered and familial actions and interactions, but are always defined by the presence of the U.S. state.
Intimate Migrations is based on over a decade of ethnographic research, focusing on Mexican immigrants with ties to a small, rural community in the Mexican state of San Luis Potosí and several states in the U.S. West. By showing how intimate relations direct migration, and by looking at kin and gender relationships through the lens of illegality, Boehm sheds new light on the study of gender and kinship, as well as understandings of the state and transnational migration.
Labornote websiste: Keith Ludlum and Terry Slaughter are two slaughterhouse workers who helped organize the union at the Smithfield Foods plant in Tar Heel, North Carolina. Here they tell the story of the way African American, white and Mexican immigrant workers were able to find common ground in that campaign, and how the company used immigration enforcement to try to defeat them. The original interviews have been edited into narrative form by David Bacon.
From Center for Community Change:
Immigration Groups Plan ‘Echo Actions’ Nationwide on Why Supreme Court Must Declare Arizona’s Anti-Immigrant Law Unconstitutional
On April 25, the U.S. Supreme Court will hear arguments for and against Arizona’s anti-immigrant law, a thinly veiled attempt to isolate immigrants and people of color and to deny them the basic rights everyone deserves.
The Supreme Court will decide whether states have the right to promote racism, hatred, and police harassment toward immigrants and people of color through laws like Arizona's.
Immigration rights groups who are members of the Fair Immigration Reform Movement will hold ‘echo actions’ nationwide on why the Supreme Court must declare Arizona’s law unconstitutional.
Here is a list of events happening nationwide, by state:
April 22-27: Phoenix, Arizona; Prayer Vigil @ Arizona State Capitol (Promise Arizona); Cesar Alcaraz (firstname.lastname@example.org; (602) 200-4947)
April 23: 3:30 – 9 PM: Phoenix, Arizona; Youth March & Rally @ Falcon Park & Civic Space Park (Promise Arizona & United Farm Workers); Cesar Alcaraz (email@example.com; (602) 200-4947)
April 25: 3 – 7 PM: Phoenix, Arizona @ 3 PM at Civic Space Park (Broad Coalition); contact: Opal Tometi 602.349.1073 and B. Loewe, NDLON, 773.791.4668 and Cesar Alcarez 602.200.4947
April 24: 9:30 AM: Los Angeles, California; Rally & Press Conference @ the Federal Building 300 N. Los Angeles Street (CHIRLA); Jorge-Mario Cabrera, firstname.lastname@example.org, (213) 353-1789
April 25: 12 PM: Boise, Idaho @ TBD; Press Conference (Idaho Community Action Network); Fernando Meija, email@example.com, 208-830-0313
April 23: TBD: Chicago, Illinois @ TBD; Press Conference (Illinois Coalition for Immigrant and Refugee Rights); Maria Salazar, firstname.lastname@example.org, 847-668-1536
April 25: 4:30 p.m, Wichita, Kansas: Rally, in front of the Wells Fargo investment building downtown (Wells Fargo Advisors,300 S Main Street.( Sunflower Community Action) Sulma Arias, 316 650-3798
April 25: TBD: Boston, Massachusetts @ Federal Court House; Press Conference & Naturalization Ceremony (MIRA Coalition); Marcony Almeida, email@example.com, 617 350 5477
April 24: 6 PM: Portland, Oregon @ Portland State University, Forum on SB1070 (CAUSA Oregon); Francisco Lopez, Francisco@causaoregon.org, 503 269-5694
April 25: TBD: Salem, Oregon @ TBD (Pineros y Campesinos Unidos de Noroeste); Erik Sorensen, firstname.lastname@example.org, 503-488-0263
April 25: TBD: Knoxville, Tennessee @ TBD (Tennessee Immigrant and Refugee Rights Coalition); Eben Cathey, email@example.com, 615-775-1069
On March 9, 2012, New Mexico Dreamers in Action staged a press conference at the University of New Mexico announcing their participation in the March 10th Coming Out of the Shadows Day, a national movement which sought to challenge U.S. immigration policies by highlighting the stories of undocumented youth. The video depicts the events and participants at the press conference. Check the video out by clicking here.
Sunday, April 22, 2012
Last Friday's "Petition of the Day" on SCOTUsBlog was the cert petition in Yang v. Holder, which seeks review of a Fifth Circuit ruling. The question raised by the petition is whether, under 8 C.F.R. § 1208.13(a), which provides that “[t]he testimony of [an asylum] applicant, if credible, may be sufficient to sustain the burden of proof without corroboration,” an immigration judge must explicitly determine whether an asylum applicant’s testimony is credible before denying asylum for failure of the applicant to provide evidence corroborating his or her asylum application. The courts of appeals are divided on the question.
Jeffrey Meyer of Yale Law School's Supreme Court Clinic is on the petition. Charles Rothfeld of Mayer Brown LLP is Counsel of Record.
Famous for his service in the President Richard Nixon administration, Charles Colson died yesterday. After prison for his Nixon-era activities, Colson had become a religious leader and, in 2010, released an interesting video about immigration. I agree with Colson on a point or two (or three).
Saturday, April 21, 2012
The New Mexico Immigrant Law Center (NMILC) is a dynamic, new immigrant legal service organization based in Albuquerque that is dedicated to providing access to justice to New Mexico’s immigrants. NMILC’s core services include representation of immigrants facing separation of family due to deportation, victims of domestic violence and crimes, immigrant children and asylum-seekers. While we focus primarily on the legal needs of New Mexico’s immigrant communities, we also recognize that immigration problems and solutions are intricately inter-connected with other areas of life and that our advocacy is stronger when we engage in holistic and interdisciplinary care for those we serve though strategic collaboration with community partners.
NMILC is seeking an Executive Director to lead and help build this growing organization. The Executive Director is charged with developing and implementing the organization’s vision; overseeing and providing legal services and advocacy; leading the fundraising process and developing donor relationships; managing internal operations in collaboration with the leadership team; meeting the organization’s financial goals; providing leadership in community affairs and collaborative initiatives; and serving as the public voice of the organization.
*J.D., admitted in at least one state. A minimum of 5 years relevant legal experience.
*Significant knowledge and experience in immigration law, immigration legal services, and advocacy
*Demonstrated success securing national and local grants and developing a strong base of individual donors and supporters. At least 2 years of relevant experience in a non-profit setting.
*Significant experience in providing strategic organization leadership
*Significant experience in leading, collaborating with and managing leadership teams, support staff and volunteers.
*Excellent written and oral communication skills
*Demonstrated skills in building community partnerships.
*Strong understanding of non-profit finances, budgeting, and governance.
*Demonstrated ability to lead and inspire.
* Excellent reputation for integrity and high ethical standards
Salary commensurate with experience. Generous benefits, including health, dental, and paid annual leave. For best consideration, submit cover letter and resume to firstname.lastname@example.org by May 4, 2012. Position to begin as soon as practicable.
The U.S. government has set deportation records in the Obama years. including record-setting deportations of parents of U.S. citizen children. Professors HIROKAZU YOSHIKAWA and CAROLA SUÁREZ-OROZCO remind us of what should be obvious -- that "Deporting Parents Hurts Kids." The U.S. citizen children face one of two difficult options -- separation from their parents or leaving the United States with their deported parents.
To help ensure America's commitment to justice for all, the American Bar Association Commission on Immigration has produced an updated version of "Know Your Rights," an educational video for the more than 400,000 men and women held in immigration detention facilities across the country each year. The "Know Your Rights" video will be especially valuable for more than 80 percent of people in detention who do not have lawyers. Unlike in the criminal justice context, there is no right to government-paid counsel in immigration proceedings.
The 45-minute video replaces a decade-old version with new information that shows detainees how to navigate the court system and what to expect as they await their day in court. Through a series of vignettes with actors re-enacting typical scenarios, the video uses proven adult-education techniques to maximize comprehension and retention. It is available in English, Spanish and French.
he ABA Commission on Immigration collaborated on the project with the American Immigration Lawyers Association, the Florence Immigrant and Refugee Rights Project, Detention Watch Network, and the National Immigrant Justice Center. The Commission is working with U.S. Immigration and Customs Enforcement to distribute the video to the 250 detention centers across the country. Click here to view a preview of the video. To view the entire video, go here.
On Wednesday, April 25, the Supreme Court will hear oral arguments in Arizona v. United States and the constitutionality of the Arisona immigration enforcement law known as S.B. 1070. Advocate for conservative causes Paul D. Clement of the law firm of Bancroft PLLC will argue for the state of Arizona. Donald B. Verrilli, Jr. from the Solicitor General's office, who had a tough time before the Court last month attempting to defend President Obama's health care reform legislation, will argue on behalf of the United States. Recall that Justice Elena Kagan recuised herself from the case and eight Justices will now decide it.
Lyle Denniston has a careful analysis of Arizona v. United States, the arguments laid out in the briefs, and possible outcomes on SCOTUSBlog. Earlier in the week on ImmigrationProf, I laid out some of the relevant context and legal issues raised by the case. See also this article touching on some of the civil rights impacts of S.B. 1070.
One possible outcome warrants consideration. In the Ninth Circuit, Judge Carlos Bea dissented from the majority's invalidation of two of the four provisions of S.B. 1070. As he stated,
"I respectfully dissent from the majority opinion as to Sections 2(B) (entitled `Cooperation and assistance in enforcement of immigration laws; indemnification') and 6 (entitled `Arrest by officer without warrant'), finding their reasoning as to Congress's intent without support in the relevant statutes and case law. As to Sections 3 and 5(C), I concur in the result and the majority of the reasoning . . . ."
Judge Bea's approach might be attractive to several of the Justices, including Chief Justice Roberts, Scalia, Kennedy, Alito, and Thomas. Attracting one or more of these Justices might result in enough votes (along with Justices Breyer, Ginsburg, and Sotomayor, who dissented in last Term's decision in Chamber of Commerce v. Whiting, which upheld the Arizona law that stripped business licenses from the employers of undocumented immigrants), to uphold part of the Ninth Circuit's ruling.
Friday, April 20, 2012
Germany's importation of temporary workers in the 1960's and strict naturalization rules created tension. The turkish workers, who remained after the program, faced integration obstacles. The naturalization rules denied children of undocumented immigrants citizenship and therefore the kids grew up feeling like theri own place of birth did not want them. Two things helped Germany with the tension. The naturalization and derivative citizenship rules were relaxed and many undocumented residents in Germany were legalized when the EU was formed. Akso all the italian, greek, and Spanish workers who lacked immigration status were thereafter eligible for residence in Germany. But even though irregular immigration (their term for undocumented immigration) in Germany is very low and total immigrant population is about 16 million (including first and second generation), integration of immigrants is a challenge. The presindent, the prime minister, foundations, and several political parties, are spending resources thinking through how to incorporate immigrants into German society and how to promote tolerance of differences--a very tall order for most coutries. I will talk about some of those programs in my next entry. EQ
For an account of how an African American/Latino coalition defeated a state immigration enforcement measure backed by Kris Kobach, see David Bacon, "How Mississippi's Black/Brown Strategy Beat the South's Anti-Immigrant Wave."