Thursday, December 31, 2020
Immigration and Customs Enforcement is not taking time off as 2021 is about to begin. On December 30, ICE announced that it had
"arrested 18 foreign nationals sought for their roles in known or suspected human rights violations or human smuggling and trafficking during a nationwide operation which concluded on Dec. 17.
Since 2014, ICE successfully effectuated five No Safe Haven operations targeting known and suspected human rights violators. This year’s Operation No Safe Haven Plus lent support to additionally advance the agency's ongoing commitment to locate fugitives both affiliated with human smuggling or trafficking and subject to final orders of removal.
The foreign nationals arrested during this operation all have outstanding removal orders and are subject to repatriation to their countries of origin. . . . "
Immigration Article of the Day: A Nation of White Immigrants: State and Federal Racial Preferences for White Noncitizens by Gabriel Jackson Chin
U.S. law, of course, drew many lines based on race from the earliest days of slavery and colonialism. It is also well known that the government discriminated against noncitizens in favor of citizens in areas such as licensing and land ownership. This Article proposes that during the long Jim Crow era, there was an additional body of racially discriminatory state and federal law that discriminated against noncitizens of particular disfavored races. This body of law has not been fully recognized or described. Because the federal government and many state governments had policies encouraging white immigration, they sought methods to discriminate against nonwhite noncitizens, primarily Asians, without also burdening white noncitizens. The “declaration of intention” to naturalize, a required part of the naturalization process, was a key device used to effectuate this policy. Between 1790 and 1952, eligibility for nationalization was racially restricted, such that only members of preferred races could file a declaration of intent. Therefore, offering benefits to so-called “declarants” intentionally and effectively favored white immigrants. Hundreds of state and federal laws offered benefits to declarants with respect to a wide range of opportunities, including voting, land ownership, public benefits, military service, public employment, government contracting, and occupational licensing. This combination of state and federal law offered white immigrants in many parts of the United States an opportunity for substantial equality with white citizens from the moment they arrived in the United States, while it simultaneously restricted competition from—and maintained the subordinated status of—noncitizens of color. This body of law should be considered when evaluating the history of racial discrimination in this country and its present effects.
"Elon Musk, South Africa
Elon Musk emigrated to the U.S. in 1992 from South Africa. Although he could have emigrated to anywhere in the world, he chose America because of its vast amount of opportunities.
Elon Musk is now the owner of Tesla and SpaceX. He previously co-founded PayPal as well but sold it in 2002 to eBay for $1.2 billion dollars.
He is currently worth $11.6 billion dollars."
Wednesday, December 30, 2020
One way to round out 2020 on a positive note is to apply for citizenship. CUNY Citizenship Now and other nonprofit organizations are providing assistance remotely. From CUNY: "Our staff is available via phone, #Zoom or #WhatsApp for consultations and to help you fill out the forms. Our services are free. Call 646-664-9400, 9-5, M-F to make an appointment or text 929-334-3784." The New Americans Campaign has collected naturalization workshops all over the country. USCIS has a citizenship resource center on its website.
For more context on the process of applying for citizenship, see "I Hereby Declare, On Oath", the immiwonk blog's multi-part series on naturalization.
Part 1. Naturalization is the end of the beginning of many immigrant's American story. Over the years some people have asked us, “I want to know more about the U.S. immigration system, but where do I start?” To them we always make the same recommendation: start by attending a naturalization ceremony. Whatever your political orientation or attitude about immigration in general, there is no more moving, emotional, and pride-inducing event than watching a group of people from diverse national, religious, and ethnic backgrounds stand together in a room and join this 200 plus year old project in small (d) democracy that we Americans are embarked upon (rocky as it may be at times).
Part 2. Do all green card holders eventually become citizens? While U.S. law outlines a clear process for permanent residents (green card holders) to become U.S. citizens, it is not a requirement. You can live in the United States with a green card for your entire life as long as you follow the restrictions, don’t vote, always file your taxes, and don’t commit a serious crime. While the benefits of citizenship are many, there are also benefits to retaining a foreign citizenship while living in the United States, and not every country in the world is willing to let you maintain your foreign passport if you are also carrying a U.S. passport.
A Part 3 on the good moral character required to get your citizenship application approved will appear next week.
The AP News wrote a retrospective piece on the rush to naturalize as an unintended consequence of Trump's election and the anticipation of exclusionary policies.
And my book and TEDx talk (A New Way to Think About American Citizenship) on Pursuing Citizenship similarly present portraits of the naturalization process based on the first-person experiences of immigrants seeking to become citizens. (Thanks for the shout-out @immiwonk and for including it on the year-end review of immigration books, immigrationprof!)
Immigration law professors published up a storm in 2020.
Here are some of the book chapters that immprofs published this year:
- Sabrineh Ardalan, EU and US Border Policy: Externalisation of Migration Control and Violation of the Right to Asylum in Securitising Asylum Flows: Deflection, Criminalisation and Challenges for Human Rights (Valsamis Mitsilegas, Violeta Moreno-Lax, and Niovi Vavoula eds., Brill Nijoff Press, 2020).
- Jason Cade, All the Border’s a Stage: Humanitarian Aid as Expressive Dissent, in 84 Studies in Law, Politics & Society, Special Issue: Law and the Citizen 109 (Austin Sarat, ed., 2020).
- Anil Kalhan, Hamilton and the Limits of Contemporary Immigration Narratives, in Hamilton and the Law (Lisa A. Tucker ed., Cornell University Press 2020).
- Elizabeth Keyes, Hamilton's Immigrant Story Today, in Hamilton and the Law (Lisa A. Tucker ed., Cornell University Press 2020).
- David B. Thronson, Citizenship and Rights of Children, in The Oxford Handbook of Children Rights Law (Jonathan Todres and Shani King, eds., Oxford University Press, 2020).
- Veronica Tobar Thronson and David B. Thronson, Child Immigration: Barriers Predicated on National Origin and Racial Identity, in Children and Race: Psychology, Public Policy, and Law (Margaret C. Stevenson, Bette L. Bottoms & Kelly Burke, eds., Oxford University Press 2020)
Kevin has already been reviewing the many wonderful books released in 2020. Here's a short list of those authored by immprofs:
- Ming Hsu Chen, Pursuing Citizenship in the Enforcement Era
- Adam Cox & Cristina Rodriguez, The President and Immigration Law
- Alina Das, No Justice in the Shadows
- Michael Kagan, The Battle to Stay in America
- Michael Olivas, Perchance to DREAM: A Legal and Political History of the DREAM Act and DACA
- Philip G. Schrag, Baby Jails
- Philip G. Schrag, Ethical Problems in the Practice of Law, 5th edition (with Lisa G. Lerman and Robert Rubinson)
- Ayelet Shacher, The Shifting Border: Legal Cartographies of Migration and Mobility
- Ilya Somin, Free to Move: Foot Voting, Migration, and Political Freedom
Yesterday, the Ninth Circuit in a Flores v. Rosen rejected the Trump administration's latest attempt to terminate the Flores settlement agreement, which governs the detention of minors. Judge Marsha Berzon, joined by William A. Fletcher and Milan D. Smith, Jr. , wrote the opinion for the court. Daniel Weissner reports on the court's decision for Reuters.
We at the ImmigrationProf blog are trying to end a miserable 2020 on a positive note. Immigrants are contributing big-time to U.S. sports.
In June, Stuart Anderson for Forbes wrote that the number of foreign-born players is rising in professional U.S. sports. "Rising revenues and sports salaries show native-born players have benefited and consumers (i.e., fans) are happy to experience the improved product."
“New research shows foreign-born athletes play an important role in professional sports in America. Foreign-born players make up 23% of the rosters in the National Basketball Association (NBA), 29% in Major League Baseball (MLB) and 72% in the National Hockey League (NHL),” according to a new National Foundation for American Policy (NFAP) analysis. “This is the highest proportion of foreign-born players ever recorded for the NBA and MLB.”
Sports fans can see the impacts of immigrant athletes. Mexican-born Julio Urias closed out the World Series for the world champion Los Angeles Dodgers. One National Basketball Association mega-superstar Giannis Antetokounmpo (Milwaukee Bucks) is a previous two-time Immigrant of the Day. His amazing story started in Nigeria, moved to Greece, and later the United States. Be on the lookout for a Disney biopic on the "Greek Freak."
Tuesday, December 29, 2020
Immigration law professors around the country have a whole lot to celebrate in 2020. Check out these professional developments.
- Sameer Ahmed joined the Harvard Immigration and Refugee Clinical Program as a clinical instructor.
- Cori Alonso-Yoder joined Georgetown Law as a visiting professor, directing the federal legislation clinic.
- Eunice Lee landed her first full-time tenure-track teaching position at the University of Arizona James E. Rogers College of Law.
- Reena Parikh joined the faculty of Boston College Law School as an assistant clinical professor. She'll be directing a new civil rights clinic focused on the issued affecting immigrant communities and low-wage workers.
- Rick Su lateraled from Buffalo to University of North Carolina School of Law in Fall 2019, finishing his first year at UNC in Spring 2020.
- Sabrineh Ardalan was promoted to Clinical Professor of Law and is now the Director of the Harvard Immigration and Refugee Clinical Program.
- Pooja Dadhania was promoted from Assistant Professor to Associate Professor at California Western School of Law.
- Kit Johnson (yup, me) received tenure and became a full professor at the University of Oklahoma College of Law.
- Jennifer J. Lee moved onto the tenure track at Temple University Beasley School of Law.
- Katherine Reynolds went from interim to permanent director of Elon University School of Law's Humanitarian Immigration Law Clinic.
- Jason Cade became Associate Dean for Clinical Programs and Experiential Learning at the University of Georgia School of Law.
- Kathleen C. Kim was appointed to be the inaugural Associate Dean for Equity & Inclusion at Loyola Law School (L.A.).
- Beth Lyon became the Clinical Program Director and inaugural Associate Dean for Experiential Education at Cornell Law School.
- Rachel E. Rosenbloom is now Associate Dean for Experiential Education at Northeastern University School of Law.
- Shoba Sivaprasad Wadhia became Associate Dean for Diversity, Equity, and Inclusion at Penn State Law.
- Michael A. Olivas retired in January 2020, after teaching at the University of Houston Law Center for more than 38 years.
Congratulations to all! Let's be sure to raise a glass at the AALS immprof social on January 8.
Mixed-status households with immigrants in their families may now be eligible for stimulus checks under a $900 billion coronavirus relief package that went into effect this week.
Up until now, US citizens and permanent residents who filed a joint tax return with an undocumented spouse were excluded from stimulus funding. Children of undocumented immigrants were also ineligible. The March 2020 CARES Act departed from practices in other federal programs that permit US citizen children of undocumented immigrants to receive benefits -- for example, the child tax credit, food stamps, housing assistance, welfare -- if they otherwise qualify. (A lawsuit challenging the March 2020 relief bill is pending.)
With the new legislation, which passed with bipartisan support, they will receive a check for $600, as well as $600 per dependent child, comparable to other families. The expanded eligibility would impact an estimated 16.7 million people who live in mixed-status households nationwide, including US citizens as well as legal permanent residents and DACA recipients.
The law also allows households with at least one family member who has a Social Security number to retroactively receive checks for up to $1,200 and an additional $500 per child under the last round of stimulus relief. But many undocumented immigrants and other taxpaying noncitizens who do not have a Social Security number are still barred from receiving stimulus checks under the law.
Noah Smith: New President Should Focus on Legal Immigration as well as Refugees, Asylum Applicants, etc.
"Making it easier to get green cards and visas might earn Biden some backlash from those who believe that immigrants primarily compete with native-born Americans for jobs. The truth -- that immigration done through legal channels tends to create more jobs than it takes away -- will have a hard time penetrating through the misconceptions built up through decades of anti-immigrant rhetoric.
But even if it’s politically difficult. Biden needs to make foreign researchers and students a priority. The U.S. needs those workers . . . . "
"fiscal year 2020 annual report numbers, highlighting trends that underscore the administration’s focus on enforcing immigration laws and leading investigations that threaten or exploit the customs and immigration laws of the United States.
. . . .
In FY 2020, ICE continued to focus its enforcement efforts on aliens who pose a threat to public safety. ICE’s Enforcement and Removal Operations (ERO) conducted 103,603 arrests, just under 30% fewer than in fiscal year 2019 – largely due to the coronavirus pandemic. Approximately 90% of those arrested had a criminal conviction or charge. Those arrested included aliens with criminal charges or convictions for 1,837 homicide offenses, 37,247 assault offenses, and 10,302 sexual assault or sex offenses. ICE ERO conducted 185,884 removals. The vast majority of ICE ERO’s interior removals – 92% – had criminal convictions or pending criminal charges."
Ted Hesson for Reuters commented on the report:
"U.S. immigration arrests fell by 27% in 2020 as the coronavirus pandemic led to fewer border crossings and reduced operations, a falloff that pro-immigrant activists say should continue when President-elect Joe Biden takes office in January.
U.S. Immigration and Customs Enforcement (ICE) said . . . .that it arrested roughly 104,000 immigration law violators in fiscal year 2020, which ended on Sept. 30. ICE arrested 143,000 during the previous year.
The agency deported 186,000 people this year, a 30 percent decline from a year earlier." bold added).
2020, a year to remember, is coming to an end. Although the instinct may be to forget all of 2020, let's not forget some of the immigration highpoints of the year.
Carnegie Corporation of New York released its annual list of Great Immigrants, honoring 38 naturalized citizens who have enriched and strengthened our nation and democracy. The philanthropic foundation has invited Americans to celebrate these exemplary individuals by participating in its online tribute “Great Immigrants, Great Americans.”
This year, the Corporation highlighted the work of millions of immigrants who are playing an essential role in the global health crisis as COVID-19 responders. A third of the honorees are helping the recovery by serving as nurses and doctors, as well as scientists who are striving to find effective treatments and a vaccine. Also honored are clergy and community leaders who are providing food and vital services to those in need. Overall, the 2020 Great Immigrants represent 35 countries of origin and a wide range of contributions to American life, from human rights and computer science to art, business, education, health care, journalism, music, politics, religion, research, and sports.
Among the COVID-19 responders:
- Fabian Arias Argentinian immigrant and Lutheran pastor distributed food to New Yorkers and comforted his congregation through the deaths of more than three dozen members.
- Luciana Borio Brazilian-born physician and former Director of Medical and Biodefense Preparedness at the National Security Council provided public health guidance and advocacy.
- Raj Chetty Indian immigrant and Harvard University economist launched a real-time data tracker to measure the economic impact of the pandemic and assisted decision-makers as they implemented new public policies.
- Marie Lafontant Haitian-born nurse at the University of Chicago Medical Center, who was assigned to a high-risk screening unit, identified and cared for patients with the virus despite inadequate personal protective equipment for staff.
- Pedro Martinez Mexican immigrant and superintendent of the San Antonio Independent School District oversaw the transition to remote learning for 49,000 students, including distribution of 30,000 computers and 4,000 Wi-Fi hotspots.
- Miriam Merad French-born Algerian immigrant, oncologist, and immunologist led the development of a quick test to monitor inflammatory responses to COVID-19 and a clinical trial to test a drug that might manage those symptoms.
- Siddhartha Mukherjee Indian immigrant, physician, and Pulitzer Prize–winning author used his communication skills to educate the public and build awareness about COVID-19 through forums and his widely read essays.
- Anna Podolanczuk Polish-born researcher and pulmonologist put her health at risk to treat patients in the emergency department at NewYork-Presbyterian/Columbia University Irving Medical Center.
- Teresa Romero Mexican immigrant and first female president of the United Farm Workers led advocacy efforts for the safety and well-being of frontline agricultural workers.
- Moncef Slaoui Moroccan-born physician and researcher has served as Chief Advisor of “Operation Warp Speed,” the Trump Administration’s effort to accelerate development of a vaccine.
- Ramon Tallaj Dominican immigrant, physician, and founder of the community health network SOMOS advocated for hard-hit, low-income, and immigrant New Yorkers and worked with the state to expand multilingual testing sites.
- Paul Yoon South Korean immigrant and rescue paramedic with the Fire Department of New York provided high-level emergency care as the department responded to as many as 7,000 critical cases daily.
- Eric Yuan Chinese-born founder and CEO of Zoom created a platform that millions of Americans relied on to stay connected to family, friends, work, and school during the pandemic.
Read the full list of 2020 Great Immigrants, including musician David Byrne, novelist Yaa Gyasi, University of Connecticut women’s basketball coach Geno Auriemma, and Florida Congresswoman Stephanie Murphy.
Monday, December 28, 2020
Deferred Action for Childhood Arrivals *DACA) recipients receive work authorization.
"ExxonMobil unlawfully denied a DACA recipient a job based on his immigration status, according to a class-action lawsuit filed . . . in federal court.
MALDEF (Mexican American Legal Defense and Educational Fund) and William G. Simpson of Tin Fulton Walker & Owen in Chapel Hill, N.C., filed the suit on behalf of Aldo De Leon Resendiz, 22. De Leon is a recipient of Deferred Action for Childhood Arrivals (DACA) and is authorized to work in the U.S. He is suing ExxonMobil Corporation for employment discrimination.
The Texas-based multinational oil and gas company is accused of violating Section 1981 of the federal Civil Rights Act of 1866, which prohibits discrimination in employment contracting based on alienage and national origin. The lawsuit seeks class-action status on behalf of all non-citizens who were legally authorized to work in the United States but were denied employment by ExxonMobil on the basis of their immigration status.
`Instead of recognizing that DACA recipients are tremendous assets to their employers, ExxonMobil chooses to follow an antiquated policy that prevents and deters work-authorized DACA holders from seeking and receiving employment,' said Thomas A. Saenz, MALDEF president and general counsel. `That policy is discriminatory and unlawful.'
`DACA recipients with work authorizations should not fear unlawful employment discrimination, but rather should be full of aspirations to be employed by the top companies in this country,' said De Leon. `I am both disappointed and frustrated by ExxonMobil's decision to not honor my work authorization. I look forward to vindicating my rights in court and removing barriers to economic participation for immigrants like me.'
The lawsuit seeks to require ExxonMobil to pay damages, for a declaration that its policy of requiring job applicants to have permanent work authorization violates federal law, and for changes to their policies.
The lawsuit is the seventh filed by MALDEF since 2017 challenging employment policies that discriminate against DACA recipients. MALDEF has filed class-action lawsuits on behalf of DACA recipients who were denied employment in California, New Jersey and Florida.
Since it was initiated in 2012, DACA has provided protection from deportation and granted work authorization to hundreds of thousands of young undocumented immigrants who came to the United States as children.
Read the complaint HERE."
WaPo has a fascinating new article about detained migrants who are voluntarily abandoning their claims and embracing deportation in order to escape coronavirus as it spreads through detention facilities. Here are two key paragraphs:
The virus has collided with the Trump administration’s “zero tolerance” approach toward people looking for refuge and asylum in the United States. Those policies have led to a record number of immigrants being held in detention, including 7,000 people who had cleared the first steps of requesting asylum when the pandemic began and would normally have been released on bond while their cases were processed.
Some immigrants have been withdrawing cases against their lawyers’ advice, saying they’re more afraid of being in detention during a coronavirus outbreak than of what might be waiting in the places they fled. More than 2,500 detainees, most with no serious criminal history, have given up their cases since March, according to records from the Transactional Records Access Clearinghouse, a research group at Syracuse University...
The article focuses on one migrant from Honduras who spent three years detained in Farmville, Va., despite establishing credible fear of persecution. His request to be deported was granted. He returned to Honduras, moved to Guatemala, and ultimately died in unclear circumstances.
The initial proliferation of the novel coronavirus (SARS CoV-2) in the United States coincided with a sharp uptick in reports of public racial abuse of “Asian-looking” individuals, bullying of Asian-American children in schools, defacement and/or vandalism of Asian-American homes, and a general sense of epidemic-laced xenophobia.
This article by SHAUNAK SASTRY, PH.D., AND ZHUO BAN, PH.D. draws on the authors' experiences participating in a WeChat group populated by Asian-American parents in a suburban school district and dedicated to being a virtual neighborhood watch, a space where members of this small community could call on one another for help if they were facing COVID-19 related racist attacks.
It complements reports of Asian-American discrimination and harassment across the country, including studies by the Pew Research Center (and here, here, and here) and accounts of others previously posted on immigrationprof blog.
Boris Johnson, Prime Minister of the United Kingdom
Brexit became a reality in 2020. Nolan Rappaport for The Hill reminds us that, as it implements Brexit, the United Kingdom joins the United States in addressing the challenge of managing undocumented immigration. Rappaport notes that
"[t]he Public Accounts Committee in the United Kingdom’s (UK) House of Commons recently published an immigration enforcement report that indicates the UK is experiencing similar problems [as the United States] . . . . The UK committee concluded among other things that the government of the UK does not know the size of the UK’s illegal population or have a clear grasp of the harm that it is causing."
We shall see what direction President-elect Biden takes U.S. immigration law and policy.
Immigrants Playing Role in the Covid-19 Vaccine
|Individual||Affiliation||Where Immigrated From|
|Charles Pfizer||Founder of Pfizer||Germany|
|Albert Bourla||CEO of Pfizer||Greece|
|Katalin Karikó||Sr. V.P. BioNTech||Hungary|
|Dr. Ugur Sahin||Founder of BioNTech||Turkey (to Germany)|
|Dr. Özlem Türeci||Founder of BioNTech||Daughter of Turkish Immigrants to Germany|
|Noubar Afeyan||Chairman and Cofounder of Moderna||Lebanon and Canada|
|Derrick Rossi||Cofounder of Moderna||Canada|
|Stéphane Bancel||CEO of Moderna||France|
|Tal Zaks||Moderna’s Chief Medical Officer||Israel|
|Marcello Damiani||Moderna's Chief Digital and Operational Excellence Officer||France|
|Juan Andres||Moderna’s Chief Technical Operations and Quality Officer||Spain|
The Doctors and Nurses Who Gave Their Lives: More than 28% of physicians (281,000) and 15% of registered nurses (570,000) in America are foreign-born, according to a National Foundation for American Policy report. The sacrifices of native-born and immigrant health care professionals have been the backbone of the country’s response to Covid-19. “Nearly a third of the nurses who've died of coronavirus in the U.S. are Filipino, even though Filipino nurses make up just 4% of the nursing population nationwide,” according to CNN.
Cert Petitions of the Week: Federal funding for sanctuary cities and another dispute about the border wall
Andrew Hamm for SCOTUSblog reports on recently filed certiorari petitions asking the Supreme Court to delve further into issues of immigration policy. One group of cases challenges the Trump administration’s attempt to crack down on so-called sanctuary cities. Another case involves certain construction projects that are part of the U.S./Mexico border wall.
De-funding sanctuary cities and building the border wall both are central Trump administration immigration policies. I imagine that the Supreme Court immigration docket will change in a Biden administration.
Sunday, December 27, 2020
Highpoints of 2020: DACA Recipient Qualifies for U.S. Olympic Trials, DACA Survives in Supreme Court
2020 has been a tough year. In closing out an abysmal time, this series is highlighting some of the year's positive events.
Runner's World reports on what could be viewed as a sad story but, in my estimation, is a story of human endurance and resilience. And it has a good ending.
When Argeo Cruz, an assistant track and cross-country coach at Florida Gulf Coast University, ran under 2:19 at the Houston Marathon and qualified for the U.S. Olympic Marathon Trials. As he told Runner’s World afterward, it felt like he’d reached the “American dream” his parents had for him when they immigrated to the United States from Oaxaca, Mexico, in search of a better life.
Sadly, Cruz later learned he would be ineligible to participate in the Trials because he is not a U.S. citizen.
When Cruz was 11 years old, he and his mother joined his father in the small town of Immokalee, Florida, where his father was based as a farm worker. Like approximately 700,000 young adult immigrants, Cruz is currently living in the United States through the Deferred Action for Childhood Arrivals (DACA).
President Trump threatened to end DACA, Like other DACA recipients, Cruz was relieved by the Supreme Court's decision in June rejecting the Trump administration's rescission of the DACA.
IMDB describes the film And Breathe Normally, streaming on Netflix, as follows: "Two women's lives will intersect while trapped in circumstances unforeseen. Between a struggling Icelandic mother and an asylum seeker from Guinea-Bissau, a delicate bond will form as both strategize to get their lives back on track."
Candice Frederick of the New York Times says this about the film:
"The boy’s query — `Why do they have to live in cages?' — lies at the core of this quiet Icelandic film, now streaming on Netflix, in which Lara, a border control officer, learns what it means to be at the mercy of the law after she and her son, Eldar, are evicted and forced to sleep in their car.
At work, where Lara has the power to reject or deny entry for migrants, she declines passage to Adja (Babetida Sadjo), a woman from Guinea who is traveling with her daughter and sister. The decision leads Lara to confront her privilege when she later finds she must accept help from someone she least expects: Adja, now living in a refugee center, who sneaks in Lara and Eldar so that they can have a warm bed."
Hat tip to Jay Krishnan!