Department of Homeland Security announces Temporary Protected Status: Liberia, Guinea and Sierra Leone

TPS

The following is an announcement by the U.S. Department of Homeland Security, announcing Temporary Protected Status for Liberia, Guinea, and Sierra Leone.

For more general information, please read our article explaining Temporary Protected Status.

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Due to the outbreak of Ebola virus disease in West Africa, Secretary of Homeland Security Jeh Johnson has announced his decision to designate Liberia, Guinea, and Sierra Leone for Temporary Protected Status (TPS) for 18 months.  As a result, eligible nationals of Liberia, Guinea, and Sierra Leone who are currently residing in the United States may apply for TPS with U.S. Citizenship and Immigration Services (USCIS). The Federal Register notices provide details and procedures for applying for TPS and are available at www.uscis.gov/tps.

The TPS designations for the three countries are effective Nov. 21, 2014 and will be in effect for 18 months. The designations mean that eligible nationals of Liberia, Guinea, and Sierra Leone (and people without nationality who last habitually resided in one of those three countries) will not be removed from the United States and are authorized to work and obtain an Employment Authorization Document (EAD). The 180-day TPS registration period begins Nov. 21, 2014 and runs through May 20, 2015.

To be eligible for TPS, applicants must demonstrate that they satisfy all eligibility criteria, including that they have been “continuously residing” in the United States since Nov. 20, 2014 and “continuously physically present in” the United States since Nov. 21, 2014.  Applicants also undergo thorough security checks.  Individuals with certain criminal records or who pose a threat to national security are not eligible for TPS. The eligibility requirements are fully described in the Federal Register notices and on the TPS Web page at www.uscis.gov/tps

Liberians currently covered under the two-year extension of Deferred Enforced Departure (DED) based on President Obama’s Sept. 26, 2014 memorandum may apply for TPS. If they do not apply for TPS within the initial 180-day registration period, they risk being ineligible for TPS because they will have missed the initial registration period. Liberians covered by DED who already possess or have applied for an EAD do not need to also apply for one related to this TPS designation. However, such individuals who are granted TPS may request a TPS-related EAD at a later date as long as the TPS designation for Liberia remains in effect.

Applicants may request that USCIS waive any or all fees based on demonstrated inability to pay by filing Form I-912, Request for Fee Waiver, or by submitting a written request. Fee-waiver requests must be accompanied by supporting documentation. USCIS will reject any TPS application that does not include the required filing fee or a properly documented fee-waiver request.

All USCIS forms are free. Applicants can download these forms from the USCIS website at www.uscis.gov/forms or request them by calling USCIS toll-free at 1-800-870-3676.

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Attorney KiKi M. Mosley is licensed to practice law by the State of Illinois and Louisiana. She is skilled and experienced in complex immigration law issues. For more information about the law firm, please visit www.KiKisLaw.com, and do not forget to “Like” the firm on Facebook and “Follow” on Twitter. You can also review Attorney Mosley’s endorsements on her Avvo profile.

Civil Rights Complaint: Asylum seekers deported in expedited removal, border patrol officers ignoring policy

There are nine individuals identified in the complaint, who were deported from the U.S. to countries where they faced persecution.

There are nine individuals identified in the complaint, who were deported from the U.S. to countries where they faced persecution.

U.S. Customs and Border Protection (“CBP”), in a civil rights complaint, is alleged to overlook, ignore or block refugees from claiming asylum in the U.S. Often without a hearing or proper screening people are deported through the expedited removal process, even when they express fear of persecution and seek asylum in the U.S.

Authentic asylum seekers are blacklisted when they are improperly removed.

When an immigrant arrives in the U.S., they may seek asylum and, if eligible, they may be allowed to remain in the U.S. pending the outcome of their application. One of the eligibility requirements is that the individual has not previously been subject of a removal order. If CBP is deporting immigrants with authentic asylum pleas, they will later be blocked from admission to the U.S. because they will not be eligible because of their removal order, even if it is not warranted and was issued in mistake or neglect.

There are nine individuals identified in the complaint, who were deported from the U.S. to countries where they faced persecution. All nine of them were deported without hearings, were subject to renewed persecution in their country of origin and when they returned to the U.S. they were determined ineligible because of their prior removal. These individuals now are in the status of withholding of removal, and are subject to removal orders which the government agrees to withhold indefinitely.

The civil rights complaint calls for increased officer training and oversight.

In the civil rights complaint filed on November 13th with the Department of Homeland Security (“DHS”) Office of Civil Rights and Civil Liberties, identifies CBP officers regularly thwarting the current systems and processes are the southern border officers where many Central Americans arrive in the U.S. after fleeing gangs, violence and persecution. In a statement by Keren Zwick, managing attorney for Heartland Alliance National Immigrant Justice Center reported, “CBP officers have tremendous power over the fate of people who come to our borders seeking refuge, and what comes a corresponding obligation to ensure our government does not deport anyone back to countries where they may be persecuted or tortured…Unfortunately many officers abuse that power.”

People who come to the U.S. to seek asylum often leave countries where they face persecution for their race, political, religious, sexual and other beliefs and associations. In cases, the asylum seekers fear torture and death. The single act of fleeing to the U.S. can cause serious problems for deported immigrants not able to seek asylum.

The complaint, prepared with the input from a significant collection of human rights groups and lawyers, requests that the DHS civil rights office make the following recommendations to CBP:

  1. Train CBP officers to ensure they understand the agency’s asylum screening requirements and are sensitive to the circumstances of recently arrived asylum seekers.
  2. Improve oversight to ensure officers comply with proper asylum screening procedures during the expedited removal process.
  3. Reinforce to CBP officers that they are not responsible for adjudicating individuals’ asylum claims, but must refer individuals who express a fear of persecution to the U.S. Citizenship and Immigration Services Asylum Office.

While this complaint is reviewed for consideration, many look to Capitol Hill awaiting action on immigration reform by President Obama’s executive order or an act by Congress that would fix the current outdated and broken system of immigration law and policy.

Immigration attorney, KiKi M. Mosley frequently represents asylum applicants at Asylum offices and immigration courts and can help asylum applicants at any part of the immigration process. Attorney KiKi M. Mosley is licensed to practice law by the State of Illinois and Louisiana. She is skilled and experienced in complex immigration law issues including and related options for undocumented immigrants seeking immigration relief. For more information about the law firm, please visit www.KiKisLaw.com, and do not forget to “Like” the firm on Facebook and “Follow” on Twitter. You can also review Attorney Mosley’s endorsements on her Avvo profile.

President Obama to reduce refugee allotments for Central Americans but calls for alternative program to benefit foreign applicants

The new programs President Obama wants would allow eligible people to apply for refugee status from other countries before they arrive on U.S. soil.

The new programs President Obama wants would allow eligible people to apply for refugee status from other countries before they arrive on U.S. soil.

There is a limit on the number of foreign individuals allowed to apply for refugee relief and resettlement assistance in the U.S. under special humanitarian concern. Last week President Obama reduced the limit for Central American refugees, despite the recent increase in arrivals from the Central American countries where crime and gang violence drove more than 60,000 families from their homes; the overall refugee admissions limit for fiscal year 2015 is the same as 2014, at 70,000. President Obama announced his interest in new programs for asylum seekers. In connection therewith, the allotment for people from Honduras, Guatemala and El Salvador is 4,000 down from the allotment of 5,000 for the current fiscal year.

The U.S. Citizenship and Immigration Services (“USCIS”) website contains general information about refugee and asylum status. The current allotment reduction for Central Americans concerns refugee status, defined by USCIS as, “A form of protection that may be granted to people who meet the definition of refugee and who are special humanitarian concern to the United States. Refugees are generally people outside of their country who are unable or unwilling to return home because they fear serious harm.[i]

The serious harm people often fear is that they will be or have been persecuted for reasons of t heir political opinion, membership in certain groups, sex, nationality, race and origin, to name a few. A variety of factors contributes to the balance of serious harm to people and humanitarian factors. Often major events, including weather catastrophes like a tsunami causing massive destruction can influence the allotments of admission to the refugee relief programs.

Here is a list of the new allotments[ii]:

  • Africa 17,000
  • East Asia 13,000
  • Europe and Central Asia 1,000
  • Latin America and Caribbean 4,000
  • Near East and South Asia 33,000
  • Unallocated Reserve 2,000

The new programs President Obama wants would allow eligible people to apply for refugee status from other countries before they arrive on U.S. soil. Specifically, the programs the president wants developed would allow Central Americans to apply for refugee status from within their own countries.[iii] In Honduras, El Salvador and Guatemala, people could benefit from a program that would give them greater security when seeking to apply for immigration relief, rather than risk detention for unlawful presence and experiencing rough conditions in the U.S. Department of Homeland Security residential facilities for undocumented immigrants arriving on U.S. soil.

There are several options President Obama may have in ordering the establishment of a refugee program of this kind and Chicago immigration attorney KiKi M. Mosley will follow the progress of this type of immigration reform effort to keep clients and colleagues up to date as the Obama administration works towards solving problems in the broken U.S. immigration system.

Attorney KiKi M. Mosley is licensed to practice law by the State of Illinois and Louisiana. She is skilled and experienced in complex immigration law issues including and related options for undocumented immigrants seeking immigration relief. For more information about the law firm, please visit www.KiKisLaw.com, and do not forget to “Like” the firm on Facebook and “Follow” on Twitter. You can also review Attorney Mosley’s endorsements on her Avvo profile.

[i] USCIS website: Refugees & Asylum

[ii] The White House Office of the Press Secretary: Presidential Memorandum – – FY 2015 Refugee Admissions

[iii] Immigration Impact, Proposed Refugee Program Limited in Central American Impact, by Amy Grenier, Oct. 3, 2014.

Immigration judges in Denver to take on asylum cases while reports of due process violations against women and children detainees

The conditions and reports of the court process in Artesia are reported as appalling.

The conditions and reports of the court process in Artesia are reported as appalling.

More than 600 women with their children and unaccompanied children are detained in an ICE facility in southeast New Mexico in the desert town of Artesia. The detention center was opened to help house newly arriving Central American refugees. One ICE official spoke out confidentially and said, “The goal is to process the immigrants and have them deported within 10 to 15 days to send a message back to their home countries that there are consequences for illegal immigration.[i]

The conditions and reports of the court process in Artesia are reported as appalling.

Volunteer attorneys representing asylum seekers frequently speak out about the conditions in which they find immigrant women and children. Several professionals involved report that mothers are directed to testify before an immigration judge, right in front of their children, and detail the physical, emotional and other abuses committed against them to prove the credibility of their pleas for asylum.

Only 38 percent of asylum seekers are granted relief in Artesia, significantly less than other facilities. Laura Lichter, a lawyer from Colorado who has been making volunteer trips to represent women and children in Artesia recently told reporters that, the living conditions there are like a “hellhole” and the way court cases are being handled is “appalling.[ii]” Many agree with the criticisms of what has been happening in Artesia, which led to a lawsuit filed against the U.S. by several human rights advocacy groups.

New Denver Immigration Judges are taking over some of the asylum docket for video hearings.

Video hearings for asylum seekers are being transferred from Immigration Judges in Arlington, VA to their colleagues in Denver. In the same time zone, as one proponent noted, the immigration judges in Denver are expected to more fairly uphold due process of law while engaged in the expedited review of immigrant asylum cases. Of course, the spokesperson from the U.S. Department of Justice, Kathryn Mattingly states the decision to reassign cases to the Denver judges had nothing to do with complaints about the Artesia facility or the pending lawsuit.[iii]

Two of the Denver immigration judges will be taken off the current Denver immigration court docket, leaving the third judge to manage a staggering 8,000 plus cases with hearing dates set out as far as 2018. Local attorneys practicing before the Denver Immigration Judges have mixed feelings about the transfer. “The general feeling is that we are really happy to have these [asylum] cases in Denver,” said Denver immigration attorney Byron Large, who also lamented the increased backlog of other immigration cases.

To learn more about volunteer attorneys and the need for their services, please read our article, “More than 60,000 unaccompanied minors need immigration lawyers and volunteer organizations need pro bono help.”

Attorney KiKi M. Mosley is licensed to practice law by the State of Illinois and Louisiana. She is skilled and experienced in complex immigration law issues including and related options for undocumented immigrants seeking immigration relief. For more information about the law firm, please visit www.KiKisLaw.com, and do not forget to “Like” the firm on Facebook and “Follow” on Twitter. You can also review Attorney Mosley’s endorsements on her Avvo profile.

[i] Denver Post, Feds: Immigrant center to expedite deportations, by Juan Carlos Llorea, Associated Press, Jun. 26, 2014.

[ii] Denver Post, Backlogged Denver immigration courts will take on glut of asylum cases, by Nancy Lofholm, Sept. 22, 2014.

[iii] Denver Post article at HNii above.

Millions of immigrants again on hold: More political moves delay immigration reform as deportations continue.

President Obama announced a delay of his executive action until after the mid-term elections in November, irritating many who anticipated immigration relief.

President Obama announced a delay of his executive action until after the mid-term elections in November, irritating many who anticipated immigration relief.

Children at recess used to play a game called “Red Light, Green Light,” where the one child faces away from the other children who start behind a line, saying “green light,” so the children behind the line can creep closer and tag them before they quickly turn around and say, “red light.” Is this the real strategy on immigration reform on Capitol Hill?

Reporting news and updates on immigration reform and the problems caused by inaction seems futile when people make promises and do not keep them. More often, people say they will make every effort at taking action, the political version of a promise. Both sides of the political aisle are frustrated with the failure to make meaningful reform to our badly outdated immigration system. As President Obama, the Democrats and Republicans in Congress continue sparring, the human casualties are mounting.

President Obama announced a delay of his executive action until after the mid-term elections in November, irritating many who anticipated immigration relief.

Earlier this summer, President Obama asked Jeh Johnson, Secretary of the Department of Homeland Security (“DHS”) to hold off on releasing the results of a review of the immigration system, so House Republicans could get together necessary votes to pass a reform bill. It never happened. When Congress adjourned for summer break, the President reported he was working on his own plan for relief through executive orders, something the House Republicans first criticized him for doing, and then suggested he take executive action after all. Meanwhile, the mid-term elections scheduled for November are the latest roadblock to reform. On Saturday September 6, The Associated Press tweeted, “BREAKING: White House officials: Obama to delay immigration action until after November election.”

Result: “Millions of immigrants will face at least 60 more days under the threat of deportation[i]

The human cost of this delay is significant. As the quote from the article indicates, millions of undocumented immigrants who anticipated relief from deportation now fear the worst. Of the millions of immigrants waiting for relief, advocates estimate that an actual 60,000 immigrants will be deported within the next 60 days.

DHS is still stating that they are, “using “prosecutorial discretion” so that resident, law-abiding unauthorized immigrants don’t get deported.[ii]” Instead, they claim, “high priority” immigrants, “those who have committed crimes, have recently entered the country, or were deported and then came back,” are the focus of current deportation activity.[iii]

The message sent by the U.S., likely heard worldwide, is that immigrants are marginalized.

Wouldn’t you feel alienated and awkward coming to a country in political turmoil over what to do about your arrival and presence? From one political party who embraces policies helping people suffering violence and injustice in their home countries, to another who would like to catapult them back to their home countries, it must be terrible not knowing who they can trust. Some compassion for people who likely are not thrilled about leaving their home countries would make for a stronger immigration stance and the current ping-pong games make U.S. leaders look foolish.

While likely feeling marginalized by a seemingly unfair political struggle, the undocumented immigrants who made it safely to the U.S. can only hope for positive change and relief, through President Obama or Congress, whoever is able to make a meaningful difference. Attorney KiKi M. Mosley also hopes for positive change in U.S. immigration policy. She will continue to offer updates and available immigration news.

Attorney KiKi M. Mosley is licensed to practice law by the State of Illinois and Louisiana. She is skilled and experienced in complex immigration law issues including and related options for undocumented immigrants seeking immigration relief. For more information about the law firm, please visit www.KiKisLaw.com, and do not forget to “Like” the firm on Facebook and “Follow” on Twitter. You can also review Attorney Mosley’s endorsements on her Avvo profile.

[i] Vox, The human cost of Obama’s delay on immigration action, by Dara Lind, Sept. 8, 2014.

[ii] See, Vox article above (HNi)

[iii] See, Vox article above (HNi)

Immigration reform: Requests to separate immigration courts and judges from the Justice Department

The United States Department of Justice (DOJ), also known as the Justice Department, is the U.S. federal executive department responsible for the enforcement of the law and administration of justice. The Department is led by the Attorney General, who is nominated by the President and confirmed by the Senate and is a member of the Cabinet. The current Attorney General is Eric Holder.

The United States Department of Justice (DOJ), also known as the Justice Department, is the U.S. federal executive department responsible for the enforcement of the law and administration of justice. The Department is led by the Attorney General, who is nominated by the President and confirmed by the Senate and is a member of the Cabinet. The current Attorney General is Eric Holder.

Immigration Judges and courts are different from most courts because the legal process in immigration is not a function of the Judicial Branch of government, but rather it is part of the Executive Branch, reporting to the U.S. Department of Justice (“DOJ”). According to leaders from the National Association of Immigration Judges (“NAIJ”), this is a significant problem and impediment to doing real justice. As employees of the DOJ Executive Office for Immigration Review, the Immigration Judges who also act as the attorney for the DOJ and must follow orders and policy from the Executive Branch. Recently when President Obama directed Immigration Judges to start hearing newly arrived immigrant children’s cases, solely before their other pending cases, some of those judges started to speak up and state their objections.

Judge Dana Leigh Marks is the president of NAJI and she is speaking out, calling for the separation of immigration courts from the DOJ. In several published articles, Marks highlights the irony in the system where judges and courts are funded and overseen by the agency established to implement and prosecute immigration laws. Marks recently stated, “Our goal is to serve as a neutral court, but paradoxically we are housed in a law enforcement agency.[i]” Further, she highlighted, “There is no other court system in which the government would be allowed to order a total overhaul of the docket, placing particular cases at the top.[ii]

Congress has yet to move forward on comprehensive immigration reform, but if and when they do, these Immigration Judges want separate immigration courts.

The organized union for Immigration Judges was represented at a recent National Press Club event, in part, by Denise Noonan Slavin, the union’s executive vice president. Salvin spoke with Judge Marks and rhetorically asked, “If your gas tank has a leak do you keep filling it up with gas or do you fix it first?[iii]

Not only is the gas tank leaking, as you might say, the line for gas is out the door; many say the underfunding of the current immigration courts is to blame for a massive backlog of 375,000 immigration cases, seen by 227 field judges who hear cases.[iv] Judge Marks is one of those judges and she alone has over 2,400 pending cases. The next case set on Judge Marks’ calendar might be heard three and a half years from its filing date.[v]

Article I of the U.S. Constitution provides for the establishment of courts.

Like the court systems for tax and bankruptcy, immigration courts, independent of the DOJ, could be established under Article I of the Constitution.[vi] While the cost of establishing a new court structure under the Judicial Branch could be significant, the savings of time and resources could make it well worth the investment. Judge Marks suggests, “This would free them (judges) from any control or influence by the Attorney General or Department of Homeland Security.[vii]

Whether comprehensive immigration reform would include new immigration courts is unknown and there have not yet been significant responses from members of Congress on this subject. Meanwhile, it is likely certain that advocates for sensible immigration reform, like Judge Marks, will continue pushing the case to remove the immigration courts and judges from the Executive Branch.

KiKi M. Mosley is an immigration attorney who represents immigration clients and experiences the backlog of cases and troubled system first-hand, and works diligently to share ideas for system reform. Attorney KiKi M. Mosley is licensed to practice law by the State of Illinois and Louisiana. She is skilled and experienced in complex immigration law issues. For more information, please visit www.KiKisLaw.com, and do not forget to “Like” the firm on Facebook and “Follow” on Twitter. You can also review Attorney Mosley’s endorsements on her Avvo profile.

[i] PBS News hour, the Rundown, Immigration Judges’ union seeks independent court system, by Alicia Caldwell, Associated Press, Aug. 27, 2014.

[ii][ii] See PBS article at FNi

[iii] See PBS article at FNi

[iv] AZcentral, 12 News, Immigration Judges urge removal from Justice jurisdiction, by Erin Kelly, Gannet Washington Bureau, Aug. 27, 201.

[v] See AZCentral article at FNiv

[vi] Power…to constitute tribunals inferior to the Supreme Court. Article I U.S. Constitution.

[vii] The Hill, Let Immigration Judges be judges, by Dana Leigh Marks, May 9, 2013.

Executive orders in immigration: President Obama to follow past presidents in executive action

A history of executive orders.

A history of executive orders.

President Obama, backed into a corner by Congress, must fix immigration with a pen and phone. The New York Times reports that the President, behind closed doors, is working on executive actions to overhaul immigration. An arduous task at best, the President has much work to do, meeting with lobbyists and members of interest groups and advisors. It is noteworthy that the executive branch of government may use executive orders to accomplish goals, despite the lack of an organized system for executive action. Congress, however, is by design, the branch of government best structured to conduct hearings, sort information and create laws. Without the meaningful assistance of Congress, President Obama is now expected to follow previous presidents who affected immigration using executive action.[i]

Everyone is affected by systemic problems in U.S. immigration but politics creates a permanent block to progress.

House Democrats want amnesty for individuals seeking asylum and immigration relief. House Republicans want southern border security and an efficient deportation process. With increased awareness of terror groups and rampant criminal action in the streets, many people living in violent and insecure countries are learning how they can come to the U.S., but they don’t know how to navigate the system to come legally, and follow in line with others making a run to U.S. borders. The immigration problems in the U.S. are not getting better and they will likely only grow worse. In the past, U.S. presidents, from both political parties, used executive orders to solve pressing immigration problems.

President Obama, like his predecessors, has executive order options he can use to overhaul immigration.

The way you hear House Republicans attacking and suing President Obama for signing executive orders in once instance, and criticizing him for failing to write immigration reform may be confusing to many. In fact, President Obama has only issued 185 executive orders as of August 5, 2014[ii]; According to Newsweek, his number, “Is Lower Than Any President in 130 Years.[iii]” In a recent report prepared by a political research organization, Executive Actions Speak Louder Than Words[iv], other recent presidents signed many more orders than President Obama:

  1. Barack Obama – 185 executive orders between 2009 and 2014;
  2. George W. Bush – 291 executive orders during two terms in office;
  3. Bill Clinton – 364 executive orders during two terms in office;
  4. George H.W. Bush – 166 executive orders during one term in office;
  5. Ronald Reagan – 381 executive orders during two terms in office;
  6. Jimmy Carter – 320 executive orders during one term in office.

Past presidents, including Reagan and both Bush presidents used executive action to address immigration.

Important executive orders have been used in recent history to address compelling civil rights problems. While so many people are quick to judge a current president’s record, it is easy to forget that this is not a new method to cure immigration problems in the U.S. Here is a summary of some notable executive actions in immigration, taken by recent U.S. presidents[v]:

  • 1987 – President Reagan eased immigration standards for 200,000 Nicaraguan exiles in the U.S.;
  • 1990 – President Bush Sr. protected Chinese students fearing persecution if sent back to China;
  • 1991 – President Bush Sr. delayed deportation for hundreds of Kuwaiti residents for four years;
  • 1992 – President Bush Sr. made repatriation “automatic” for Haitians coming to the U.S., including those with “potentially valid claim to refugee status”;
  • 1993 – President Clinton granted 18-month extension of the Deferred Enforcement Departure Program, giving 200,000 Salvadorans the right to legally live and work in the U.S.;
  • 1997 – President Clinton again used executive authority to give exemptions to up to 20,000 Haitians for an additional year, from strict new deportation rules;
  • 1998 – President Clinton temporarily suspended deportation to hurricane-ravaged countries;
  • 2001 – President Bush Jr. gave temporary protected status to up to 150,000 Salvadorans;
  • 2002 – President Bush Jr. expedited naturalization for green card holders enlisted in the military.

Obviously, the use of executive actions by U.S. presidents, in immigration, is a common practice. Despite House Representatives, who refuse to take meaningful action in immigration reform, the President can and apparently will sign one or a series of executive orders to address current immigration crises, including some 57,000 recent migrant individuals fleeing from Central America.

KiKi M. Mosley keeps pace with the immigration roller coaster on Capitol Hill because real people need immigration reform today.

Attorney KiKi M. Mosley is licensed to practice law by the State of Illinois and Louisiana. She is skilled and experienced in complex immigration law issues including DACA and related options for children arriving in the U.S. For more information about the law firm, please visit www.KiKisLaw.com, and do not forget to “Like” the firm on Facebook and “Follow” on Twitter. You can also review Attorney Mosley’s endorsements on her Avvo profile.

[i] New York Times, Behind Closed Doors, Obama Crafts Executive Actions, by Julie Hirschfeld Davis, Aug. 18, 2014.

[ii] Federal Register, Executive Orders website.

[iii] Newsweek, An Embarrassing Hole in Boehner’s Plan to Sue ‘King’ Obama, by Leah McGrath Goodman, Jun. 27, 2014.

[iv] American Bridge, Executive Actions Speak Louder Than Words, Aug. 8, 2014.

[v] See American Bridge report (HNiv) for specific article sources.