Backlog of asylum cases at USCIS and the immigration courts

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Currently across the world, the number of people being displaced from their homes due to violence and other problems has increased greatly. Many of these people are fleeing to other countries seeking to escape from threats to their lives. The United States has received many asylum seekers in recent years. However, we lack the resources to deal with the high volume of refugees, which has created an enormous backlog at the United States Citizenship and Immigration Services (USCIS) Asylum Division and within the immigration courts.

A refugee or asylee is legally defined to be a person unable or unwilling to return to their country of origin because of persecution or a well-founded fear of persecution on account of race, religion, nationality, political opinion, or membership in a particular social group.

Human Rights First, a non-profit organization which helps coordinate legal representation to refugees in partnership with pro-bono attorneys, has published a report concerning the state of the immigration courts and USCIS in regards to these asylum cases, which make up approximately 20% of cases in the immigration courts. They found that at present, over 620,000 removal and asylum cases are pending in the immigration courts. Additionally, asylum seekers typically wait between three and six years for a resolution of their asylum claim – an exceedingly long time and which often detrimentally affects these potential asylees.

The systemic delays in both USCIS and the immigration courts have created a backlog; the number of cases that are backlogged at the Asylum Division at USCIS has more than quadrupled since 2013. That is, in 2013, there were 32,560 cases pending; that number has increased to 144,500 by March, 2016. This backlog is growing at a rate of approximately 20,000 cases every three months, and if nothing changes, USCIS is estimated to have over 200,000 pending cases by the end of 2016.

The delays are largely caused by an increase in credible and reasonable fear interviews, which are given to potential asylum applicants upon arrival at a US port of entry. In credible fear interviews (CFI), the USCIS officer determines if there is a “significant possibility” that the petitioner can establish an asylum or withholding of removal claim before a judge. In a reasonable fear interview (RFI), the officer determines whether there is a “reasonable possibility” of future persecution based on one of the five protected grounds under the refugee definition – the number of CFIs and RFIs have increased nine fold and seven fold, respectively, since 2009.

The average wait time for an initial asylum interview exceeds two years. Of the eight USCIS offices handling these cases, six are now scheduling interviews for applications filed over two years ago. This wait time is incredibly far behind the statutory requirement, which requires USCIS to conduct an initial interview within 45 days and have a complete initial adjudication within 180 days of the case being received.

Besides the CFIs and RFIs, another reason why the Asylum Division is so backlogged is because it lacks funding to hire a sufficient number of asylum officers necessary to adjudicate the cases in a timely manner. In order to completely eliminate the backlog, USCIS needs to increase its staff to 700 or 800 officers from its current size of 447.

The immigration courts also have a huge load of backlogged cases. In early 2016, the number of backlogged cases reached 480,815. If more judges are not hired, the backlog is predicted to reach 500,000 cases by the end of the 2016 fiscal year, and 1,000,000 cases by fiscal year 2022. The court is severely understaffed with a mere 254 judges, when 524 are needed to handle the large caseload. Because of this issue, delays can cause potential asylees to wait over six years in total for their cases to be adjudicated. It can take over two years for the initial interview with the USCIS Asylum Division. If USCIS denies the case, it then refers it to immigration court, where it can take more than another three and a half years, at best, to have the case heard. The problem feeds on itself, as many judges have retired due to the deteriorating working conditions, while not enough judges are being hired to cover this loss.

While these two divisions remain underfunded and understaffed, Congress has disproportionately increased the budget for immigration enforcement – the budget for enforcement agencies, such as Customs and Border Protection (CBP) and the Immigration and Customs Enforcement (ICE), has more than quadrupled, increasing from $4.5 billion in 2002 to $20.1 billion in 2016, whereas funding for the immigration court increased by a mere 74%. This has also contributed to the backlog – the US now has a greater capacity for apprehending and prosecuting immigrants, but this creates cases and without a proportionately increased budget for the systems handling these cases, the number of pending cases has skyrocketed.

At present, the number of people seeking asylum is at an all-time high. The chronic underfunding of USCIS and the immigration courts has caused the backlog to grow since 2008. Many refugees are fleeing from violence in Guatemala, Honduras, and El Salvador, and the volume of unaccompanied children and families has increased dramatically recently. This has exacerbated the backlog, as these refugees’ cases are given priority over other asylum seekers. While these cases are, in large part, meritorious (that is, approximately 90% of Central American asylum seekers who are lucky enough to be represented by an attorney are eventually granted asylum), the priority given to them has resulted in tens of thousands of cases being rescheduled for as late as November, 2019.

The impact these backlogs cause on the refugees can be highly detrimental. While potential asylees wait to be approved, their family members remain separated and in danger. Their families often are in hiding and face persecution, sometimes as a direct result of their loved one petitioning for asylum in the US. Furthermore, the long wait can harm the refugee’s mental health. The constant fear of not knowing what will happen, whether they will receive asylum, and their concerns about their family members’ safety, impedes many asylum seekers from being able to fully recover from their past trauma. Oftentimes, they struggle with worsened symptoms or develop new symptoms such as heightened stress and depression. In addition, many seekers have difficulties supporting themselves since they are not authorized to work for many months after first filing their asylum claims. They are also often unable to pursue an education since it is expensive – most forms of financial aid are not available to asylum seekers.

The long wait additionally has a negative impact on pro-bono legal representation. Almost 75% of pro-bono coordinators have said that the delays in the immigration courts play a significant role in their ability to take on a pro-bono case. However, access to legal representation is a substantial factor for the petitioning refugee, and can make the difference between deportation or relief.

Human Rights First proposed a few steps that could be taken in order to adjudicate these cases in a timely and fair manner, the main one being to increase funding for the Asylum Division at USCIS and the immigration courts.

In summary, if nothing changes from our current situation, the number of asylum cases will continue to exponentially increase and place stress on our resources. USCIS and the immigration courts will continue to be overly burdened and asylum seekers will have to wait for even longer periods to get their cases settled, which will harm their relationships and mental health. As Human Rights First explains, we are in a state of crisis, and this poor and unfair treatment of refugees needs to be rectified quickly.

All information in this post was obtained and summarized from the report published by Human Rights First. If you are interested in learning more about the backlogs in the USCIS Asylum Division and the immigration courts, please follow the link below to access the full report:

Antonio Banderas’s inspiring acceptance speech at the 2015 PLATINO Awards of Iberoamerican Cinema

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“Since you are not experienced in things of the world, all things that are a bit difficult seem impossible to you. Trust time; it usually provides a sweet way out of many bitter challenges.”
-Miguel de Cervantes Saavedra, Don Quixote

Antonio Banderas was the winner of the Honorary Award at the prestigious PLATINO Awards of Iberoamerican Cinema this year. The Spanish actor repudiated Donald Trump’s comments in which he characterized Mexicans as delinquents. Banderas defended Latin and Iberoamerican culture in his inspiring acceptance speech, which we have translated for your reading pleasure:

Thank you. Receiving this PLATINO award is obviously an honor, especially since I’m receiving it from the hands of a legend, Rita Moreno; indeed it is a great privilege.

From my Phoenician, Muslim, Roman, and Picassian Málaga, on my father’s side, and Zambrinian, on my mother’s side, I send my regards to all the Latin communities with which I unite not just in the same tongue, but also in our shared desire to dream, and of doing it through the big screen in movement, that is what we call cinema.

Whether I want to or not, I must acknowledge that receiving an award comes with a mountain of vain temptations against which one must fight as Don Quixote fought against the windmills, or giants, of his Manchegan land. And although I was born in Andalusian lands, in Málaga, which, for me, is a dream come true, I have always believed myself to share with that gentleman of sad figure, the foolish insanity, the irrepressible yearnings, and the eager vocation for adventure.

Today I am so happy and excited to receive this recognition, for which I am grateful from the bottom of my heart, as I am of receiving so many friends, so much talent, to whom I hope my Malagan land will open the door and treat with the same affection with which I have been treated in each of the Latin countries in which I have had the good fortune of working.

Seven movies in Mexico, three in Argentina, one in Venezuela, one in Chile, one in Colombia and one in Puerto Rico, in which I was able to share with large teams of professionals a way to make cinema, and a way of understanding life.

But the great change has not been produced yet. The great leap has not been taken. It was really the United States, it must be acknowledged, which little by little has given possibilities to Hispanic talent, and some of us who are present here have benefited from this fact—give to Caesar what is Caesar’s, and to Hispanics what is ours. It is there, I repeat, where I begin to comprehend the real dimension, the universal character, the indubitable potential, and the uncontainable strength of what is Latin.

That place where, despite Mr. Donald Trump’s noxious and absolutely reproachable interest in kicking our behinds, a crucible of communities that speak the Cervantean tongue reunite, not only enriching the cultural life of the country, but also contributing values supported in their own dignity, hard work, sacrifice, and the powerful aftertaste of feeling united against no one.

Indeed, without confrontations, with an open heart, with curiosity as our flag, and with the clear idea that, although we all love our respective countries of origin, we can, without a doubt, embrace the idea of the Latin and the pride of feeling Hispanic.

I think that these PLATINO Awards are a platform to begin a journey that helps us consolidate the respect that Latin cinematography has acquired, that allows us to reclaim our tongue in productions, and that makes us strong so that we are able to compete in equality of circumstances. No more and no less.

No one will value us if we don’t do it ourselves.

I will end with Cervantes and his Don Quixote who, from his dreaming and at times lucid mind, would say:

“Since you are not experienced in things of the world, all things that are a bit difficult seem impossible to you. Trust time; it usually provides a sweet way out of many bitter challenges.”

Lydia’s Long Wait – A Federal Court Victory

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From left: Nancy Vizer, Lydia, and Noelia Rodríguez

Lydia has given us permission to use her real name for this story. She is one of the United States’ newest citizens. Lydia has been an asset to the United States for many years, serving as one of the patient, caring people who tends to elderly people in their homes, giving our parents and grandparents the time and energy that we can’t take out of our busy lives.

Yet Lydia was a victim of incompetence, indifference and outright heartlessness on the part of numerous US government employees.

Lydia came to our office about five years ago. She had come to the United States from Ghana and had married a nice young man, a US citizen. He wished to sponsor her for permanent residence, so that she would be able to remain here and share her life with him. It is our policy to only take cases where we are convinced that the couple is “real”; we have declined numerous illegal “fraudulent marriage” cases over the years.

After meeting with the couple and satisfying ourselves about their relationship, we prepared and submitted the necessary application forms, attended an interview with the couple, and the case was approved in due time.

Since Lydia had not been married for two years when her case was approved, she was required to renew her permanent residence two years later, to again prove that she was not in a sham marriage. We met with the couple and again submitted the necessary application package on August 12, 2012. And then we waited. We got a formal Request for Evidence in the mail and submitted additional documents. And then we waited. The couple was called in for an interview. The interviewing officer asked for additional documents. We provided the additional documents. And then we waited. The interviewing officer was reassigned before he closed out the case, so the couple was called in for a second interview, which we attended together. And then we waited.

We finally got tired of waiting. Because she had been a permanent resident for well over the required three years, Lydia was eligible for US citizenship, so we prepared and submitted that application package. She was called in for an interview within a reasonable amount of time, but the officer told us she could not approve the case until the permanent residence renewal had been resolved. I reminded the officer that the regulations require that a citizenship application be approved or denied within 120 days of the interview. We left the interview. And then we waited. After 120 days, we wrote to several supervisors, advising them that the interviewing officer was violating the regulations by not finishing out the case within 120 days. And then we waited.

During all of this time, Lydia missed the funerals of two good friends in Ghana. She wished to visit her father in Ghana, whose health is not good. But she was afraid to travel while her various applications remained pending. There is always the possibility that if an application is denied while the foreign national is overseas, she will not be admitted back into the United States.

So finally, after about 150 days of waiting for a decision on Lydia’s naturalization application, we took the matter to federal court, seeking the judge’s order requiring US Citizenship and Immigration Services to follow its own regulations. And then we waited. The government was required to respond to our complaint within 60 days, but asked for an additional 30 days. We agreed, since the judge would have allowed the delay  with or without our agreement. The US government just gets to do that, with no excuse.

Finally, on the 90th day, August 10, 2015, almost exactly three years after Lydia started her renewal odyssey, we learned that USCIS had approved her case, so that its officers would not have to explain to a federal judge why the USCIS was violating the law. She took her oath of citizenship on August 25. We normally don’t go to these oath ceremonies, but we chose to go to Lydia’s to share the end of her very difficult ordeal.

We are thrilled that she will continue to be an asset to this country, to our parents and grandparents, and that her long wait is over!

Watch out for Diversity Visa Scams

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Every year the Department of State conducts a “Diversity Visa Lottery,” where people from all over the world who wish to become lawful permanent residents of the United States enter their information online, and several thousand are selected.  The only “real” requirement is that the applicant have a high school diploma (and not be a criminal, etc., etc.).  Every year, the Department of State database gets hacked (surprise, surprise).  And every year, many people are taken in by scams, believe they have been selected, and send money to the hackers.  Finally, every year, we hear from at least one victim, telling us they have paid the fee, and now need our help to proceed.  PLEASE don’t fall victim to this scam.  As of today, there are no “slots” left in this fiscal year’s lottery, which ends October 1, 2015.  That is, if you have not heard from the Department of State by now, you were not selected.  If you get an email that you think is “legit” for the 2015-2016 lottery, you are welcome to contact our firm.  We do not charge to check whether you have been scammed or not.

For those who are trying for the 2015-2016 lottery, good luck, but be careful!

Suman’s Surprise – An EB-1 Outstanding Researcher Success

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I don’t know “Suman” very well, as I have mostly worked with her husband, “Karan.” Suman was born in India, but spent a part of her adult life living in other parts of Asia as she followed Karan’s career around the world. Besides continuing to work full time, Suman was the primary caretaker for the couple’s child. She has been living in the United States for about a year and loves it here!

Karan is an outstanding researcher in the field of Biotechnology. His arduous research at a major US university is helping to improve the environment both in the United States and overseas. He is also helping to develop crops that will not only grow more efficiently, but will taste better to consumers.

As citizens of India, it was quite difficult for Karan, Suman and their daughter to obtain permanent residence in the United States. There is an annual quota for each category of permanent residence. Each country can only use 7% of the quota each year, so certain categories are oversubscribed, and that country’s citizens must wait years to “move to the head of the line” with respect to the quota.

In Karan’s case, there were two ways he could get permanent residence. The easier way would be to prove that his work is in the national interest (we all want a better environment and better tasting crops, I think), that it would have nationwide benefits (ditto) and that his work is exceptional among his peers. However, this particular category is so oversubscribed among citizens of India that the family’s wait for permanent residence would have been close to ten years. During this time, it would have been very difficult, or maybe impossible, for Suman to work legally in the United States. The family would have to survive on one postdoctoral researcher’s income. Sadly, in spite of the importance of Karan’s work, this pay is not enough for a family of three.

So we tried a different category; “outstanding” researcher, or category EB-1. This category has a much higher standard, but it is not oversubscribed. The family could become permanent residents within about 90 days of the immigration officer’s finding that Karan’s work is “outstanding.” Suman would be able to keep working. (She had a temporary work authorization that she would not have been able to renew after the end of August, 2015).

It was getting close to August. The family was facing the loss of Suman’s income, which would have led to very difficult times. So Karan turned to me for help.

I reviewed Karan’s cv with him, and told him that I thought his work was outstanding, but that I was not the one who would decide his case. I could only prepare an application package and submit it to USCIS. I worked intensely with Karan over a six-week period to gather reference letters from his peers, along with about 80 other supporting documents. Karan paid the government an additional $1,225 “premium processing” fee, over and above the normal $2,720 government filing fee, to insure that the government would make a decision about whether or not his work was “outstanding” within 15 days. Quite a gamble when the government’s standard of review is often prohibitive in these cases. Karan, who was aware of the risk, was willing to take it to ensure his family’s future.

Sure enough, within about a week, we received a preliminary approval notice, and I expect the family to become permanent residents before the end of the year.

So why is this blog post called “Suman’s Surprise?” Because Karan decided to surprise Suman with the approval. In fact, he didn’t even tell her he was submitting the preliminary application package. When it was approved, Karan took his family out to Maggiano’s for a great Italian dinner. He first handed his phone to a friend to take a video. Then he told Suman he was giving her an early birthday present, and handed her an envelope with the preliminary approval notice inside. There were several other associated documents, and Suman took a few minutes to leaf through them, trying to understand the significance.

Finally, she “got it.” Watching the video of her face move from confusion to exuberance was one of the most rewarding moments of my career. Suman gradually realized that her family would be able to remain in the United States indefinitely, that she would be able to continue working, and that their child would be a “normal” part of the American fabric. Her smile grew bigger as she figured out each implication of the pieces of paper in her hands. As she got up to hug Karan, he told the camera, “I didn’t tell her.” The couple’s daughter caught the mood and began hugging both parents, running from one side of the table to the other.

I hope that I get to meet Suman, Karan and their daughter one day. They live far from Chicago so they will have to plan a family “road trip.” But whether I ever meet them or not, I am glad that the United States will continue to benefit from their presence here.

The inadequacy of the In-Country Refugee/Parole Program for Central American Minors (CAM)

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On December 1, 2014, a new program was announced by the U.S. Department of State (DOS) in response to the “surge” of immigrant minors at the border during the summer of 2014. The program implemented by U.S. Citizenship and Immigration Services (USCIS) is now called CAM which stands for the Central American Minors Refugee/Parole Program. It is specifically designed to help minors living in Honduras, El Salvador and Guatemala who have parents lawfully residing in the United States to escape the violence and turmoil in their native country.  It is dubbed “a safe, legal, and orderly alternative to the dangerous journey that some children are currently undertaking to the United States.” Information on who is eligible to apply for the program and a description of the process can be found at the following link:

As of April 23, 2015 the program has only received 461 applications, none of which have been adjudicated. The estimated processing time for an application is 9 months to a year. In the mean time there are no protections offered to the children awaiting adjudication. The “safe, legal, and orderly alternative” characterization of the program belies its true nature.  The reality is that these children do not have time to wait 9 to 12 months, and even to a casual observer this seems absurd. Essentially the U.S. government is saying, “You say you fear for your life because you have already been persecuted or you have a well-founded fear of future persecution? That’s nice. Please return to your scary life for 9 to 12 months while we look into that. And I’m sorry, even though speaking to U.S. government officials could expose you to even more danger, we have no protection to offer you. But thanks for applying!”

And let’s further discuss that 461 figure mentioned above. That number seems awfully low compared to the surge of thousands who came in the summer of 2014 and are still coming to our southern borders seeking refuge. It might be said that the program is inadequately publicized but the experience in our office has been that plenty of people in the Salvadoran, Honduran and Guatemalan community are aware of the program and its benefits.

The issue comes from the lack of funding provided to the local designated resettlement agencies here in the United States who are supposed to be helping the parents here in the United States to submit their applications.  During a recent teleconference hosted by USCIS on March 31, 2015, several callers were directors or employees of these resettlement agencies stating that they cannot meet the burden placed upon them to fill out the initial application because they have no budget to support this program. We have heard this complaint from some of our own clients who state that they called 3 or 4 resettlement agencies here in the Washington, D.C. area and none of them were able to assist in filling out this application. How is this program supposed to provide the necessary relief when clients can’t even get basic access to submit their applications?

Furthermore this program has been designed to cut attorneys out of the loop so that the parents who want legal representation during the process do not have that option. The application form can only be accessed and completed with the assistance of a designated resettlement agency, which has no funding to staff someone to assist you with filling out the application. As attorneys all we can do is advise our clients on the potential strength of their children’s claim but at this point there seems to be no other avenue for us to intervene or assist.

At best this program is a loose band-aid for the current crisis at the southern border. At its worst it puts the lives of the refugees at risk because it provides no protection for those who speak to U.S. government officials in connection with these applications. We hope that Congress will heed the appeals of the immigrant advocates who recently testified before them regarding this program and will take active steps to improve it. To view the hearing please click on the following link:

New USCIS Case Status & E-Requests Rife with Inefficiencies

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You have been diligently checking your USCIS case status online for the past few months. For a while now, the case status has reflected that USCIS is “ready to schedule your Form I-485, Application to Register Permanent Residence or Adjust Status, Receipt Number ABC1234567891, for an interview.” On November 11, 2014, you go online once again, and are surprised by the website’s new look, which now includes an “upgraded” Case Status tool. To your dismay, your case status now states “If you do not receive your interview notice by September 5, 2014, please go to ( to request a copy of the notice”!!! Now you are really freaking out. Since when have I had the option to file an E-Request and inquire about my interview notice? Do I have to file an e-request? What if USCIS did send out a notice and I didn’t receive it? It sounds like they did, otherwise why would they be telling me to request a copy of the notice? At this point you either call your attorney and ask them to file the E-Request on your behalf or you go ahead and file one on your own.

As soon as the E-Request is submitted through the website, you are sent to a confirmation page with the following message:

Thank you for your request

USCIS will review and process the request.

Expect a reply by December 3, 2014

Your request ID number is AB12345678912ABC

Your attorney or you receives an email from with the same information.

You have been frenetically checking your inbox in the days leading up to December 3rd, but to no avail–USCIS failed to respond to your request by their self-imposed deadline. Today is December 17, and you have still not received any reply from USCIS. Back to square one.

If you had me as an attorney, I would have told you not to hold your breath. We had a few clients call with the above questions right after USCIS unveiled a new look to its website and additional  features, including the upgraded Cases Status and E-Request tools discussed above. While sleek-looking and user-friendly, these tools are completely useless if they don’t do what they promise to do.

User-friendly, yes. Efficient, not so much.

User-friendly, yes. Efficient, not so much.

I wouldn’t worry too much about the “deadlines” for filing E-Requests. These seem to have been automatically computed from the date of last action on the case. I would especially not worry if you have an attorney on the case, and he/she has also not received an interview notice.

Looks fabulous, but can be highly misleading.

Looks fabulous, but can be highly misleading.

Shortly after the USCIS website unveiled its new look, it went down for nearly a full day. They have significantly improved the speed of the website, but it’s clearly still a work in progress. In light of these ever-changing circumstances, take what you see online with a grain of salt. You might be better off just speaking to a USCIS customer service representative.

John Oliver Blasts Immigration Bureaucracy

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John Oliver recently did a feature about the Kafka-esque difficulties faced by translators who have served the US in Iraq and Afghanistan, at the risk of their lives, when trying to obtain visas to the United States.  The video speaks for itself.  As a PS, the State Department changed its procedures about a week after this show.  Coincidence?  We’ll never know.  Warning:  the video contains language unsuitable for children.

Charlie’s Children – Criminal Immigrants

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Okay, “Charlie” is a criminal. I get it. But that does not make his teenage and young adult children criminals.

Charlie, his three children and their mother came to the US from Central America when the children were about ten years old, give or take. They remained in the United States for years, much longer than the six months they were allowed.

Not a model family man, Charlie left his family for a young lady he met at work. The only positive to come from this union was that when Charlie married this US citizen, she was able to sponsor him and his three children for permanent residence.

Not surprisingly, the marriage did not last long. But at the end of two years, Charlie and the children needed to renew their permanent residence. The renewal application was required to include evidence that Charlie’s marriage to the US citizen had been bona fide. The marriage had been bona fide – there was a child, as well as other evidence that the couple actually lived together as a couple. Although the couple was already divorced, this evidence that it had been a “real” marriage would have been sufficient for Charlie and the children to renew their status.

Unfortunately, there was a catch. Charlie was barred from renewing his permanent residence because of the $100,000 + he had chosen to embezzle. He was in jail and on his way back to Belize once his sentence was over. His children, who were excelling in high school and college, were suddenly left without a way to remain in the United States. Within weeks, the government put them into removal proceedings, seeking to get them out of the country.

Luckily, the timing was right. President Obama had just taken executive action that allowed young adults who had no status in the United States to obtain employment authorization and remain here legally. Charlie’s children fell in this category and were able to take advantage of this lifeline. His oldest child, who recently graduated from college with honors and is now serving the community as a social worker, will be able to get back her permanent residence because she has married a US citizen. The younger two may be able to regain their status this way also at some point. For now, they are grateful for the opportunity to live and work legally in the United States until they are able to become full members of the community.

Charlie writes to me from time to time from Central America, asking me if any of the laws proposed by Congress will help him return to the United States. I can’t imagine that Congress will ever ease the path for convicted felons to return to the US, although it is certainly unfortunate that Charlie’s children are unlikely to ever reunite with their father.

Obama Turns Back on his Political Base – Immigration Politics

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President Obama has once again turned his back on the huge voting bloc that helped him into office, blaming “political pressure” for his failure to act.  American Immigration Lawyers Association President Leslie Holman elaborated on the scope of this betrayal in a press release this past weekend.

The fact is, the last time Congress did anything substantive about immigration was in late 2000.  There is no “right time” for the president to do the “right thing,” and nothing to indicate that if he waits, Congress will do the right thing.

Ms. Holman’s press release can be found on the AILA website: AILA InfoNet Doc. No. 14090640