Associate Clinical Professor; Director of the Immigration Clinic; Associate Dean for Experiential Learning

A major problem facing noncitizen criminal defendants today is the vagueness of the term “crime involving moral turpitude” (CIMT) in deportation law. The Supreme Court in the 1951 case Jordan v. DeGeorge decided that a statute authorizing deportation for a CIMT was not void for vagueness because courts had long held the noncitizen’s offense, fraud, to be a CIMT, so he was on notice of his likely deportation. I argue that when noncitizens are charged with an offense that case law has not clearly delineated as a CIMT, the term is vague, since the definition used by the agency and courts, an act that is “base, vile, depraved, and contrary to the rules of morality,” provides no useful definition. Rather, it casts judges in the role of God, deporting noncitizens for sin. Exacerbating this situation is the Supreme Court’s 2010 decision in Padilla v. Kentucky; since the Court held that defense counsel only has a Sixth Amendment duty to warn noncitizens about immigration consequences that are “succinct, clear, and explicit” from the immigration statute, there is no clear obligation to warn about deportability for a CIMT. Scholars have thoroughly discussed the vagueness doctrine and also have begun to analyze the Court’s recent Padilla decision. This article is the first to address whether CIMT in deportation law is void for vagueness in a post-Padilla world.

Boston College Law School Faculty Papers

Deportation for a Sin: Why Moral Turpitude Is Void for Vagueness

In this paper I compare the habeas corpus systems of El Salvador, the United States and Argentina.  My purpose is to develop a general understanding of the procedure for bringing the writ in each country and analyze the substantive law governing the rights of habeas corpus petitioners in each country.  I evaluate the systems against the backdrop of each country’s political and legal history with respect to the writ of habeas corpus.  The ultimate aim of this paper is to reform the habeas corpus law of El Salvador by analyzing the Salvadoran system as compared to the Argentine and U.S. systems.  
I conclude that the Argentine habeas corpus system provides a better model for the Salvadoran system than does the U.S. system.  I draw this conclusion because the two countries share common foundations for their legal systems, in addition to common histories of civil war, during which there were numerous disappearances and denial of habeas corpus rights.  Moreover, Argentina’s habeas corpus law protects the liberty interest of the detained individual more so than U.S. habeas corpus law.  This heightened protection of the right to liberty largely results from the country’s past history of forced disappearances and incommunicado detention.  Because El Salvador witnessed similar problems in its past, the Argentine model provides a good model for Salvadoran reform.

Law and Justice in the Americas Working Paper Series

Habeas Corpus Reform in El Salvador

In the waning days of the Bush administration, Attorney General Michael Mukasey decided In re Silva-Trevino, in which he reversed over a century of immigration law precedent by creating a new moral turpitude test. He abandoned the well-entrenched "categorical approach," the mechanism by which immigration judges decide whether a noncitizen is removable for a criminal conviction, and allowed judges to engage in a factual inquiry of whether an offense involves moral turpitude. The Attorney General made such a broad, sweeping change through a process that allowed no input from affected parties, including the individual whose case became the new precedent. In this article, I argue that courts should refuse deference to Silva-Trevino under "Chevron step zero." Chevron, U.S.A. Inc. v. NRDC introduced a well-known two-step analysis for courts to determine whether an agency’s decision deserved deference: first, courts determine whether Congress used clear language in the statute; second, if Congress was not clear, courts defer to the agency’s reasonable interpretation. The Court later introduced what scholars call "Chevron step zero." In an important step zero decision, the Court decided United States v. Mead Corp., holding that courts should not defer to agency interpretations of law issued through informal procedures because such interpretations do not have the force of law. I argue that courts should not defer to Silva-Trevino under Chevron step zero because the Attorney General did not decide the case using law-like procedures: the decision-making process demonstrated neither transparency nor careful consideration.

The New Moral Turpitude Test: Failing Chevron Step Zero

At first glance, the U.S. immigration system seems very family-friendly. The majority of lawful immigration occurs through family petitions, reflecting family reunification as one of the core principles of immigration policy. However, a closer look at the immigration system calls into question the idea that immigration law is family-friendly. Immigration law's definition of who fits within family relationships and thus deserves sponsorship to join a relative in the U.S. does not include relationships that, in many other parts of the world, are valued (such as grandparents, cousins, and, in some cases, siblings). More importantly, the immigration system's heavy-handed enforcement mechanisms only serve to separate well-functioning families by detaining and deporting thousands of people each year.This article seeks to answer the question of whether immigration law is family-friendly by pointing to certain policies that seem family-friendly but that, once examined further, reveal that they serve to keep families apart. The same can be said for the immigration policies of the Obama administration, which has made strides towards implementing more family-friendly immigration laws, but also has maintained a system that tears families apart.

Is Immigration Law Family-Friendly?

In this article, I examine the burden of proof in bond proceedings.  I apply theories for why burdens of proof exist in the law to demonstrate why the government should bear the burden of proof.  I also argue that in order to ensure that such detention comports with Due Process, the government must prove, by clear and convincing evidence, that a detainee is dangerous.  This presumption of freedom previously existed, yet was eviscerated by the former Immigration and Naturalization Service in a 1997 regulation and the Board of Immigration Appeals in a 1999 decision.  That the detainee must bear the burden of proof in bond hearings has become the norm, yet this article seeks to explain how this burden shift occurred and, in doing so, exposes this troubling aspect of today’s bond hearings.

The Beast of Burden in Immigration Bond Hearings

President Trump, during his campaign, promised a “deportation task force” to swiftly deport the eleven million undocumented noncitizens in the United States. Within his first week in office, he issued two Executive Orders calling for stricter immigration enforcement and a stronger border. The Department of Homeland Security (“DHS”) Memos implementing his interior and border enforcement executive orders indicate that DHS will use every tool to enforce the immigration laws, expanding the use of procedural tools that bypass immigration courts and ensuring that noncitizens remain detained during these “shadow” deportations.Two of these procedural tools, administrative removal and expedited removal, allow an Immigration and Customs Enforcement (“ICE”) officer or Customs and Border Protection (“CBP”) officer – the immigration police – to sign off on arrest and detention with no involvement of an immigration judge. Such a seizure without a probable cause finding by a neutral, detached magistrate, if occurring within the criminal justice system, would clearly violate the Fourth Amendment. In this article, I build off of prior scholarship and litigation examining Fourth Amendment violations in immigration law to argue that the arrest and detention pursuant to administrative and expedited removal is an unreasonable seizure. I propose a framework for thinking about the Fourth Amendment violations at issue in these shadow deportation procedures. This framework focuses on the reasonableness of the seizure, not the status of the person harmed by the seizure, and not whether the proceedings that follow are punishment. In doing so, this article examines how the Fourth Amendment’s core concerns are present in the immigration law enforcement context notwithstanding immigration law’s plenary power. As such, the article contributes to the scholarship that has both challenged immigration law’s historical exceptionalism and mapped where the plenary power has not trumped.

The Unreasonable Seizures of Shadow Deportations

When a person suspected of a crime is arrested without a warrant, the Fourth Amendment guarantees that freedom may not be taken away except upon a neutral magistrate judge’s prompt confirmation that probable cause exists that this person in fact committed the crime.  In contrast, in the deportation process, a person is often detained for weeks before a judge determines that the noncitizen is actually deportable, thus justifying detention.  Even the separate procedures available to review custody do not suffice because the mandatory detention statute renders many detainees ineligible for review by a judge.  If they are entitled to a bond hearing, the presumption is detention, and the detainee must bear the burden of proving he is not a danger or a flight risk.  In this Article, I make a modest proposal:  for post-entry social control acts of deportation, immigration detainees must be brought promptly before a neutral judge to determine whether probable cause exists to hold them.  I limit the reach of this proposal to the post-entry social control acts of deportation (as opposed to extended border control cases) because those are the deportation cases that most resemble punishment for a crime.  Also, for strategic reasons, those who have been admitted to the United States are better served by a quick probable cause hearing before an immigration judge, whereas entrants without inspection could benefit from more time to consult with a lawyer before any such hearing.  I also foresee that this proposal will lead the government to more carefully justify its decision to detain lawful permanent residents (LPRs), and thus LPRs, who have the strongest claims to procedural protections, will benefit the most from this additional procedure.

Promptly Proving the Need to Detain for Post-Entry Social Control Deportation

Refugees are not protected from deportation if they have been convicted of a “particularly serious crime” (PSC) which renders them a danger to the community. This raises questions about the meaning of “particularly serious” and “danger to the community.” The Board of Immigration Appeals, Attorney General, and Congress have interpreted PSC quite broadly, leaving many refugees vulnerable to deportation without any consideration of the risk of persecution in their cases. This trend is disturbing as a matter of refugee law, but it is even more disturbing because it demonstrates how certain criminal law trends have played out in immigration law. This Article offers an explanation for the PSC expansion, the “mistrusting criminal judges effect:” Attorney General Ashcroft and the Board of Immigration Appeals (Board) eliminated the criminal sentence as a relevant factor from the test set forth in the 1982 seminal case on PSC, Matter of Frentescu, which is part of an increasing mistrust of criminal court judges in immigration law. This PSC trend mirrors a trend occurring within the criminal justice system; namely, the “severity revolution” of the 1980’s and 90’s, where attention shifted away from rehabilitating the individual offender and toward minimizing the risks presented by certain classes of offenders. The severity revolution, which was reflected in immigration law during the 1990’s and 2000’s, allowed “tough on crime” mentality to outweigh the humanitarian aspects of the 1980 Refugee Act, where the term PSC first was introduced into U.S. immigration law. This Article seeks to expose this troubling trend in PSC law and proposes that the term include only violent crimes against persons where the offender has served a significant sentence.

Redefining “Particularly Serious Crimes” in Refugee Law

In July, the Trump administration announced that immigration police could start detaining and deporting people anywhere without any involvement by any judge. Prior to subjecting a person to this shadow deportation process, called “expedited removal,” the Department of Homeland Security officer need only determine that the person is without legal status and without two years of continuous presence in the United States. Immigration advocates have just sued, asking a federal court to block the policy. Expanded expedited removal creates a constitutional problem: it violates the Fourth Amendment rights of those who are subject to the procedures.

Expanded Expedited Removal: Can Fourth Amendment "Border Exceptionalism" Be Everywhere Now?

Justice Black warned in 1952 about the dangers of giving immigration police and prosecutors the authority to jail human beings with very little involvement by the judiciary. Today’s immigration detention machine illustrates Justice Black’s fears: U.S. Department of Homeland Security (“DHS”) agents have both arrested 182,869 people in a single year and decided whether those individuals will be released or remain incarcerated for the remainder of their removal proceedings. For those entitled to immigration judge review, the judge works for the Department of Justice (“DOJ”) under the supervision of the Attorney General, the nation’s top prosecutor. Immigration judges’ lack of independence has long been a subject of critique, leading some to refer to themselves as “‘U.S. imitation judges.’” In sum, when the DHS police arrest a person, only a prosecutor reviews that decision. Most of these crucial decisions about a person’s liberty occur without any review by an Article III judge.In this Article, I propose that Congress, in recognition that immigration detention is punishment, strip imitation judges of their authority to review decisions about physical liberty. Such decisions should only be entrusted to a federal magistrate judge, with review by an Article III judge. The procedures are already in place elsewhere; Congress need look no further than the Bail Reform Act, which applies when a person is held while awaiting a criminal trial. Federal courts have borrowed heavily from criminal pretrial detention procedures, engaging in piecemeal oversight of the immigration detention system through habeas corpus review. I argue that these decisions reflect lower federal courts’ persistence in monitoring the rights of immigration detainees, even in the face of legislation that has aimed to limit the judiciary’s role. Yet such review has happened for only a subset of detainees—those who are savvy enough to file a habeas corpus petition and lucky enough (or rich enough) to have habeas counsel, and those for whom the federal court reaches the merits of the custody challenge before the deportation case concludes (which moots the petition). The work of these lower federal courts has been laudable, but a better solution that reaches every immigration detainee is necessary.This Article merges two themes from the existing scholarship: (1) immigration judges’ lack of independence and (2) lack of procedural rights for immigration detainees. Scholars, lawyers, judges, and congressional committees have been recommending a more independent immigration adjudication system for decades. My proposal advocates for a change to a subset of immigration decisions, those involving physical custody. Detention is different from other immigration decisions—scholars have argued that it is punishment. Thus, imitation judges should have no role in these decisions. Nor does the immigration judge have any particular expertise in determining danger and flight risk; rather, magistrate judges make these decisions for criminal defendants on a daily basis. I go further than others by proposing that the adjudicator not be an administrative law judge or even an Article I court, but a magistrate judge, whose decisions are subject to review by an Article III judge. I and others have advocated for stronger procedural protections in immigration detention decisions, such as a government-borne burden of proof, a prompt probable cause hearing, court-appointed counsel, and the requirement that judges determine alternatives to detention and a detainee’s ability to pay; with these procedures, immigration bond hearings can more closely track criminal pretrial detention hearings. My proposal here differs in that it physically moves the procedures to an entirely different court. Rather than importing procedural protections piecemeal into immigration court, with oversight by federal judges through habeas corpus, I propose a system where all decisions regarding physical custody are removed from immigration court and placed in federal district court.

Taking Liberty Decisions Away from "Imitation" Judges

Immigration judges routinely use police reports to make life-altering decisions in noncitizens’ lives. The word of the police officer prevents a detainee from being released on bond, leads to negative discretionary decisions in relief from removal, and can prove that a past crime fits within a ground of removability. Yet the police officers who write these reports rarely step foot in immigration court; immigration judges rely on the hearsay document to make such critical decisions. This practice is especially troubling when the same police reports cannot be used against the noncitizen in a criminal case without the officer testifying, due to both the Sixth Amendment’s Confrontation Clause and Federal Rules of Evidence, neither of which apply in immigration court. In these days of the increasing criminalization of immigration law and prioritization of deporting so-called “criminal aliens,” the police report problem is salient, and impacts thousands of noncitizens every year. 
 
This article argues for a right to confront police officers in immigration court by examining three different ways to conceptualize removal proceedings: (1) in light of the Supreme Court’s 2010 decision in Padilla v. Kentucky, deportation should be considered punishment, thus guaranteeing all of the protections of a criminal trial, including the Sixth Amendment Confrontation Clause; (2) under the Mathews v. Eldridge case-by-case balancing test of the due process clause, courts should balance the interests at stake and adopt a right to confrontation and cross-examination of police officers in immigration court; and (3) if deportation is conceptualized as “quasi-criminal” and thus deserving of some, but not all, of the protections guaranteed at a criminal trial, one of those protections should be the right to confront one’s accuser, especially when the accuser is a police officer. The scholarship has focused on why other rights guaranteed in a criminal trial –court-appointed counsel, freedom from ex post facto laws, freedom from double jeopardy, proportionality principles, and the Fourth Amendment exclusionary rule – should apply to removal proceedings. An overlooked criminal protection is the right to confront one’s accuser in immigration court.

Confronting Cops in Immigration Court

Article 3 of the United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment of Punishment (“CAT”) prevents removal of a person to a country where there is a substantial likelihood of torture. The U.S. ratified the CAT in 1994, yet modified the treaty’s definition of “torture” by inserting an understanding that “torture” includes only pain or suffering that is “specifically intended.” Specific intent, an antiquated criminal law term, has several different meanings in criminal law jurisprudence. In Matter of J-E-, the Board of Immigration Appeals in 2002 chose the most narrow definition of specific intent, “purposeful,” and in doing so shifted the focus in CAT protection cases from the victim to the alleged torturer. In this article, I argue that the BIA has adopted a misguided approach to CAT protection that disregards substantial criminal law jurisprudence and creates an insurmountable obstacle to obtain protection from torture. As a solution, I propose that Attorney General Eric Holder or courts adopt a revised definition of specific intent that includes “knowing that severe pain or suffering is foreseeable.” Such a definition is consistent with the legislative history and purpose of the CAT and finds ample support in criminal law jurisprudence. In addition, this definition of specific intent is employed by the Office of Legal Counsel of the Department of Justice in their 2004 memo regarding whether certain interrogation techniques would subject U.S. troops to prosecution under the CAT.

Specific Intent and the Purposeful Narrowing of Victim Protection Under the Convention Against Torture

Refugees are not protected from deportation if they have been convicted of a “particularly serious crime” (“PSC”) which renders them a danger to the community. This raises questions about the meaning of “particularly serious” and “danger to the community.” The Board of Immigration Appeals, Attorney General, and Congress have interpreted PSC quite broadly, leaving many refugees vulnerable to deportation without any consideration of the risk of persecution in their cases. This trend is disturbing as a matter of refugee law, but it is even more disturbing because it demonstrates how certain criminal law trends have played out in immigration law. This article offers an explanation for the PSC expansion and proposes a definition that includes only violent crimes, i.e., those involving actual or threatened physical injury to a person, where the noncitizen served a significant sentence. While there has been much scholarship on the convergence of criminal and immigration law (dubbed “crimmigration”) and on refugee protection, there has been surprisingly little written about the PSC bar to refugee protection, where crimmigration law meets refugee law. This article seeks to fill that gap in the literature.

This article proposes two theories for the ever-broadening PSC definition. First is what this article terms the “mistrusting criminal judges effect:” Attorney General Ashcroft and the Board of Immigration Appeals (“Board”) eliminated the criminal sentence as a relevant factor from the test set forth in the 1982 seminal case on PSC, Matter of Frentescu; this is part of an increasing mistrust of criminal court judges in immigration law. Second is what this article terms “the sweeping effect:” the expansive reading of the PSC bar is part of a larger trend by the Board and Congress to sweep many offenses into a “crimmigration” term of art in order to render more noncitizens deportable and fewer eligible for relief from removal. These PSC trends mirror a trend occurring within the criminal justice system; namely, the “severity revolution” of the 1980’s and 90’s, where attention shifted away from rehabilitating the individual offender and toward minimizing the risks presented by certain classes of offenders. The severity revolution, which was reflected in immigration law during the 1990’s and 2000’s, allowed “tough on crime” mentality to outweigh the humanitarian aspects of the 1980 Refugee Act, where the term PSC first was introduced into U.S. immigration law. This article seeks to expose these troubling trends in PSC law and proposes that the term include only violent crimes against persons where the offender has served a significant sentence.

The Expansion of “Particularly Serious Crimes” in Refugee Law: Mirroring the Severity Revolution

Scholars, immigration judges, attorneys, and congressional committees have been calling for a truly independent immigration adjudication system for decades, critiquing a system in which some judges describe themselves as “U.S. imitation judges.” This Article examines the lack of truly independent immigration judges (IJs) through the lens of the Fourth Amendment, which applies when a noncitizen is arrested for deportation. In 1975, the Supreme Court held in Gerstein v. Pugh that to continue detention after an initial arrest in the criminal context, the detached judgment of a neutral judge is necessary; a prosecutor’s finding of probable cause is insufficient to protect the important Fourth Amendment rights to be free from an unreasonable seizure. In contrast, in the immigration detention context, no such neutral judge has any role in the process. Every person who authorizes a noncitizen’s arrest and detention works for a law enforcement agency.This Article builds off of prior scholarship examining the Fourth Amendment’s application in the immigration context, introducing a further problem: immigration adjudicators’ lack of independence. In this Article, I propose that federal magistrate judges make such a probable cause finding in order to continue pretrial detention for deportation. This proposal resolves the Fourth Amendment violations that occur when the only supposedly “neutral” judge who authorizes the jailing of a human being is regularly critiqued as not so “neutral.” While others have effectively argued that the entire immigration adjudication system needs a judge who is untethered from a law enforcement agency, in this Article, I focus only on the initial decision to continue pretrial detention, as this is where, in the criminal pre-trial context, the Fourth Amendment’s probable cause hearing requirement attaches.

The Fourth Amendment Implications of "U.S. Imitation Judges"

A new wave of federal court litigation has required immigration judges to consider alternatives to immigration detention in bond hearings. Although alternatives to detention can take many forms, the most common is electronic monitoring. Immigration detainees and their advocates now find themselves asking to trade the physical walls of jail for virtual walls, begging for a different type of punishment and control. Electronic monitoring imposes pain, shame, arbitrary rules, and limitation of freedom on persons, causing many to experience it as punitive. Its use also facilitates replacing a regime of over-detention with one of over-supervision and becomes the means by which immigration enforcement authorities surveil immigrant communities. It has become a Faustian bargain—should a detainee remain in jail or request these virtual walls?

The Supreme Court’s immigration detention doctrine has set up this tradeoff by succumbing to the plenary power’s defenders who believe that noncitizens in removal proceedings have no right to freedom. Instead of outright freedom, the Court has offered release under restrictive supervision policies utilized by the immigration authorities. Supervision through electronic monitoring has come to reside doctrinally in the middle ground between absolute freedom and incarceration. Yet as we have learned from electronic monitoring’s use in the criminal legal system, this “middle ground” ceded too much ground. This Article explains, for the first time, how the Court’s immigration detention doctrine and perverse pull of the plenary power has carved out a doctrinal space where electronic monitoring now resides. The Article is also the first to expose a trend in the immigration context, in which the diminished rights that come with the status of a final order of removal have negatively impacted the rights of those who are pretrial. These trends indicate that electronic monitoring will likely continue, unchecked by the judiciary, in the immigration context. It is thus necessary for the executive branch to not repeat the mistakes of the criminal legal system by substituting virtual walls for real ones.

Immigration E-Carceration: A Faustian Bargain

This is a book review written by Professor Holper of a new book about immigration detention by Elliot Young, titled Forever Prisoners: How the United States Made the World’s Largest Immigration Detention System.

Book Review: Forever Prisoners: How the United States Made the World’s Largest Immigration Detention System

This Article examines the issue of gang evidence through the lens of the law’s use of presumptions and the corresponding burdens of proof at play in immigration proceedings. In immigration law, most of the burdens of proof fall on noncitizens. These burden allocations allow adjudicators to readily accept the harmful presumption contained in the gang evidence — that urban youth of color are criminals and likely to engage in violent crime associated with gangs. This Article seeks to explain how this racist assumption led to the creation of a gang database, and proposes an evidentiary presumption that the gang evidence is not reliable, in order to specifically instruct the judge to reject the presumption society has put in place about urban youth of color and criminality. In this way, this Article tracks common interests of critical race theory, by explaining how U.S. society has subordinated people of color in the creation of gang databases, and seeking to not only understand, but change this bond between law and racial power.

Part I explains the justifications for why gang databases exist, using the creation of Boston’s Gang Database as an example. Following the lead of critical race theorists, this Part asks whether there is a counter-account of the social reality in Boston that led to the creation of this database. This Part then discusses various forces that gave rise to its creation: the segregation and concentration of poor people of color in certain neighborhoods; the diminishing social services in these neighborhoods, which gave rise to the police acting as the primary social workers, all the while surveilling young men of color; the extraordinary powers granted to the police to surveil and control these young men; and the labeling of a dangerous minority whom the government can eradicate through detention and deportation. Part I also explains how local anti-gang efforts became part of a national immigration enforcement agenda. Part II discusses burdens of proof in the law and how the burdens operate in immigration cases to validate harmful presumptions that a young man of color is a gang member. Part III proposes the creation of an evidentiary burden that gang evidence is unreliable in immigration cases and explains how that burden can counteract the harmful presumptions contained in the gang evidence.

Gang Accusations: The Beast That Burdens Noncitizens

There is a dire need for bail reform in the immigration detention system. Scholars have suggested a variety of recommendations to improve the manner in which immigration detention decisions are made. All of these recommendations have rested on the assumption that there is a finite pool of decisionmakers: Immigration and Customs Enforcement, the immigration judge, and, in certain cases, a federal district court judge deciding detention issues in habeas corpus proceedings. In this article, the author proposes the introduction of a new decisionmaker in the immigration detention system: the criminal court judge. This proposal is a JRAD redux—instead of a judicial recommendation against deportation (“JRAD”), as previously existed in immigration law, it is a judicial recommendation against immigration detention (“JRAID”). To provide a normative defense of this proposal, the article builds off of literature examining immigration detention as punishment, procedural justice, and the relationship between states and the federal government in immigration enforcement.

JRAD Redux: Judicial Recommendation Against Immigration Detention

A panel discussion related to the exploitation of immigrants, types of potential fraud, scams, and financial threats of immigrants, and resources for lawyers and social workers.
Panelists include:
<ul>
<li>Robin E. Eichen, Senior General Attorney at the Federal Trade Commission in New York, New York</li>
<li>Westy Egmont, Associate Professor of Macro Practice, Global Practice and Director of the Immigrant Integration Lab, School of Social Work</li>
<li>Mary Holper, Associate Clinical Professor and Director of the Immigration Clinic at Boston College Law School</li>
<li>Daniel Kanstroom, Professor of Law, Director of the International Human Rights Program, and Associate Director of the Boston College Center for Human Rights and International Justice</li>
<li>Timothy Depin, Constituent Services Coordinator, Community Engagement Division, Office of Attorney General, Boston, MA.</li>
</ul>
Sponsored by BC Law School Immigration Clinic, School of Social Work Immigrant Integration Lab, and the MA Attorney General's office.

Boston College Law School Webcast Archive

Immigration Exploitation

Panel Three: Academic Approaches Moderator: Mary Holper, Professor, Boston College Law School Panelists: Ingrid Eagly, Professor, University of California, Los Angeles, School of Law Stephen Legomsky, Professor, Washington University Law Alicia Schmidt Camacho, Professor, Yale University
Concluding Remarks: Dan Kanstroom, Professor, Boston College Law School

Mary Holper

Works