Biden's "Parole in Place" Plan to Keep Families Together: Read the Fine Print!

A sincere humanitarian effort to keep families together or a politically motivated wolf in sheep's clothing?

President Joe Biden, State of the Union, March 7, 2024. Photo credit: Shawn Thew, Getty Images.

To determine whether President Biden’s July 11 Order is a sincere humanitarian effort to keep families together or a politically motivated wolf in sheep’s clothing, it is helpful to have a basic understanding of immigration issues and proposals beginning with the Bill Clinton administration in the 1990s. The bill has a context; it did not come out of nowhere. Because Biden is a Democrat, it is also important to understand that he is part of a long line of Democrats whose words and actions have been just as anti-immigrant as those of Republicans.

Part 1: BACKGROUND

Bill Clinton (1993-2001): NAFTA

In 1993, the United States, Canada, and Mexico created a trade bloc. U. S. President Bill Clinton, Canadian Prime Minister Brian Mulroney, and Mexico’s President Carlos Salinas signed an agreement known as the North American Free Trade Agreement [NAFTA]. It allowed products and capital to flow freely across borders. For designated products in the agricultural, automotive, and communications sectors, “freely” meant that tariffs were lifted. Tariffs are protections (corporate taxes) that protect small farmers and small producers from unfair competition by big producers.

Clinton: Article 27 of the Mexican Constitution

As a condition for being able to enter into NAFTA, Mexico was required to repeal Article 27 of the 1917 Mexican constitution which had codified land reform, a major goal of the Mexican Revolution. Article 27 was a provision which allowed indigenous farmers primarily in the southern parts of Mexico to stay on their lands. These lands, and the water underneath and around them, called ejidos, had been held in common, that is without private titles to land.

Having repealed Article 27, the ejiditarios, the indigenous owners of the ejidos who were small producers of corn and beans, were put into direct competition with heavily subsidized companies such as the U. S.’s Archer Daniels Midland [ADM]. It was no surprise to the signers of NAFTA nor to the ejiditarios that they would not be able to compete. Undersold in products central to their economy and their culture, they were forced to sell off their ejidos to corporations interested in their land, its aquifers, and all its water rights. So unsurprised were they, that on the day NAFTA was signed, January 1, 1994, the Zapatista Army of National Liberation or Zapatistas [EZLN], consisting of around 3,000 armed, mostly Mayan indigenous insurgents seized six towns and cities in the southern state of Chiapas. They had more or less declared war on the Mexican government, centering on what they had concluded was its illegitimate signing of NAFTA.

Nor was it any surprise that in a short period of time millions of indigenous farmers and other small producers and vendors lost their lands and their livelihoods. It produced Mexico’s first billionaires including Carlos Slim; the displacement of millions of poor people and the creation of billionaires were dependent on each other.

Having no real options, small farmers and producers were forced into migrating north. The U. S. made it illegal for them to cross. In order to be able to cross into the U. S. legally with a visa of their own, they had to demonstrate they had “strong ties” to Mexico which the U. S. defined in part as having title to land which, of course, the displaced ejiditarios and many others could not produce.

Clinton: Border Militarization

Concurrent with the repeal of Article 27 of the Mexican Constitution and Bill Clintons’s signing of NAFTA, anticipating the millions of indigenous and others affected by the implementation of NAFTA, Clinton and his Immigration and Naturalization Services commissioner, Doris Meissner, began to militarize the U. S./Mexico border, a process which continued throughout the Clinton, Bush, Obama, Trump, and Biden administrations. In succession, Operations Hold the Line and Gatekeeper, the Secure Fence Act and other programs specified the militarization of our southern border.

Up went the “esthetically pleasing” Bollard walls and other barriers, infra-red cameras, and stadium lights. The numbers of Border Patrol personnel, vehicles, dogs, and horses multiplied. Interior checkpoints were established. Under Meissner alone, Border Patrol’s workforce expanded from 3,226 in 1990 to 32,000 employees, and its annual budget tripled from 262.65 million U.S. dollars for the 1990 fiscal year to $4.3 billion.1

Clinton: Prevention Through Deterrence

The policy which gained next to no media or advocate attention was the policy of “prevention through deterrence” spelled out in the Border Patrol Strategic Plan of 1994 and Beyond.2 Meissner proposed it; Clinton signed it. The word “deterrence” was a euphemism for “death.” Walls, surveillance aparatus, and Border Patrol agents were to close off the relatively safe urban crossing areas in Arizona and funnel migrants into the vast and deadly Sonoran Desert. The shadeless summer heat and freezing winters would take it from there. The plan was that a few migrants would die, word would get back to sending communities as to the tremendous hazards, and crossings would stop. The plan was a failure. To date, the remains of some 8,000 migrants have been recovered from Arizona alone. People who watch the border and regularly talk with undocumented people put the actual figure at around 27,000.

Clinton: Illegal Immigration and Immigrant Responsibility Act

Clinton also made it harder for families of undocumented migrants to stay together. In 1996, Congress authorized his Illegal Immigration Reform and Immigrant Responsibility Act of 1996 [IIRAIRA]. It imposed 3 and 10 year “bars” requiring living outside the United States before a spouse who had been deported could even apply for legal admission. Today, thousands of U. S. citizen spouses and children live in exile in Mexico, Central America, and South America with no way to return to their families here because of their adopted home countries’ stiff exit fees and other reasons.

George W. Bush (2001-2009)

This article focuses on the legacy, including the policies and ideologies, that the Democratic Party passed on to Joe Biden. Yet, I do want to mention the innovations of the George W. Bush and Donald Trump administrations.

Bush: Post 9/11 Branding of Undocumented People as Potential Terrorists

The pilots who carried out the nightmare of September 11, 2001 were Saudi Arabians who entered U. S. airspace with visas, i.e. legally. Under Clinton and Meissner, the numbers of Border Patrol agents and funding were already expanding dramatically. The horror of the attacks on the Twin Towers and the Pentagon and the hi-jacking of United Airlines Flight 93 provided the rationale Bush needed to brand those who come illegally, i.e. without visas, as potential terrorists. Even though his analysis was badly flawed, 9/11 provided him with the opportunity for even more agents and funding and for upping the ideological ante.

Bush: Creation of the Department of Homeland Security

In 2003, Bush debuted the Department of Homeland Security, one of the most significant reorganizations of the federal government since the end of the Cold War. Over time, with ever increasing funding, it became one of the largest law enforcement agencies in the country.

Bush: Operation Streamline

In Tucson (2005), Operation Streamline undercut basic legal rights of undocumented people, shackling them, parading them to a bench trial that they could not understand, and convicting 70 at a time. Deportation followed swiftly.

Bush: The Secure Fence Act of 2006.

Bush’s contribution to the militarization of the U. S./Mexico border was the Secure Fence Act of 2006. One of the notable events towards that end was that in 2008 his Secretary of Homeland Security, Michael Certoff, waived in their entirety dozens of protections for Native American graves and religious sites, migratory birds and other wildlife, air and water, and hundreds of protections for the land itself in order to install 700 miles of wall.

Barack Obama (2009-2017): the Deporter in Chief

Barack Obama’s presidential administration followed those of Bill Clinton and George W. Bush. Obama characterized unauthorized border crossers as those who “don’t play by the rules” knowing full-well there were no rules for them to play by that would allow them to come legally. He earned the nickname “Deporter in Chief” because under him deportations sky-rocketed. His administration honored contracts with private prisons to keep 34,000 undocumented people in beds each and every day. He honored the quota of 400,000 deportations per year which added up to 2.8 million families broken up over the course of his two administrations.

Obama: Mental, Physical, and Sexual Abuse of Asylum-Seeking Children

During his two terms, Obama approved toddlers representing themselves in immigration court, tried to classify detention centers for children as “day-care” facilities, and authorized returning unaccompanied asylum-seeking children to gangs in Central America. He had supported the illegal coup d’etat of Manuel Zelaya in Honduras (2009) which was in part responsible for setting up the conditions from which Honduran children were fleeing in the first place. Because of Obama’s deportation of their mothers and fathers, some 5,000 children were left behind and placed in foster care even though they had parents who loved them.

By way of a successful Freedom of Information [FOIA] law suit, the American Civil Liberties Union [ACLU]acquired 30,000 pages of documents detailing Border Patrol’s horrific sexual, mental, and physical abuses of asylum-seeking children in its custody during Obama’s first term as president (2009-2012).3 Here are a few highlights from the complaints, as obtained by the ACLU:

A 16-year-old child recounted that a Border Patrol agent threw him down and smashed his head into the ground with his boot. The child also reported that as the same agent walked him to aBorder Patrol vehicle, he told the child that he would “fuck [him] up” if he tried to run away.

In another instance, Border Patrol agents apprehended a 13-year-old child in shallow ocean water near Imperial Beach, California. The government report excerpted below states that the child “was evading apprehension,” although no details or justification for this determination are provided. A Border Patrol agent grabbed the child by the back of the neck and kicked him in the shins, causing the boy to fall. The agent then pulled the child back up to a standing position and kicked him again, knocking him to the ground a second time. Thereafter, the agent shoved the child into the back of a patrol vehicle.

A Border Patrol agent tightly handcuffed a child’s wrists and ignored the child’s pleas to loosen the cuffs, instead tightening them further. While the child was restrained, the agent also continually pushed the child’s shoulder into the ground, causing bleeding.

A child reported that Border Patrol agents awoke a group of migrants sleeping in the Arizona desert by yelling at and kicking them. The agents then restrained the child’s hands so tightly that his circulation was cut off; the child’s pleas for the restraints to be loosened were ignored.

Another complaint documented a child who was “run over by a CBP truck,” which resulted in “crushing damage” and “significant trauma” to the child’s leg. The complaint also indicated “that CBP did not take proper care of [the child’s] injury.” Later, doctors diagnosed the child “with a broken right leg.”

Physical abuse at apprehension sometimes involved sexual abuse. One agent grabbed a child’s buttocks when he was alone with her after arresting her in the Phoenix, Arizona desert. The abuse only stopped when she screamed, attracting another agent to the area.

CBP officials abused a 16-year-old girl upon apprehension. The girl reported that, after mocking her by asking her why “she did not ask the Mexicans for help,” the officials subjected her to a search in which they “forcefully spread her legs and touched her private parts so hard that she screamed.

These are only a few of the complaints. Again, the ACLU obtained 30,000 pages of complaints.

Obama: Deferred Action for Childhood Arrivals

Obama sought to dispel his well-earned image as the “deporter in chief” by issuing the "Deferred Action for Childhood Arrivals” [DACA] memorandum (2012). DACA was widely touted by immigrant advocacy groups and mainstream media as “protection from deportation” for those who qualified. It offered some, but not all, immigrants who had been brought to the U. S. as children the ability to apply for a two-year postponement on deportation. They had to have been younger than 31 on June 15, 2012, must have come to the U.S. when they were younger than 16, and must have lived in the U.S. since 2007.

Immigration advocates relentlessly pressured undocumented childhood arrivals to apply for the deferment. They seldom stressed to their undocumented “friends” that in order to apply for the deferment, they had to turn themselves and their families in to the very department oriented to deportation, the Department of Homeland Security, which issued the memorandum. One reason is that they had not actually read the memo and did not understand it themselves.

An applicant had to provide biometrics (finger prints) and address to DHS, necessarily informing DHS that their parents and siblings were unauthorized. Some were 16 years old, incapable of consenting to such a high stakes gamble with such a short term, limited payoff. Others had parents unable to advise them as they spoke limited English, others spoke indigenous languages and, even with Spanish speaking interpreters, could not fully comprehend what was being said and did not have a good grasp of the U. S. system. They trusted their advocate advisors.

It never offered what many thought they were getting—a legal status, a pathway to citizenship, automatic granting of the deferment upon application, and certain protection from deportation.

Buried in the DHS memo issued by the Secretary of Homeland Security, Janet Napolitano, was the caveat that DHS could turn over to ICE information supplied by applicants. It said, “DHS will not use information about a requestor in a request for DACA to initiate immigration enforcement proceedings against that requestor, UNLESS (emphasis added by me) DHS is initiating immigration enforcement proceedings due to a criminal offense (criminal offenses include misdemeanors as well as felonies), fraud, a threat to national security, or public safety concerns. That “dacamented” migrants could be deported never occurred to far too many advocates and far too many undocumented applicants and they didn’t do the research they should have done in order to find out.

Some ‘dacamented’ themselves later regretted having thrown themselves, their own parents, and their siblings under the bus.

Obama: Comprehensive Immigration Reform, S. 744

The Border Security, Economic Opportunity, and Immigration Modernization Act, S. 744, was generally known as Comprehensive Immigration Reform (2013). Like DACA, it was touted far and wide among immigrants’ advocates as being a humanitarian step forward. It was not. It was anything but a humanitarian effort.

It was a deal. An exchange. It provided for the full militarization of the entire U. S. southern border. That necessarily meant more tax-payer funding, and specified certain corporate beneficiaries of contracts including Black Hawk’s helicopters. More militarization equated to more migrant deaths. There is no way around that. The package also called for major extensions of the H2 guest worker visa. The guest worker program was a federally-sponsored program of indentured servitude, tying workers to their employers making them extremely vulnerable to abuse.

The promised exchange was a “path to citizenship.” But the trigger that would activate this path was the full militarization of the U. S. southern border. That date was impossible to anticipate—by what measure would the border ever be considered fully militarized? I suspect that never would have happened. Meanwhile, even if undocumented persons ever managed to get on the path, the application was so riddled with fees and exceptions one could fall off it at any time. By applying, he or she would already have turned themselves in to the Department of Homeland Security which had those bed and deportation quotas to meet.

The Bill did not take into account that citizenship is not the maximum that many people needed anyway. The grandfather in the Sonora Desert, the child about to cross the Rio Grande on her father's back, the mother attempting to navigate the Pacific Ocean didn’t need a path to citizenship. They simply needed a way to cross our border legally without incurring massive expenses, risking their families entire fortunes, and courting death.

The horrendous package was touted by such mainstream liberal pundits as Rachel Maddow and major liberal advocacy groups including America’s Voice. Either they and other supporters had never bothered to read the language or they simply didn’t care that they were promoting death, servitude, and human trafficking.

Donald J. Trump (2016-2020)

Trump undertook few innovations in immigration policy. A major factor in the public’s perception of Trump and his immigration policies as “cruel for the sake of cruelty” and a novelty in U. S. politics was an explosion of media attention. It had been either silent or terribly subdued in its treatment of Clinton and Obama. One stand-out example is the caging of children and separation of children from parents which Obama had employed on a grand scale.

The major Trump innovations were the so-called “Muslim Ban,” the Migrant Protection Protocols, generally known as the "Remain in Mexico" program, and the Title 42 public health restriction.

Trump: Muslim Ban (2017)

In January, Trump issued an Executive Order (Executive Orders have the force of law) indefinitely banning Syrian refugees and banning asylum seekers and refugees from Syria and 6 other predominantly Muslim countries for 90 days. Those countries were, in addition to Syria, Iran, Iraq, Libya, Somalia, Sudan, and Yemen.⁴

Trump: Migrant Protection Protocols (2019)

Known generaly as “Remain in Mexico,” the policy upended the policy that allowed asylum seekers to do so after crossing the border and from anywhere in the U. S. The new policy required migrants seeking asylum to remain in Mexico until their U. S. immigration court date. Human rights organizations criticized the policy for exposing migrants to attacks while they waited indefinitely in Mexico. By December 2019, some 57,000 asylum seekers had been returned to Mexico.

Trump: Title 42 (2020)

Title 42 capitalized on fear surrounding the Covid 19 epidemic. It allowed Border Patrol officers to expel those deemed likely to be able to spread communicable diseases.

Part 2: Joseph Biden (2020-2024)

Biden: Suspension and Limitation on Asylum Seekers (June 4, 2024)

On June 4 of this year, via a Presidential Proclamation, the Department of Homeland Security and the Department of Justice jointly issued a drastic suspension of the ability of unauthorized border crossers to apply for asylum. It was part of the Biden administration’s effort to lock out asylum seekers at the southern border of the U. S. from the Pacific to the Atlantic Oceans. Among other things, it made unauthorized border crossers ineligible for asylum and increased the “credible fear” screening standard for claims under the Convention Against Torture. According to the National Immigration Justice Center, the changes “will result in the deportation of thousands of people seeking safety.”⁵

Biden: Parole in Place Order (June 17, 2024)

1. There are reasons to be suspicious or, at the very least, cautious about the present “parole in place” order. The first reason is the history of Democrats, including Biden, in immigration matters. Second, a lot hinges on what the language of the order means—what it means technically and legally.

The purpose of this article is to urge extreme caution before applying for parole in place. Read the Order carefully and consult an immigration attorney.

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2. What, exactly, is an “executive order”?

The American Bar Association breaks it down. An “executive order is a signed, written, and published directive from the President of the United States . . . and is published in the Federal Register.” More important to understand is that executive orders are not legislation. Congress can make it difficult to enforce the order, but it cannot just overturn it.

The practical question, then, is: who CAN reverse an executive order? The answer: the next sitting president. With a presidential election scheduled for this coming November and with the reality that the next president could be Donald Trump or an unfriendly Democrat again, caution is well-warranted.⁶

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3. What does this particular order provide?

It changes the requirement that a non-citizen spouse of a U.S. citizen must leave the country for an unspecified and indefinite period of time in order to apply for lawful permanent residence. Instead, the application may be filed while the undocumented spouse remains in the U.S. with his/her family.⁷

It provides for judicial discretion in deciding whether the applicant will be granted “parole in place” on a case by case basis. Parole in place [PIP] means that the applicant may stay in the U.S. during the application process. Judicial discretion means that the immigration judge may rule in favor of the applicant or he/she may rule against the applicant. There are immigration judges who have a humanitarian orientation. There are others who are notorious for not having a humanitarian bone in their body. Since the applicant has already turned himself/herself in to the Department of Homeland Security [DHS], having admitted he/she entered the U.S. illegally, DHS, i.e. the department oriented to deportation, by applying he/she has made him/herself available for deportation.

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4. To whom does the order apply? Does it apply to all undocumented spouses/children?

This is where it gets sticky. The short answer is “no.”

a. According to the Department of Homeland Security’s fact sheet on the order, it applies to “certain” undocumented spouses of U.S. citizens. Watch out for that word “certain.” It applies to “nationals of Colombia, El Salvador, Guatemala, Honduras, and Ecuador” and for “certain” nationals of Cuba, Haiti, Nicaragua, and Venezuela (CHNV) who have a “U.S.-based supporter.”

Read that again: there is no mention of Mexican nationals or Paraguayan nationals or Scottish nationals or Chinese nationals or Sudanese nationals.

b. To be considered, the applicant must have been “present in the United States without admission or parole.” What does “without admission or parole” mean? Does it mean that an agricultural worker, e.g., who entered legally with a H2A visa, but overstayed his/her visa and is now undocumented was “admitted” for immigration purposes? I would be leery of thinking that it did. What about for one who has already has been granted “parole in place?” The language seems clearly to stipulate that he/she would not be eligible.

c.The applicant must have been “continuously present in the United States for at least 10 years as of June 17, 2024.” What does “continuously” mean? “Continuously” is not the same thing as “continually.” Continuously means, according to Black’s Law Dictionary, “uninterrupted, unbroken, not intermittent or occasional.”⁸ So, for example, it would seem to me that an H2B non-agricultural worker from Guatemala who came legally on a visa on June 17, 2014, had a child here in 2015, went home to Guatemala, returned on a new H2B visa in 2016 would not be eligible because she would have not been here “continuously” in the legal sense.

d.The applicant must have had a legally valid marriage to a U.S. citizen as of June 17, 2024. What is a “legally valid” marriage? According to Cornell Law School, a legally valid marriage must have certain basic elements: the parties had the legal ability to marry each other, mutual consent of the parties, and a marriage contract.⁹

In most instances, the individual states determine what constitutes a legal marriage. For example, one state might put the age of consent at 16 years old while another puts it at 18. Suppose, though, a girl from Nicaragua was 14 when she consented to marry a U.S. citizen? Would that constitute a legally valid marriage for “parole in place” purposes?

Or, suppose that prior to the 2015 Obergefell v. Hodges U.S. Supreme Court decision that the states could not deny marriage to gay couples, a gay Salvadoran man entered into a long-term “common law” marriage with a gay U.S. citizen who was ex-military? The couple then decided, in 2015, that they would get married formally in order to protect military protections for spouses? Would that be a legally valid marriage for our purposes?

Or, suppose that the couple were in Alabama where until 2019 it was required that there be an officiant recognized by a religious institution which kept minutes and a marriage certificate signed by a judge but the couple did not know these things and had an unauthorized officiant not recognized by the State of Alabama? Would the immigration judge rule “yay” or “nay” on whether this couple was in a legally valid marriage?

Or, suppose that a man from Venezuela married a U.S. citizen woman in June, 2014, but legally separated in 2016, then resumed their marriage in 2018, would they have been legally married for PIP purposes?

e. The applicant “must have no disqualifying criminal history.” Justicia US Law, a free resource for legal information, warns that whether your crime was in the U.S. or abroad, your criminal record can result in your deportation. This applies to those who “already have a valid non-immigrant visa or even a green card.” What does this mean exactly? Since the Order does not spell it out, we seem to be left to assume what “disqualifying” crimes might be. I have an undocumented friend who had served in the U.S. Army as a parachuter who accidentally discharged a firearm in a vehicle which led to his deportation and separation from his wife and daughter. What, exactly, are we talking about?

f. The applicant must not “constitute a threat to national security or public safety.”

This is the slipperiest of all issues which an applicant could face, especially when we keep in mind that the rationale for the establishment of the Department of Homeland Security was a presumption that undocumented people might be terrorists in the days following the September 11, 2001 Saudi Arabian attacks on New York City’s Twin Towers and the Pentagon. That was not the reality; it was a presumption for marketing purposes.

Beyond that, back on February 7, 2022, during Biden’s second year as president, his Department of Homeland Security issued a memo subsuming those who disseminate misinformation, disinformation, or malinformation into what it called a terrorist threat.¹⁰ It defined the terms like this:

Misinformation is false, but not created or shared with the intention of causing harm.

Disinformation is deliberately created to mislead, harm, or manipulate a person, social group, organization, or country.

Malinformation is based on fact, but used out of context to mislead, harm, or manipulate.

In particular, it implicated those who caused people to question the U.S. government because of its response to Covid-19 as part of that terrorist threat.

In other words, if you called into question the Covid-19 vaccines or use of masking, you potentially could be assigned the label of a “threat to public safety.” If you opposed the NATO/U.S. conflict with Russia over Ukraine or challenged the U.S. government’s support of the Israeli genocide in Gaza, you potentially could be labeled, for PIP purposes, part of a terrorist threat.

To be sure, the period of the memo itself expired on June 20, 2022. However, the ideology behind it continues.

Again, PLEASE, consult an attorney if you are considering applying for PIP. Not just any attorney, you will need to consult one with experience in immigration law. And READ THE ORDER with a suspicious eye. Once you turn yourself in to DHS, you cannot un-turn yourself in.

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1

“Border Patrol Agents: Southern Versus Northern Border,” Syracuse University, Transactional Records Access Clearinghouse [TRAC], Graphical Highlights, Immigration. https://trac.syr.edu/immigration/reports/143/include/rep143table2.html;

Statista Research Department, U. S. Enacted Border Patrol Program Budget 1990-2024, July 5, 2024. https://www.statista.com/aboutus/our-research-commitment.

2

“Border Patrol Strategic Plan 1994 and Beyond,” Homeland Security Digital Library. https://www.hsdl.org/c/view?docid=721845.

3

“Neglect and Abuse of Unaccompanied Immigrant Children by U. S. Customs and Border Protection,” American Civil Liberties Union, May, 2018. https://www.dropbox.com/scl/fi/2dd5s4tijfvynjbuvgyra/CBP-Report-ACLU_IHRC-5.23-FINAL.pdf?rlkey=hrq11o7n1n7i8w96kavkmpn2h&e=1&dl=0.

4

“A License to Discriminate: Trump’s Muslim and Refugee Ban,” Amnesty International UK, October 6, 2020. https://www.amnesty.org.uk/licence-discriminate-trumps-muslim-refugee-ban.

5

Staff, “New Biden Executive Action Further Eviscerates The Right To Seek Asylum: Frequently Asked Questions About The Latest Anti-Immigrant Policy,” National Immigrant Justice Center, June 5, 2024. https://immigrantjustice.org/staff/blog/new-biden-executive-action-further-eviscerates-right-seek-asylum-frequently-asked.

6

“Teaching Legal Docs: What is an Executive Order?”, American Bar Association, January 25, 2021. https://www.americanbar.org/groups/public_education/publications/teaching-legal-docs/what-is-an-executive-order.

7

“Fact Sheet: President Biden Announces New Actions to Keep Families Together,” Department of Homeland Security, June 18, 2024. https://www.whitehouse.gov/briefing-room/statements-releases/2024/06/18/fact-sheet-president-biden-announces-new-actions-to-keep-families-together/#:~:text=Keeping%20American%20Families%20Together&text=This%20new%20process%20will%20help,for%20%E2%80%93%20without%20leaving%20the%20country.

8

“Continuous: Definition and Legal Meaning,” Black’s Law Dictionary. Onlinehttps://thelawdictionary.org/continuous/#:~:text=CONTINUOUS%20Definition%20%26%20Legal%20Meaning&text=Uninterrupted%3B%20unbroken%3B%20not%20intermittent%20or,Black%20v.

9

“Marriage,” Cornell Law School, Legal Information Institute.

10

“Summary of Terrorism Threat to the U.S. Homeland,” National Terrorism Advisory System, Department of Homeland Security, February 7, 2022. https://www.dhs.gov/ntas/advisory/national-terrorism-advisory-system-bulletin-february-07-2022.