The RAISE Act: Its Strengths and Weaknesses and Why I Ultimately Oppose

Introduction

On August 2, 2017, Republican Senators Tom Cotton of Arkansas and David Perdue of Georgia proposed legislation titled the “Reforming American Immigration for a Strong Economy Act (“RAISE Act”). The RAISE Act contains provisions for reforming the employment immigration system, eliminating Diversity Visas, and eliminating family-based preferences for extended family and adult relatives. On the same day that it was proposed, the legislation was endorsed by President Donald Trump.

In this post, I will examine the proposed legislation in brief and explain that, while it has certain merits, the proposal is ultimately deeply flawed such that it stands little to no chance of becoming law. Simply put, it should not become law in its current form. Rather, I will explain why the proposal should constitute the beginning — rather than the conclusion — of efforts to reform the immigrant visa system.

For your reference, please see the following resources on the legislation, courtesy of the Senate website of Senator Cotton:

• Full text of the legislation [PDF version];
• News Release [PDF version];
• Section-By-Section Summary [PDF version]; and
• Fact Sheet [PDF version].

Overview of the RAISE Act

The RAISE Act focuses on immigrant visas and refugee admissions. Accordingly, nothing in the proposal would affect the nonimmigrant visa categories, including those that are work-based. We will tackle each of the major points of the proposal in turn. Please note that this is a general overview of the main points and not intended to be comprehensive.

1. Establish Skills-Based System for Employment-Based Visas

Our current employment-based immigrant visa system includes five preferences [see section on employment immigration and see section on investment immigration]. In general, this allows employers to petition for a foreign national under the rules of one of the preferences. In certain categories and preferences, self-petitioning by the foreign national is permitted and no job offer is required.

Under the new system, hopefuls for employment-based immigrant visas would be evaluated on the following six factors:

• Education;
• English-language ability;
• High-paying job offers;
• Age;
• Record of extraordinary achievement; and
• Entrepreneurial initiative.

A certain number of points would be allocated based on the age of the applicant.

In order to qualify for an immigrant visa, an applicant would need to accrue at least 30 points under the system. The number of employment-based immigrant visas, including derivative spouses and children (“children” defined as being under the age of 18), would be capped at 140,000 annually. The proposal accounts for the fact that there would likely be more individuals meeting the 30 point threshold, along with derivatives, than available employment-based visas in a given year. Accordingly, the proposal would provide for a variety of tiebreakers among individuals with the same number of points.

From the pool of qualified applicants, the United States Citizenship and Immigration Services (USCIS) would invite a certain number within the cap to seek employment-based visas. This would occur twice each fiscal year, with enough applicants to assume half of the 140,000 employment-based immigrant visas being invited each time. Invited applicants would be permitted to submit applications and undergo security vetting.

The RAISE Act would provide a nonimmigrant option for dependent adult sons and daughters of employment-based visa beneficiaries. However, the nonimmigrant adult would not be able to work in the United States, avail him or herself to employment authorization, or remain if he or she became able to care for him or herself. It would also allocate a small number of points to certain individuals who were prevented from procuring a family-based visa under the new rules, but who decide to seek an employment-based visa instead.

2. Curtail Family-Based Immigration

The RAISE Act would restrict family-based immigration to immediate relatives (spouse and unmarried children) of U.S. citizens and spouses and unmarried children of lawful permanent residents. The FB-1, FB-2B, FB-3 and FB-4 extended family preferences would be eliminated. The definition of “child” would be changed from under the age of 21 to under the age of 18. Family-based immigration would be capped at 88,000 admissions each fiscal year.

Individuals with outstanding approved petitions in eliminated preference categories would be permitted to obtain a visa if he or she is scheduled to receive a visa no more than one year after the enactment of the RAISE Act, or if he or she entered the United States within one year of the date of the enactment.

The RAISE Act would create a special nonimmigrant classification for parents of adult U.S. citizens. This would be the “W” nonimmigrant category. A W visa would be authorized for an initial period of five years, with the option of five year extensions (no limit on number of extensions). W nonimmigrants would be ineligible from accepting means-tested public benefits and ineligible for employment authorization. The U.S. citizen son or daughter would be responsible for the financial upkeep of the W nonimmigrant parent, including provision of health insurance.

The RAISE Act would make necessary conforming amendments to the V nonimmigrant category.

3. Eliminate the Diversity Visa Category

The RAISE Act would abolish the Diversity Visa category, which allocates 50,000 immigrant visas annually to individuals from countries with low levels of immigration to the United States.

4. Refugee Cap

The RAISE Act would cap the number of refugees that could be admitted in each fiscal year at 50,000.

5. Naturalization and Public Charge

The RAISE act would require the sponsor of an immigrant applying for naturalization to reimburse the government for any means-tested public benefits used by the immigrant within five years of his or her obtaining lawful permanent resident status before the immigrant would be eligible for naturalization.

Support and Opposition

The most important and notable supporter of the RAISE Act proposal is President Trump himself. Although the RAISE Act stands little to no chance of becoming law in its current form, it goes without saying that the President's support for any piece of legislation is significant. Unsurprisingly, the proposal also drew support from Attorney General Jeff Sessions, who was an ally of Senator Cotton and a supporter of lower levels of immigration during his twenty-year tenure in the U.S. Senate [PDF version]. Interestingly, Senator Marco Rubio of Florida, who has generally supported higher immigration levels, expressed conditional support for the effort without outright endorsing the proposal.[1] Commentators who generally support immigration reform that would lower immigration levels such as Mark Kirkorian of the Center for immigration Studies have expressed support for the general aims of the proposal, if not every aspect.[2]

The proposal has received nearly unanimous opposition from the Democratic Party and Democratic officials. Liberal groups have been similarly opposed. This includes the American Immigration Lawyers Association (AILA), which generally opposes these types of polices. The President of AILA, Annaluisa Padilla, took the position that the proposal “repudiates our national ethos, which recognizes the value of keeping families together to create a stronger nation.”[3]

Perhaps more ominous for its prospects, however, is the opposition from Republicans. The legislation was opposed, for example, by Senators Lindsey Graham of South Carolina and Jeff Flake of Arizona, two Republican members of the ill-fated “Gang of Eight” reform effort from 2013 (along with Rubio and Senator John McCain).[4]

My Thoughts on the Proposal

Overall, I do not support the RAISE Act in its current form due to its myriad flaws. Fortunately, its flaws will prevent it from being seriously considered by Congress. However, if there is will on both sides, perhaps an unlikely prospect, there are solid points of the proposal which could eventually form the basis of a more positive immigration proposal.

Where I Agree

In the interest of positivity, let us look at a few of the good points of the proposal.

Firstly, I agree with a merit-based system for employment immigration in general [see blog]. While I have numerous issues with the version proposed in the RAISE Act, it is worth noting that this should be a starting point for reforming our employment immigration system.

Secondly, I agree with the elimination of the family-based fourth preference category for siblings of U.S. citizens. I broadly support emphasizing the immigration of immediate relatives and the spouses and children of permanent residents. Our current immigration system has too many visas consumed by chain migration. There is undoubtedly room for compromise on how far this should go, if at all, beyond eliminating the family-based fourth preference category.

Thirdly, I agree with the RAISE Act's abolition of the Diversity Visa program. While other immigrant visas are accorded based on factors such as family relationships, employment, investment, humanitarian grounds, or to certain victims of violence, the Diversity Visa program is based on primarily being from a country with low levels of immigration. While I know for a fact that many wonderful individuals have become immigrants through the Diversity Visa program, the premise of the program is simply no basis upon which to award immigrant visas. Some, such as AILA, argue that the program accords with an interest in “recogniz[ing] the value of diversity.”[5] However, I would argue that no discernable U.S. interest is served by admitting individuals from countries based on little more than their country of origin. Outside of the family immigration context and certain special programs, the interests of the United States are served by admitting individuals based on merit, which does not include being from a country from which few people apply or can qualify. If anything, it is unfair to countless highly skilled immigrant visa hopefuls with job offers, or family members who have followed the rules through a years' long process, that 50,000 immigrant visas are issued based on national origin.

Finally, I agree generally with capping refugee admissions. More broadly, I support the efforts of the current administration to perform a wholesale reevaluation of the United States Refugee Admissions Program (USRAP).

Where I Disagree

Here, I will examine some of my most prominent issues with the proposal. Please note that my not that omission does not necessarily mean agreement. Neither my list of disagreements nor my list of agreements is intended to be exhaustive.

My first point of disagreement with the proposal is the severe reduction in overall immigration levels. This is where my approach would diverge from the approach taken by Senators Cotton and Perdue. We agree that the immigration system should be tailored to benefit the national interest. However, we disagree on the effect of immigration. It is my position that skilled immigration benefits the U.S. economy, whereas Senators Cotton and Perdue, in addition to other proponents of lower levels of immigration such as Attorney General Jeff Sessions and White House Chief Political Strategist Steve Bannon, believe that the current level of immigration harms the U.S. economy rather than just the misguided emphasis of the immigration system. While I support the elimination of the Diversity Visa program and certain family-based preferences, it is my position that these visas should be, at the very least, reallocated to merit-based employment categories rather than eliminated altogether.

My second key point of disagreement is with the points system itself. The points system, as constructed in the RAISE Act, affords too much discretion to the USCIS. A more sound points system would set clear benchmarks in statute that are not subject to case-by-case discretion or extensive modification through regulations. Applicants should have a clear understanding, before applying, of whether they have the requisite qualifications to meet the points threshold. Furthermore, this would allow those who are interested in obtaining permanent resident status based on employment to determine where they need to fill in the gaps if their qualifications do not meet the threshold.

My third key disagreement is how it would handle those who meet the threshold. Meeting the points threshold would not necessarily permit an individual to apply for an immigrant visa. Rather, the individual would be placed in a pool and would only be permitted to apply for a visa if selected from the pool by the USCIS. This system is unnecessarily cumbersome and unresponsive to the needs of business. Meeting the points requirement should allow a business to begin the process of seeking to bring a prospective employee to the United States with permanent resident status. Beyond determining whether a foreign national meets the points requirement, the USCIS should not have a role in determining who can even apply for a visa.

For my fourth disagreement, I will note one point on which I agree with AILA. AILA criticized the RAISE Act for “unfairly eliminat[ing] key immigrant visa programs, such as the EB-5 immigrant investor program, the special immigrant religious workers program, and the physician national interest waiver green card program.”[6] Now, to be clear, I think that the employment-based immigrant visa categories should be addressed wholesale in any reform effort. However, I agree with the general point that our immigration system should be designed to target specific needs. Some needs could be addressed as carve-outs in a points-based system (such as physicians and investors), and others could be met through reforms separate from the points-based system (religious workers). I would hope to see this addressed in a better version of the legislation.

Fifth, it is important to consider that employers rely on both nonimmigrant and immigrant visas to meet their needs. It does not make sense to address only one without addressing the other. For example, changing how immigrant visas work in one area may suggest that a nonimmigrant visa category should be modified to ensure that the needs of employers are met. For future efforts to reform immigrant visa preferences, it is worth considering employment immigration generally in both nonimmigrant and immigrant contexts.

Finally, I do not think that a change to our immigrant visa system should punish those who have followed the rules and who have approved immigrant visas. For example, while I support eliminating the family-based fourth preference category for siblings of U.S. citizens, I do not support ending the process for those who have patiently waited for the opportunity to apply for a visa based on an approved petition. The RAISE Act would mean that many individuals who have waited to apply for a visa based on an approved petition for over a decade would suddenly be unable to obtain a visa. It is true that foreign nationals do not have a right to enter the United States; however, in the vast majority of cases, it would be patently unfair and represent bad policy to penalize those who have invested time and resources into long-pending applications by suddenly revoking their approved petitions.

Conclusion

The current iteration of the RAISE Act is flawed, but it should not represent the end of the process. Although I oppose legalization without first handling immigration enforcement in a concrete way [see blog], it is well-past time for us to modernize the employment immigration system. If addressed in both the nonimmigrant and immigrant contexts, reform could reduce the incentive to employ aliens illegally and ensure that the most qualified applicants are preferenced. Senators Cotton and Perdue, in addition to President Trump, have the right idea generally with the proposed merit-based system. Let us hope that Congress develops alternative proposals to address the flaws with that system in the RAISE Act in addition to other issues with the legislation.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

1. Daugherty, Alex. “Rubio still considering Trump-sponsored immigration plan introduced in February.” Bradenton Herald. Aug. 4, 2017. Bradenton.com
2. See e.g., Kirkorian, Mark. “Finally, a debate on Legal Immigration.” Center for Immigration Studies. Aug. 2, 2017. Cis.org.
3. AILA Doc. No. 17080370 (Aug. 3, 2017)
4. Daugherty, Alex. “Rubio still considering Trump-sponsored immigration plan introduced in February.” Bradenton Herald. Aug. 4, 2017. Bradenton.com
5. AILA Doc. No. 17080234 (Aug. 3, 2017)
6. Id.

Lawyer website: http://myattorneyusa.com

Full Resumption of H1B Premium Processing

On March 11, 2019, the United States Citizenship and Immigration Services (USCIS) resumed premium processing for all H1B petitions [PDF version]. Premium processing of certain H1B petitions had been suspended for extended periods over the past couple of years [see article].

The USCIS news release on the resumption of H1B premium processing includes the following chart on where to file a premium processing request for individuals whose H1B petitions were transferred [see here].

To learn about premium processing of Form I-129 petitions generally, please see our full article on the issue [see article].

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Department of Justice Conditions Participation in Public Safety Partnership Program on Immigration Enforcement Cooperation

On June 20, 2017, the United States Attorney General Jeff Sessions announced the creation of the “National Public Safety Partnership” [PDF version]. The National Public Safety Partnership was created in response to President Donald Trump's February 9, 2017 Executive Order 13776 titled “Task Force on Crime Reduction and Public Safety” [PDF version]. Localities may apply to participate in the National Public Safety Partnership. The Department of Justice (DOJ) will assist participating localities in reducing violent crime rates.

On August 3, 2017, the DOJ announced that, in order to be selected for participation in the National Public Safety Partnership program, “local jurisdictions must show a commitment to reducing crime stemming from illegal immigration” [PDF version]. To assess whether jurisdictions applying to participate in the program are sufficiently cooperative with Federal immigration enforcement, the DOJ will ask applicants the following questions (quoted from DOJ news release):

1. Does your jurisdiction have a statute, rule, regulation, policy, or practice that is designed to ensure that U.S. Department of Homeland Security (DHS) personnel have access to any correctional or detention facility in order to meet with an alien (or an individual believed to be an alien) and inquire as to his or her right to be or to remain in the United States?
2. Does your jurisdiction have a statute, rule, regulation, policy, or practice that is designed to ensure that your correctional and detention facilities provide at least 48 hours advance notice, where possible, to DHS regarding the scheduled release date and time of an alien in the jurisdiction's custody when DHS requests such notice in order to take custody of the alien?
3. Does your jurisdiction have a statute, rule, regulation, policy, or practice that is designed to ensure that your correctional and detention facilities will honor a written request from DHS to hold a foreign national for up to 48 hours beyond the scheduled release date, in order to permit DHS to take custody of the foreign national?

The Department of Justice formally requested information from the following four jurisdictions that had expressed interest in participating in the Public Safety Partnership program:

• Albuquerque, New Mexico;
• Baltimore, Maryland;
• San Bernardino, California; and
• Stockton, California.

You may read the letters here [PDF version].

On January 25, 2017, President Trump issued Executive Order 13768, directing the Department of Justice to withhold Federal grants from sanctuary jurisdictions. After an adverse court ruling regarding the provision by the United States District Court for the District of California, Attorney General Sessions issued a DOJ memorandum interpreting the sanctuary jurisdiction provision to apply only to new grants, and not to preexisting grants the terms of which did not stipulate cooperation with Federal immigration enforcement [see blog].

Since the Public Safety Partnership program was announced only on June 20, 2017, and subsequent to President Trump's Executive Order on sanctuary jurisdictions, it is unsurprising that the DOJ has moved to condition participation on meeting certain benchmarks regarding cooperation with Federal immigration enforcement. It remains to be seen how the jurisdictions from which more evidence was requested by the DOJ will respond.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

New Electronic Payment System For 18 USCIS Field Offices

On November 5, 2018, the United States Citizenship and Immigration Services (USCIS) implemented changes to fee payments at the Los Angeles Field Office and the Los Angeles County Field Office [PDF version].

At the two Los Angeles offices, the USCIS implemented a new electronic system for processing fee payments. The goal of this system was to “increase transaction security and reduce processing errors that could cause USCIS to reject applications and petitions.” As a result of the change, applicants were no longer permitted to pay fees by money orders or cashier checks. Applicants were still permitted to pay by check, debit card, credit card, or reloadable pre-paid debit or credit card.

On February 25, 2019, the USCIS announced that it was expanding its new payment system to the following offices [PDF version]:

• Albuquerque, New Mexico;
• Buffalo, New York;
• Detroit, Michigan;
• El Paso, Texas;
• Harlingen, Texas;
• Hartford, Connecticut;
• Jacksonville, Florida;
• Louisville, Kentucky;
• Mt. Laurel, New Jersey;
• Newark, New Jersey;
• Raleigh, North Carolina;
• Sacramento, California; and
• San Antonio, Texas.

These field offices join the Los Angeles, Los Angeles Count, San Bernardino, Santa Ana, and San Fernando Valley field offices in California.

The new news release specifies that the following forms of payment are accepted at the 18 affected field offices:

• Personal check;
• Attorney check;
• Business check;
• Debit card;
• Credit card; or
• Reloadable prepaid credit or debit card.

The USCIS stated “that the update to the fee payment system reduced processing time by 88 percent and reduced the overall applicant service wait time by 75 percent while giving USCIS field officers greater capacity to complete their cases more quickly.

The USCIS stated that it anticipates expanding the new electronic payment program to all field offices by the end of fiscal year 2019.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Overview of GAO Report on Refugee Screening

In July of 2017, the United States Government Accountability Office (GAO) issued a report titled “REFUGEES: Actions Needed by State Department and DHS to Further Strengthen Applicant Screening Process and Assess Fraud Risks” [GAO-17-706]. We have access to the public version of the report which includes all material not deemed sensitive. The 82-page report contains a detailed analysis of the entire refugee screening process and recommendations for the Departments of State (DOS) and Homeland Security (DHS) for improving the vetting process with regard to national security and fraud detection. In this article, we will briefly summarize the report's findings and conclusions. Those who are interested in delving deeper into the issues should study the report in its entirety.

The report found that the DOS and Resettlement Support Centers (RSC) have included in the refugee screening process procedures for detecting fraud. However, the GAO determined that the DOS has not developed outcome-based indicators in accord with its own internal policies for RSCs. The GAO recommended that the DOS develop and implement outcome-based indicators and subsequently monitor the performance of the RSCs against these indicators. The DOS responded favorably to the recommendation, informing the GAO that it has already developed new guidance to monitor RSCs.

The report made three recommendations for the DHS's United States Citizenship and Immigration Services (USCIS) to help the USCIS better adjudicate refugee applications. Firstly, the GAO found that full-time USCIS officers who handle refugee applications are well-trained. However, the GAO recommended that the USCIS provide additional training to temporary officers who may adjudicate refugee applications on circuit rides. Secondly, the GAO noted that the USCIS has achieved favorable results in deploying officers with national security experience to assist in refugee applications. The GAO encouraged the USCIS to formalize this system by developing and implementing a plan to deploy these officers on future circuit rides. Finally, the GAO encouraged the USCIS to conduct quality assurance assessments of refugee applications across the Refugee Affairs Division (RAD) and Internal Operations Division (IO). The USCIS responded favorably to all three recommendations, and it explained how it was seeking to implement them. For example, the USCIS explained that the RAD began hiring and training officers with national security experience who will deploy to locations with high rates of cases beginning in the first quarter of FY 2018.

The GAO also made a joint recommendation for the DOS and DHS. It encouraged the two agencies to conduct regular joint assessments of applicant fraud risks across the United States Refugee Admissions Program (USRAP). Both agencies responded favorably to the suggestion and explained that they are taking steps to implement the regular joint assessments.

The GAO report also closely examined refugee screening of individuals coming from areas where there is significant terrorist activity. However, it is worth noting that the GAO report did not examine this in light of President Donald Trump's Executive Order 13780 [see blog] due in part to the extensive litigation over the Order rendering its effects uncertain.

This post provides just a small sample of the extensive analysis in the GAO report, focusing primarily on its conclusions and its recommendations. It will be worth following how the DOS and DHS move to implement the report's recommendations after having concurred with them in full.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

EOIR Releases Statistics for Feb 1, 2017-July 31, 2017

On August 8, 2017, the Executive Office for Immigration Review (EOIR) released a document titled “Return to Rule of Law in Trump Administration Marked by Increase in Key Immigration Statistics” [PDF version].

The document includes a few interesting statistics from the immigration courts for the period spanning from February 1, 2017 to July 31, 2017.

According to the EOIR, 49,983 total orders of removal were issued in the six-month period covered. This is up from 39,113 orders of removal issued in the same period in 2016, making for a 27.8 percent increase.

The EOIR stated that 57,069 total orders of removal and voluntary departures were issued in the six-month period, making for a 30.9 percent increase over the 43,595 issued in the same period in 2016.

Finally, the EOIR reported 73,127 “final decisions” in the six month period, meaning a situation in which a case ends at the immigration judge level such that the case is no longer pending. This represents a 14.5 percent increase from the 63,850 final decisions issued in the same period in 2016.

The EOIR attributed the increase in part to President Donald Trump's January 25, 2017 Executive Order titled “Border Security and Immigration Enforcement Improvements” [see article on memo on the Order]. In response to the Order, the Department of Justice (DOJ), of which the EOIR is part, moved existing immigration judges to detention facilities across the United States. The DOJ also hired 54 immigration judges since President Trump took office.

The statistics are interesting, although limited in scope. What is clear, however, is that the Trump Administration has taken a more aggressive stance on immigration enforcement than had been taken in the past few years. An individual facing proceedings in immigration court should consult with an experienced immigration attorney immediately to ensure that his or her rights and interests are protected in the adjudicative process.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

DHS OIG Report Finds Waste in Administering Polygraph Exams to CBP Job Applicants

On August 10, 2017, the Department of Homeland Security (DHS) Office of Inspector General (OIG) released a report showing that the U.S. Customs and Border Protection (CBP) spent more than $5,000,000 on polygraph exams for job applicants who had already admitted to disqualifying criminal acts and/or drug use prior to the polygraph exams [PDF version].

The DHS OIG analyzed 380 polygraph exams administered to applicants between 2013-2016. Nearly 20-percent of those who were administered the polygraph exams had previously admitted to criminal activity or drug use that disqualified them from being hired at CBP, regardless of the results of the polygraph exams. The CBP's own data indicated that approximately 2,300 applicants who took polygraph exams admitted to disqualifying offenses or factors prior to their exams, including:

• Illegal drug use;
• Drug smuggling;
• Human trafficking; and
• Having close personal relationships with people who commit such crimes.

The DHS OIG noted that each polygraph exam costs taxpayers $2,200, thus explaining the estimated high cost associated with the useless exams.

The DHS OIG attributed the problem to the CBP's failure to consistently use its on-call adjudication process, which allows examiners to determine prior to administering the polygraph exam whether the job applicant had already made admissions that rendered him or her un-hirable by the CBP.

In response to the findings, the CBP implemented the OIG's recommendation to immediately contact adjudicators when an applicant admits to wrongdoing. Upon the determination of an adjudicator that the applicant is unsuitable based on his or her admissions, the examiner ends the test and the applicant is removed from the hiring process. Additionally, the CBP implemented a pilot program for a new polygraph format. The DHS OIG stated that the CBP's implementation of its recommendations has both improved efficiency and allowed the CBP to focus on suitable candidates who are more likely to pass the polygraph and meet the requirements for the position.

Analysis

Although $5 million dollars is a miniscule amount of the DHS's budget, the report is nevertheless troubling for two reasons.

Firstly, although the amount is small in the grand scheme of DHS funding, it is still an egregious waste of taxpayer money on polygraph exams for persons patently unsuitable for work at the CBP. The government has a fundamental obligation to not waste taxpayers' money.

Secondly, the Trump Administration has requested significant amounts of new funding for the DHS in order to facilitate hiring and new initiatives regarding immigration enforcement. Unsurprisingly, the Trump Administration has thus far had difficulty securing its desired funding from Congress, and it will likely continue to have such difficulty going forward. In the meantime, it is important for the DHS to carefully study how it spends the money that it already receives. The OIG pointed to a similar issue in the summary of the report, namely, the on-going difficulty in completing the CBP hiring surge ordered by President Trump:

Given its plans to hire 5,000 additional Border Patrol Agents, it is important that CBP focus its resources on the most qualified and suitable applicants.

Regarding both money and resource allocation, the DHS's favorable response to the OIG report is certainly encouraging. We can only hope that the reforms will fully resolve the scourge of frivolous polygraph examinations.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

DHS Terminates CAM Parole Program (Effective Aug. 16, 2017)

On August 16, 2017, the Department of Homeland Security (DHS) published a notice in the Federal Register (FR) titled “Termination of the Central American Minors Parole Program” [see 82 FR 38926]. As the name indicates, the Acting Secretary of Homeland Security, Elaine Duke, terminated the Central American Minors (CAM) Parole Program. The termination is effective immediately.

The CAM Parole program was implemented on December 1, 2014, and expanded on November 15, 2016. It is important to distinguish between the CAM Refugee program and the CAM Parole Program. Under the CAM Refugee Program, certain parents who are lawfully present in the United States may seek refugee resettlement interviews for their children residing in Guatemala, Honduras, or El Salvador. The CAM Parole Program allowed those deemed ineligible for refugee status to be paroled into the United States instead. The 2016 expansion of the CAM Parole Program extended the parole benefits to unmarried children under the age of 21 of the qualifying child and allowed individuals other than parents to petition in certain cases. Please see the United States Citizenship and Immigration Services (USCIS) page on the subject for more information [PDF version].

On January 25, 2017, President Donald Trump issued an Executive Order titled “Border Security and Immigration Improvements.” We discussed the Executive Order in detail in our article on then-Secretary of Homeland Security John Kelly's memorandum implementing its provisions [see article]. Both the Executive Order and the Kelly memo directed the DHS to ensure that parole authority is only exercised on a case-by-case basis in accord with section 212(d)(5) of the Immigration and Nationality Act (INA) [see section]. In accord with the Executive Order, Acting Secretary Duke has now terminated the CAM Parole program as being inconsistent with its directive.

Effective August 16, 2017, the DHS will no longer consider parole requests or authorize parole under the CAM Parole Program. Accordingly, individuals who have already been conditionally approved for parole under the CAM Parole Program, but who have not yet traveled to the United States, have had had their conditional parole approval rescinded. However, these individuals may seek parole under the DHS's regular parole authority by filing the Form I-131, Application for Travel Document, in accord with the form instructions. Each parole application will be assessed on a case-by-case basis in light of whether there are urgent humanitarian reasons or significant public benefit grounds for granting parole.

Individuals who are already in the United States on parole that was granted under the CAM Parole Program will not have their parole rescinded. Instead, they will be able to maintain parole until the expiration of their parole periods, unless their parole is otherwise terminated for unrelated reasons in accord with 8 C.F.R. 212.5(e). These individuals may file for re-parole to stay in the United States on the Form I-131. Requests for re-parole should be submitted at least 90 days before the expiration of the parole period. The USCIS will evaluate each request for re-parole on a case-by-case basis and it may require re-parole applicants to demonstrate urgent humanitarian reasons or a significant public benefit.

Please note that the termination of the CAM Parole Program does not affect the CAM Refugee Program. The CAM Refugee Program remains in effect. The only change is that there is no special parole provisions for those denied status under the CAM Refugee Program.

Individuals who are affected by the termination of the CAM Parole Program, or who are unsure of its effects, should consult with an experienced immigration attorney for case-specific guidance. 

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

EOIR Adds Nine New Immigration Judges

On August 14, 2017, the Executive Office for Immigration Review (EOIR) announced that it swore in nine new immigration judges to fill vacancies on seven immigration courts [PDF version]. The nine new immigration judges brings the size of the immigration judge corps to 334. The EOIR stated in the news release that it is using a new streamlined hiring process to reach the maximum authorized number of 384 immigration judges.

The following are the new immigration judges and the immigration courts on which they now sit:

• Karel L. Hansen (Bloomington Immigration Court)
• Jose A. Sanchez (Boston Immigration Court)
• Christopher R. Seppanen (Cleveland Immigration Court)
• Charlotte D. Brown (Harlingen Immigration Court)
• Charles R. Conroy (New York City Immigration Court)
• Maria E. Navarro (New York City Immigration Court)
• Charles M. McCullough (San Antonio Immigration Court)
• Patrick S. O'Brien (San Francisco Immigration Court)
• Joseph Y. Park (San Francisco Immigration Court)

All nine new immigration judges were appointed by Attorney General Jeff Sessions. Both the New York City Immigration Court and the San Francisco Immigration Court welcomed two new immigration judges. The additions to the New York City Immigration Court are also notable in that the previous EOIR investiture also added a new immigration judge to the court [see blog].

In addition to the nine new immigration judges, the EOIR also announced that, beginning on August 20, 2018, Daniel Weiss and Clay Martin will begin work in Dallas and San Antonio, respectively, as assistant chief immigration judges.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

General Requirements for Being an Hired as an Immigration Judge

On August 14, 2017, the Executive Officer for Immigration Review announced the swearing in of nine immigration judges, which we discuss on site [see blog]. In its news release, the EOIR provided a window into what the Attorney General looks for when evaluating immigration judge applicants [PDF version].

An April 7, 2016 notice for an immigration judge job opening for the Baltimore Immigration Court noted several additional requirements [PDF version]:

• Must have an LL.B or J.D. degree;
• Must be duly licensed and authorized to practice law as an attorney under the laws of a state, territory, or the District of Columbia;
• Must be a U.S. citizen or national (noncitizen nationals qualify); and
• Must have a minimum of seven years of relevant post-bar admission legal experience at the time the application is submitted.

It is important to note that those who are neither citizens nor nationals are not eligible to be immigration judges. This includes lawful permanent residents.

Applicants are required to meet the above basic qualifications by the closing date of the job opening announcement.

Returning to the August 14, 2017 document, the EOIR stated that an immigration judge applicant must demonstrate the “appropriate temperament” to serve as an immigration judge. Additionally, the applicant must satisfy any three of the following five criteria in order to be selected as an immigration judge:

• Knowledge of immigration laws and procedures;
• Substantial litigation experience;
• Experience handling complex legal issues;
• Experience conducting administrative hearings; and
• Knowledge of judicial practices and procedures.

The qualifications allow for talented lawyers with a variety of legal backgrounds to be considered for positions as immigration judges. The nine judges sworn in on August 14 bring a variety of experiences to their new positions. Some worked extensively in private practice, others served as administrative adjudicators in non-immigration positions, a few were attorneys for the Legal Aid Society, one was a military adjudicator, and two served as attorneys at the U.S. Immigration and Customs Enforcement (ICE).

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Two Prominent Florida Republicans Offer Thoughts on RAISE Act Proposal

Two prominent Republicans from Florida made interesting comments regarding the RAISE Act, the substantial immigration bill proposal co-sponsored by Senators Tom Cotton of Arkansas and David Perdue of Georgia. To read an overview of the RAISE Act proposal and my thoughts on the proposed legislation, please see my comprehensive blog [see blog]. In this article, we will examine the comments of Senator Marco Rubio of Florida and former Florida Governor Jeb Bush.

Senator Rubio's remarks were reported by Melissa Quinn of the Washington Examiner [link][1]. I noted in my full blog on the RAISE Act that Senator Rubio seemed to express support for some of the legislation's goals. In a subsequent interview, he suggested that, despite the RAISE Act being supported by President Trump, he believed that there was no chance that it would pass the Senate.

Regarding the merits of the legislation, he supported its goal of creating a merit-based immigration system, noting that this particular point of the legislation was similar to the Gang of Eight effort he was part of in 2013. However, Senator Rubio disagreed with the proposed cuts to overall immigration numbers in the proposal. He stated that his goal was not to limit legal immigration, but rather to change the immigration system. He noted that where he differed was the RAISE Act's setting of an “arbitrary cap on the number of people that are able to come through with a green card.” Instead, he suggested that immigration numbers should be tied to demand.

Newsmax reported comments on the legislation from Jeb Bush, the former Governor of Florida who, like Rubio, ran for president in 2016 [link][2]. Similarly to Senator Rubio, Bush backed the RAISE Act's implementation of a points-based system for employment immigration, noting that it was similar to systems in Australia and Canada which have proven to be successful. Bush went further, also supporting the limitation of family reunification visas to spouses and unmarried children under the age of 21. He criticized the current system of allowing adult siblings, adult parents, and adult sons and daughters to obtain permanent resident status through family-based immigration. He added that the United States takes in far more family-based immigrants as a percentage of total immigrants than “any other country.”

However, Bush criticized two aspects of the proposal. First, he agreed with Senator Rubio that overall immigration levels should not be cut. Second, he disagreed with what he described as the English language requirement, believing that it should only come into play for naturalization purposes.

I agree with both Rubio and Bush that the RAISE Act fails in cutting overall immigration levels. However, as they note, certain elements of the legislation, such as the concept of the points-based immigration system, should be a part of any immigration reform effort. It is unclear whether there is any path in the Senate to passing immigration legislation of this scope. However, if an agreement can be reached on the issue of overall immigration numbers between those who want reductions, such as Senators Cotton and Perdue, and those who want to keep the numbers steady or increase them, such as Senators Marco Rubio and Lindsey Graham, it is possible that workable legislation which includes a points-based system for employment immigration could garner more serious consideration.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

1. Quinn, Melissa. “Marco Rubio: Trump's immigration bill is 'not going to pass' the Senate.” Washington Examiner. Aug. 7, 2017. Washingtonexaminer.com
2. Beamon, Todd. “Jeb Bush Likes Some Parts of Trump-Backed Immigration Plan.” Newsmax. Aug. 9, 2017. Newsmax.com

Lawyer website: http://myattorneyusa.com

Important Settlement Agreement for Detainees at Two Major ICE Detention Facilities

In important news, the parties in Dilley Pro Bono Project v. ICE reached a settlement in proceedings before the United States District Court for the District of Columbia [PDF version]. The settlement agreement helps ensure that pro bono attorneys for detainees at two U.S. Immigration and Customs Enforcement (ICE) facilities will be able to facilitate telephonic mental health examinations for their clients in a timely manner. For this article, we will also rely upon the statement of facts contained in the plaintiff's complaint for declaratory and injunctive relief [PDF version].

General Background

The plaintiff, Dilley Pro Bono Project (DPBP), provides free legal services to mothers and children in immigration detention who are seeking asylum.

The incident sparking the litigation occurred at the South Texas Family Residential Center (STFRC), the largest of the U.S. Immigration and Customs Enforcement's (ICE's) detention facilities. The STFRC was established in 2014, and since its establishment, the ICE has permitted legal service providers to enter the facility to meet with clients. According to the complaint, the ICE provides offices and telephones for use by the legal service providers and their detainee clients. However, the complaint stated that in May of 2017, the ICE adopted a policy requiring that any telephonic mental health medical examinations (during which counsel is present while the client consults by telephone with the medical professional) required pre-approval. The complaint states that the ICE relied upon this policy to justify revoking access to the facility by Caroline Perris, an attorney for the DPBP, who had arranged a telephonic medical examination for a client for March 3, 2017. The complaint states that she arranged this telephonic mental health evaluation because it was necessary in order to avert the deportation of her client and her client's child to the country from which they fled.

The DPBP stated that the revocation of Perris's access to the STFRC “significantly impeded” the ability of both the DPBP and its managing attorney, Shalyn Fluharty, to effectively represent potential clients in immigration detention. They noted, first, that because the DPBP relies on mental health professionals who are willing to provide free services the DPBP must be able to accommodate their schedules. The DPBP stated that the ICE had implemented no guidelines or timetables for approving requests for telephonic mental health examinations and, in fact, would often fail to approve them in a timely manner. The DPBP accordingly argued that the ICE's policy was contrary to law.

Settlement Agreement

On August 15, 2017, the plaintiffs and the ICE entered into a stipulated settlement agreement. The ICE denied and continues to deny that its policies involving telephonic medical examinations were improper. Nevertheless, both parties agreed to the stipulated settlement agreement, finding it to be in their best interests and in the interests of justice.

The agreement affects the STFRC and the Karnes County Residential Center (KCRC), which is also in Texas. Under the settlement agreement, legal counsel must still make a request to ICE regarding a telephonic medical examination. Furthermore, the request cannot stay removal or otherwise interfere with any actions of the United States government related to the detainee that would conflict with the scheduled evaluation. However, the agreement prohibits the ICE from “tak[ing] actions for the purpose of interfering with a resident's ability to participate in a telephonic medical evaluation.”

Under the agreement, the ICE may only base the denial of an initial request for a telephonic medical examination on one of the following grounds:

1. Confirmation that the health provider's relevant professional license or credential is currently revoked or suspended;
2. Identification of relevant criminal history of a health provider that indicates a risk of harm or abuse to the resident;
3. Confirmation that the provider's access to the family residential center is currently revoked for misconduct that indicates a risk of harm or abuse to the resident.

If the ICE denies an initial request, it will be required to provide the requester with a detailed written explanation for the denial at the same time that the denial is issued. This must give the requester time to independently verify the basis of the denial. In the event that the parties disagree over a denial, the settlement agreement sets procedures for “good faith” conferrals to jointly and informally resolve the dispute.

One condition of the agreement was that Judge Christopher R. Cooper of the District Court for the District of Columbia, or a magistrate judge designated by Judge Cooper, retain jurisdiction over the case for 2.5 years in order to enforce the settlement agreement. Judge Cooper assumed such jurisdiction and dismissed the case with prejudice on the same day [PDF version].

Additionally, the ICE agreed that Caroline Perris's access to the STFRC is reinstated. The ICE also agreed to refrain from taking any action to inhibit the access of any of the plaintiffs' attorneys based on the events of March 3, 2017. It is worth noting that Perris' access was reinstated in response to the initial complaint filed by the DPBP.

Conclusion

The settlement agreement represents an important victory for pro bono attorneys and their clients at two major ICE detention facilities. It is important that individuals in immigration detention have access to legal counsel and services to assess their situations and protect their rights. As the plaintiffs noted, mental health evaluations may in many cases be decisive for mothers and children staking a claim for relief after crossing the Southwest Border. Regardless of the concerns that led to the ICE's implementation of the policy in question, individuals in immigration detention must be permitted to have their cases fully assessed by qualified legal representatives, which includes having access to crucial mental health evaluations when necessary. The settlement agreement promises to help ensure that attorneys have the ability to offer clients in detention at the two covered facilities the full and robust representation that they deserve. In so doing, the agreement will ensure that clients at the facilities have the opportunity to have their cases for relief effectively developed and considered.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Over 27,000 Visa Applications Denied in 2018 Due to "Travel Ban"

On February 26, 2019, Reuters reported that the Department of State (DOS) refused more than 37,000 visa applications in 2018 under President Donald Trump's Presidential Proclamation 9645, colloquially known as the “travel ban.”[1] DOS denied 21,645 applications for nonimmigrant visas and 15,384 applications for immigrant visas in 2018 under the travel ban. The DOS granted approximately 2,200 waivers of the entry restrictions for nationals from affected countries.

The 37,000 denials marked a dramatic increase from 2017, when only 1,000 visa applications were denied under previous iterations of the ban. The increase corresponds with the Supreme Court of the United States' decision in Trump v. Hawaii, which upheld the travel ban in Presidential Proclamation 9645 in its entirety. Reuters notes that the number of visas issued to nationals of Iran, Libya, Somalia, Syria, and Yemen in 2018 were down approximately 80 percent from 2016.

It is clear that Presidential Proclamation 9645 is being implemented in a way that creates a high bar for those from affected countries seeking to overcome the entry restrictions. Individuals from these countries seeking visas in affected categories should consult with an experienced immigration attorney for case-specific guidance. To learn more, please see our full articles on the “travel ban” [see article] and the opinion of the Court in Trump v. Hawaii [see article].

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

1. Torbati, Yeganeh. “U.S. denied tens of thousands more visas in 2018 due to travel ban: data.” Reuters. Feb. 26, 2019. https://www.reuters.com/article/us-usa-immigration-ban/u-s-denied-tens-of-thousands-more-visas-in-2018-due-to-travel-ban-data-idUSKCN1QF2KF

Lawyer website: http://myattorneyusa.com

USCIS Contact Center Experiencing Higher Than Normal Wait Times

On February 25, 2019, the United States Citizenship and Immigration Services (USCIS) advised customers that the USCIS Contact Center is experiencing higher than normal wait times for callers to speak to a USCIS representative [PDF version].

The USCIS states that it is working to resolve the issue of long wait times for customers calling the USCIS Contact Center. In the interim, the USCIS advises customers to use self-service applicant tools on the USCIS website where applicable. These tools include, but are not limited to, USCIS online accounts, the Case Status Online tool, the Change of Address tool, and the USCIS's online virtual assistant (“Emma”).

Those who cannot resolve inquiries through use of the USCIS's self-service applicant tools may call the USCIS Contact Center at 800-375-5283 (TTY 800-767-1833). The USCIS Contact Center has representatives available from 8 AM to 8 PM from Monday through Friday, excluding federal holidays.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

USCIS Reaches H2B Cap for Second Half of FY-2019

On February 22, 2019, the United States Citizenship and Immigration Services (USCIS) announced that it received enough H2B petitions to meet the H2B cap for the second half of fiscal year 2019 [PDF version]. February 19, 2019, was the final receipt date for H2B petitions requesting an employment start date before October 1, 2019. Accordingly, the USCIS will reject any new cap-subject H2B petitions requesting an employment start date before October 1, 2019.

The USCIS received petitions for more potential H2B beneficiaries than the total number of remaining available H2B visas for the second half of fiscal year 2019. Accordingly, the USCIS conducted an H2B lottery to select from those petitions enough to meet the fiscal year 2019 H2B cap. The USCIS assigned all H2B petitions selected in the H2B lottery a receipt date of February 22, 2019. The USCIS also began premium process service [see article] for H2B petitions selected in the H2B lottery on that date.

Notwithstanding the USCIS's meeting the H2B cap for the second half of fiscal year 2019, the USCIS will continue to accept H2B petitions that are not subject to the H2B cap. For example, current H2B workers who are petitioning for an extension of stay and (if applicable) a change of the terms of employment or change of employer are not subject to the H2B cap. Certain petitions for fish roe processors, fish roe technicians, and supervisors of fish roe processing are not subject to the H2B cap. Finally, H2B petitions in the Commonwealth of the Northern Mariana Islands and Guam are, under specific rules, not subject to the H2B cap from November 29, 2009, through December 31, 2029.

To learn about which countries are eligible to participate in the H2B program in 2019, please see our full article on the subject [see article].

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Imprecise Language and the Immigration Debate

In this post, I will examine an interesting op-ed by Donna Locke published in the Tennessean titled “Trump goes after illegal entrants to U.S., not all immigrants” [PDF version][1].

There is much in Locke's post with which I disagree. For example, Locke seems to advocate for “immigration control” based in part on the fact that the population would grow for many years even with no immigration at all. Readers of my blog will note that while I am a proponent of effective enforcement of our immigration laws [see blog], I am also a strong supporter of legal immigration as a force that is in the national benefit [see blog].

However, while I disagree with Locke on many particulars, she makes an important point with which I agree regarding the effect of language on the immigration debate. She takes issue with terminology from the media and from those who support laxer immigration laws to “blur the distinctions between legal and illegal” in the immigration context.

Locke notes that many outlets refer to those in the United States illegally as “immigrants.” The issue with this is that an “immigrant” is someone who is in the United States with legal authorization, specifically, an alien who is lawfully admitted for permanent residence. Immigrants are distinguished from other classes of aliens who are in the United States legally — such as nonimmigrants and parolees. Under no circumstance is an individual who illegally entered or illegally remained the United States or who for whatever reason lost his or her legal status an “immigrant.”

To describe individuals in the United States illegally as “immigrants” implies “bias,” as Locke notes. It is important to remember — especially for those who frequent our website and are interested in the immigration laws — that the vast majority of people are exceedingly unfamiliar with the technicalities of U.S. immigration law. This is why describing those who are here illegally as “immigrants” has a tendency to sway the immigration debate. It is likely that, to laymen, reading about President Trump (or any other president) deporting “immigrants” sounds quite different than President Trump deporting an “illegal alien” or someone who is in the United States without legal authorization. Of course, an “immigrant” is only subject to removal on specified grounds, whereas someone who is in the country illegally is subject to removal based on the fact that he or she is in the country illegally. Locke also noted the bizarre push to stop using the term “alien.” The term alien is not sinister at all; it is simply the technical term in immigration law for referring to those who are not citizens or nationals of the United States.

Using precise language is not callous, but in fact necessary in many cases. I have represented countless clients who faced removal for being in the United States illegally for one reason or another. Effective representation begins with understanding the laws and the situation. This certainly does not involve pretending that a client, who is without status and removable is, in fact an immigrant in good standing under the immigration laws.

In order to improve the system of immigration laws, it is in the best interest of everyone to have an honest debate about immigration. An honest debate about immigration involves people who actually understand what they are debating. This in turn supports the notion that the terms we use should reflect the reality of the immigration laws, not the opinions of one side of a many-sided debate. Save for open borders advocates, it is in the best interests of everyone to actually distinguish between those who are here legally and illegally, and to further distinguish within those categories on the basis of legal status and how and when people came to be here illegally.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

1. Locke, Donna. “Trump goes after illegal entrants to U.S., not all immigrants.” Tennessean. Aug. 10, 2017. Tennessean.com

Lawyer website: http://myattorneyusa.com