`
`Nos. 24A884, 24A885, 24A886
`
`
`
`
`
`IN THE SUPREME COURT OF THE UNITED STATES
`
`
`
`DONALD J. TRUMP, et al., Applicants,
`v.
`CASA, INC., et al., Respondents.
`
`
`DONALD J. TRUMP, et al., Applicants,
`v.
`WASHINGTON, et al., Respondents.
`
`
`DONALD J. TRUMP, et al., Applicants,
`v.
`NEW JERSEY, et al., Respondents.
`
`
`
`BRIEF OF IMMIGRATION REFORM LAW INSTITUTE
`AS AMICUS CURIAE IN SUPPORT OF APPLICATIONS FOR STAY
`
`
`
`
`
`CHRISTOPHER J. HAJEC
`Counsel of Record
`GABRIEL R. CANAAN
`IMMIGRATION REFORM LAW INSTITUTE
`25 Massachusetts Ave., NW, Suite 335
`Washington, DC 20001
`chajec@irli.org
`(202) 232-5590
`
`Counsel for Amicus Curiae
`Immigration Reform Law Institute
`
`
`
`
`
`
`
`
`
`
`

`

`
`
`TABLE OF CONTENTS
`
`TABLE OF AUTHORITIES ................................................................................ ii
`
`IDENTITY AND INTEREST OF AMICUS CURIAE .........................................1
`
`INTRODUCTION .................................................................................................1
`
`SUMMARY OF ARGUMENT ..............................................................................2
`
`ARGUMENT .........................................................................................................3
`
`I.
`
`To be “subject to the jurisdiction” of the United States under the
`Citizenship Clause, one must have permission to reside in the
`United States .........................................................................................4
`
`A. To be within the allegiance and protection of the United States,
`one must have permission to reside here ...........................................4
`
`B. To be subject to the jurisdiction of the United States, one must be
`within the allegiance and protection of the United States ...............9
`
`C. Wong Kim Ark’s permission requirement was a holding of the
`Court ................................................................................................. 10
`
`II. Respondents have no likelihood of success in their facial challenge 12
`
`CONCLUSION ................................................................................................... 13
`
`
`
`
`
`
`
`
`
`
`
`i
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`
`

`

`
`
`
`
`Cases
`
`TABLE OF AUTHORITIES
`
`AFSCME Council 79 v. Scott,
`717 F.3d 851 (11th Cir. 2013)....................................................................... 13
`
`Alliance for the Wild Rockies v. Cottrell,
`632 F.3d 1127 (9th Cir. 2011)..........................................................................3
`
`
`Ariz. Dream Act Coalition v. Brewer,
`855 F.3d 957 (9th Cir. 2017)............................................................................1
`
`Disney Enters., Inc. v. VidAngel, Inc.,
`869 F.3d 848 (9th Cir. 2017)............................................................................3
`
`Elk v. Wilkins,
`112 U.S. 94 (1884) ............................................................................................9
`
`Fong Yue Ting v. United States,
`149 U.S. 698 (1893) ........................................................................... 5, 6, 7, 10
`
`Franchise Tax Bd. of Cal. v. Hyatt,
`587 U.S. 230 (2019) ..........................................................................................7
`
`Jackson v. Virginia,
`443 U.S. 307 (1979) ....................................................................................... 11
`
`Minor v. Happersett,
`88 U.S. 162 (1874) ............................................................................................8
`
`
`New York State Liquor Authority v. Bellanca,
`452 U.S. 714 (1981) ..........................................................................................3
`
`Plyler v. Doe,
`457 U.S. 202 (1982) ....................................................................................... 12
`
`Rodriguez de Quijas v. Shearson/American Express, Inc.,
`490 U.S. 477 (1989) ....................................................................................... 12
`
`
`Matter of Silva-Trevino,
`26 I. & N. Dec. 826 (B.I.A. 2016) .....................................................................1
`
`
`
`ii
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`
`

`

`
`
`Trump v. Hawaii,
`585 U.S. 667 (2018) ..........................................................................................1
`
`United States v. Salerno,
`481 U.S. 739 (1987) ....................................................................................... 13
`
`
`United States v. Texas,
`599 U.S. 670 (2023) ..........................................................................................1
`
`United States v. Wong Kim Ark,
`169 U.S. 649 (1898) ....................................................................... 4, 5, 7, 9, 12
`
`
`Wash. All. Tech Workers v. U.S. Dep’t of Homeland Sec.,
`50 F.4th 164 (D.C. Cir. 2022) ..........................................................................1
`
`Winter v. NRDC, Inc.,
`555 U.S. 7 (2008) ..............................................................................................3
`
`Other Authorities
`
`U.S. National Archives & Records Administration, Chinese Exclusion Act ......8
`
`The Concise Oxford Dictionary of Current English (7th ed. 1919).....................5
`
`Exec. Order No. 13989, 85 Fed. Reg. 512 (2025) .................................................2
`
`Amanda Frost, “By Accident of Birth”: The Battle over Birthright
`Citizenship After United States v. Wong Kim Ark,
`32 Yale J.L. & Human. 38 (2021)......................................................................8
`
`Treatises
`
`Emer de Vattel, The Law of Nations bk. 1, ch. 19, § 213
`(Joseph Chitty trans., 6th Am. ed. 1844) .........................................................7
`
`Constitutional Provisions
`
`U.S. CONST. amend. XIV, § 1 .............................................................................4
`
`
`
`
`
`
`iii
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`
`
`IDENTITY AND INTEREST OF AMICUS CURIAE
`
`Amicus curiae Immigration Reform Law Institute (“IRLI”) is a non-profit
`
`501(c)(3) public interest law firm dedicated to litigating immigration-related
`
`cases on behalf of, and in the interests of, United States citizens, and also to
`
`assisting courts in understanding and accurately applying federal immigration
`
`law. IRLI has litigated or filed amicus curiae briefs in a wide variety of cases,
`
`including Trump v. Hawaii, 585 U.S. 667 (2018); United States v. Texas, 599
`
`U.S. 670 (2023); Ariz. Dream Act Coalition v. Brewer, 855 F.3d 957 (9th Cir.
`
`2017); Wash. All. Tech Workers v. U.S. Dep’t of Homeland Sec., 50 F.4th 164
`
`(D.C. Cir. 2022); and Matter of Silva-Trevino, 26 I. & N. Dec. 826 (B.I.A. 2016).1
`
`INTRODUCTION
`
`On January 20, 2025, President Donald J. Trump signed an executive
`
`order titled “Protecting the Value of United States Citizenship” (“EO”). This
`
`order provides that:
`
`United States citizenship does not automatically extend to persons
`born in the United States: (1) when that person’s mother was
`unlawfully present in the United States and the father was not a
`United States citizen or lawful permanent resident at the time of
`said person’s birth, or (2) when that person’s mother’s presence in
`the United States at the time of said person’s birth was lawful but
`temporary (such as, but not limited to, visiting the United States
`under the auspices of the Visa Waiver Program or visiting on a
`
`
`1 No counsel for any party authored this brief in whole or in part and no
`person or entity, other than amicus curiae, its members, or its counsel, has
`contributed money that was intended to fund preparing or submitting the brief.
`
`1
`
`
`

`

`
`
`student, work, or tourist visa) and the father was not a United
`States citizen or lawful permanent resident at the time of said
`person’s birth.
`
`Exec. Order No. 13989, 85 Fed. Reg. 512 (2025). It then directs the relevant
`
`federal agencies to “take all appropriate measures to ensure that the
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`regulations and policies of their respective departments and agencies are
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`consistent with this order, and that no officers, employees, or agents of their
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`respective departments and agencies act, or forbear from acting, in any manner
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`inconsistent with this order.” Id.
`
`SUMMARY OF ARGUMENT
`
`The lower courts’ preliminary injunctions rest on a glaring legal error.
`
`This Court has held that only children born in the United States to parents
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`who, at the time, were permitted to reside in the United States are citizens at
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`birth by virtue of the Citizenship Clause of the Fourteenth Amendment. Also,
`
`because Respondents make only a facial challenge to the EO, they can succeed
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`only if no set of circumstances exists under which the EO would be valid. Under
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`this Court’s controlling precedent, the EO is valid as applied in innumerable
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`situations, such as to children of illegal aliens.
`
`The lower courts wrongly concluded that the phrase “subject to the
`
`jurisdiction” as used in the Citizenship Clause means merely being subject to
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`the country’s territorial sovereignty. In fact, to be “subject to the jurisdiction”
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`of the United States for purposes of this clause means to be within the nation’s
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`2
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`

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`
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`allegiance and protection, not merely subject to its laws or territorial
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`sovereignty. This Court has held that for a person to be born within the nation’s
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`allegiance and protection, and thus subject to its jurisdiction, that person must
`
`be born in the United States to a parent who, at that time, had permission to
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`reside in the United States. Because the lower courts applied the incorrect
`
`legal standard in determining that Respondents were likely to succeed on the
`
`merits, this court should narrow the lower courts’ injunctions, which, as the
`
`Applications demonstrate, also suffer from jurisdictional and scope-of-relief
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`issues.
`
`ARGUMENT
`
`A preliminary injunction is an “extraordinary remedy.” Winter v. NRDC,
`
`Inc., 555 U.S. 7, 20 (2008). The standard of review for a preliminary injunction
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`is abuse of discretion, New York State Liquor Authority v. Bellanca, 452 U.S.
`
`714, 716 (1981), and a district court abuses its discretion if it applies an
`
`incorrect legal standard, makes clearly erroneous factual findings, or
`
`misapplies the relevant legal principles. Alliance for the Wild Rockies v.
`
`Cottrell, 632 F.3d 1127, 1131 (9th Cir. 2011); Disney Enters., Inc. v. VidAngel,
`
`Inc., 869 F.3d 848, 856 (9th Cir. 2017).
`
`Here, the lower courts applied an incorrect legal standard. The
`
`Citizenship Clause of the Fourteenth Amendment provides that “[a]ll persons
`
`born or naturalized in the United States, and subject to the jurisdiction thereof,
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`3
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`

`

`
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`are citizens of the United States.” U.S. CONST. amend. XIV, § 1. Contrary to
`
`the lower courts’ views, in the central case on birthright citizenship, United
`
`States v. Wong Kim Ark, 169 U.S. 649 (1898), this Court held that, to have
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`citizenship at birth under the Citizenship Clause, one must be born in the
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`geographic confines of the United States to parents who, at the time of one’s
`
`birth, had permission to reside in the United States.
`
`I.
`
`
`
`To be “subject to the jurisdiction” of the United States under the
`Citizenship Clause, one must have permission to reside in the
`United States.
`
`A. To be within the allegiance and protection of the United
`States, one must have permission to reside here.
`
`
`At issue in Wong Kim Ark was whether a son born to Chinese subjects
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`lawfully residing in the United States was a citizen at birth under the
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`Citizenship Clause. This Court found that he was, explaining:
`
`The Fourteenth Amendment affirms the ancient and fundamental
`rule of citizenship by birth within the territory, in the allegiance
`and under the protection of the country, including all children here
`born of resident aliens, with the exceptions or qualifications (as old
`as the rule itself) of children of foreign sovereigns or their
`ministers, or born on foreign public ships, or of enemies within and
`during a hostile occupation of part of our territory, and with the
`single additional exception of children of members of the Indian
`tribes owing direct allegiance to their several tribes. The
`Amendment, in clear words and in manifest intent, includes the
`children born, within the territory of the United States, of all other
`persons, of whatever race or color, domiciled within the United
`States. Every citizen or subject of another country, while domiciled
`here, is within the allegiance and the protection, and consequently
`subject to the jurisdiction, of the United States. His allegiance to
`the United States is direct and immediate, and although but local
`
`4
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`

`

`
`
`and temporary, continuing only so long as he remains within our
`territory, is yet, in the words of Lord Coke, in Calvin’s Case, 7 Rep.
`6a, “strong enough to make a natural subject, for if he hath issue
`here, that issue is a natural-born subject;” and his child, as said by
`Mr. Binney in his essay before quoted, “if born in the country, is as
`much a citizen as the natural-born child of a citizen, and by
`operation of the same principle.” It can hardly be denied that an
`alien is completely subject to the political jurisdiction of the country
`in which he resides—seeing that, as said by Mr. Webster, when
`Secretary of State, in his Report to the President on Thrasher’s
`Case in 1851, and since repeated by this court, “independently of a
`residence with intention to continue such residence; independently
`of any domiciliation; independently of the taking of any oath of
`allegiance or of renouncing any former allegiance, it is well known
`that, by the public law, an alien, or a stranger born, for so long a
`time as he continues within the dominions of a foreign government,
`owes obedience to the laws of that government, and may be
`punished for treason, or other crimes, as a native-born subject
`might be, unless his case is varied by some treaty stipulations.” Ex.
`Doc. H.R. No. 10, 1st sess. 32d Congress, p. 4; 6 Webster’s Works,
`526; United States v. Carlisle, 16 Wall. 147, 155; Calvin’s Case, 7
`Rep. 6a; Ellesmere on Postnati, 63; 1 Hale P.C. 62; 4 Bl. Com. 74,
`92.
`
`
`Id. at 693-94 (emphasis added). The Court then added an important proviso,
`
`applicable to the particular facts of the case:
`
`Chinese persons, born out of the United States, remaining subjects
`of the Emperor of China, and not having become citizens of the
`United States, are entitled to the protection of and owe allegiance
`to the United States, so long as they are permitted by the United
`States to reside here; and are “subject to the jurisdiction thereof,”
`in the same sense as all other aliens [lawfully] residing in the
`United States.
`
`
`Id. at 694 (emphasis added) (citing, inter alia, Fong Yue Ting v. United States,
`
`149 U.S. 698, 724 (1893)). See, e.g., The Concise Oxford Dictionary of Current
`
`English 825 (7th ed. 1919) (defining “so long as” as “with the proviso, on the
`
`5
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`

`

`
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`condition, that”). Here, then, the Court held that persons such as Wong Kim
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`Ark’s parents—and thus children born to them in the United States—were
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`within the allegiance and protection of the United States “so long as they are
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`permitted by the United States to reside here”—meaning, provided that they
`
`were permitted to reside here.
`
`One reason the Wong Kim Ark Court added this proviso is that, at the
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`time, other Chinese persons—laborers who had overstayed their permission to
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`be in the country—were subject to deportation under the Exclusion Acts, and
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`thus, for the Court, were not within the allegiance and protection of the United
`
`States. As the Court had put it in a case it cited in the above passage:
`
`Chinese laborers, [] like all other aliens residing in the United
`States for a shorter or longer time, are entitled, so long as they are
`permitted by the government of the United States to remain in the
`country, to the safeguards of the Constitution, and to the protection
`of the laws, in regard to their rights of person or property, and to
`their civil and criminal responsibility.
`
`Fong Yue Ting, 149 U.S. at 724 (emphasis added). Thus, for the Court, Chinese
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`laborers and other resident aliens who were not permitted by law to reside in
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`the United States were not “entitled . . . to the safeguards of the Constitution,
`
`and to the protection of the laws, in regard to their rights of person or property,
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`and to their civil and criminal responsibility.” And, thus, unlike Chinese
`
`persons such as Wong Kim Ark’s parents, whose permission to reside here was
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`6
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`

`

`
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`undisputed, such aliens were not within the allegiance and protection of the
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`United States. Wong Kim Ark, 169 U.S. at 694.
`
`As the Court in Fong Yue Ting further explained:
`
`By the law of nations, doubtless, aliens residing in a country, with
`the intention of making it a permanent place of abode, acquire, in
`one sense, a domicil there; and, while they are permitted by the
`nation to retain such a residence and domicil, are subject to its
`laws, and may invoke its protection against other nations. This is
`recognized by those publicists who, as has been seen, maintain in
`the strongest terms the right of the nation to expel any or all aliens
`at its pleasure. Vattel, lib. 1, c. 19, § 213; 1 Phillimore, c. 18, § 321;
`Mr. Marcy, in Koszta’s case, Wharton’s International Law Digest,
`§ 198. See also Lau Ow Bew v. United States, 144 U.S. 47, 62;
`Merlin, Repertoire de Jurisprudence, Domicile, § 13, quoted in the
`case, above cited, of In re Adam, 1 Moore P.C. 460, 472,
`473.(emphasis added).
`
`
`Fong Yue Ting, 149 U.S. at 724 (emphasis added). The cited-to selection of
`
`Emmer de Vattel’s treatise The Law of Nations, which was highly influential
`
`on American jurisprudence, Franchise Tax Bd. of Cal. v. Hyatt, 587 U.S. 230,
`
`239 (2019), describes these reciprocal duties:
`
`The inhabitants, as distinguished from citizens, are foreigners who
`are permitted to settle and stay in the country. Bound to the society
`by the residence, they are subject to the laws of the state while
`they reside in it; and they are obliged to defend it, because it grants
`them protection, though they do not participate in all the rights of
`citizens. They enjoy only the advantages which the law or custom
`gives them. (emphasis added.)
`
`
`Emer de Vattel, The Law of Nations bk. 1, ch. 19, § 213 (Joseph Chitty trans.,
`
`6th Am. ed. 1844) (emphasis added). Indeed, the Court’s holding in Wong Kim
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`Ark continues to comport with common sense, since an illegal alien, subject to
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`7
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`

`

`
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`apprehension, detention, and removal at all times, can hardly be said to be
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`within the “protection” of the United States, as the phrase “allegiance and
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`protection” has always been understood. See, e.g., Minor v. Happersett, 88 U.S.
`
`162, 165-66 (1874) (“The very idea of a political community, such as a nation
`
`is, implies an association of persons for the promotion of their general welfare.
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`Each one of the persons associated becomes a member of the nation formed by
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`the association. He owes it allegiance and is entitled to its protection.”)
`
`(emphasis added).
`
`When the Court issued its ruling in Wong Kim Ark, no law prohibited
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`aliens of any nationality other than Chinese from residing here. See Amanda
`
`Frost, “By Accident of Birth”: The Battle over Birthright Citizenship After
`
`United States v. Wong Kim Ark, 32 Yale J.L. & Human. 38, 47 (Summer 2021);
`
`U.S. National Archives & Records Administration, Chinese Exclusion Act,
`
`https://www.archives.gov/milestone-documents/chinese-exclusion-act
`
`(last
`
`visited Mar. 13, 2025). But, of course, even apart from Fong Yue Ting’s above
`
`generalization of the permission requirement to all resident aliens, it is wholly
`
`against the tenor of Wong Kim Ark to imagine that the requirement was only
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`applicable to the Chinese—that only Chinese persons, if excluded, would be
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`outside the allegiance and protection of the United States, while those of other
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`nationalities who might be excluded, if Congress had passed a law excluding
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`them, would somehow remain within the nation’s allegiance and protection.
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`8
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`

`

`
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`Needless to say, the Court was far from observing any such distinction of race
`
`or nationality.
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`B. To be subject to the jurisdiction of the United States, one
`must be within the allegiance and protection of the United
`States.
`
`
`Being “subject to the jurisdiction” of the United States under the
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`Citizenship Clause means not merely being subject to the laws of the United
`
`States, but being subject to the nation’s political jurisdiction and “owing it
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`direct and immediate allegiance.” Wong Kim Ark, 169 U.S. at 680 (citing Elk
`
`v. Wilkins, 112 U.S. 94, 101-102 (1884)):
`
`The only adjudication that has been made by this court upon the
`meaning of the clause, “and subject to the jurisdiction thereof,” in
`the
`leading provision
`of
`the Fourteenth Amendment,
`is Elk v. Wilkins, 112 U.S. 94, in which it was decided that an
`Indian born a member of one of the Indian tribes within the United
`States, which still existed and was recognized as an Indian tribe
`by the United States, who had voluntarily separated himself from
`his tribe, and taken up his residence among the white citizens of a
`State, but who did not appear to have been naturalized, or taxed,
`or in any way recognized or treated as a citizen, either by the
`United States or by the State, was not a citizen of the United
`States, as a person born in the United States, “and subject to the
`jurisdiction thereof,” within the meaning of the clause in question.
`That decision was placed upon the grounds, that the
`meaning of those words was, “not merely subject in some respect
`or degree to the jurisdiction of the United States, but completely
`subject to their political jurisdiction, and owing them direct and
`immediate allegiance.”
`
`Id. at 680 (emphasis added). Thus, for this Court, being subject to the
`
`jurisdiction of the United States required “owing” the United States “direct and
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`9
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`

`

`
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`immediate allegiance.” Quite obviously, those outside the allegiance and
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`protection of the United States altogether—such as excluded Chinese laborers
`
`then, or illegal aliens today—cannot be said to meet the requirement of owing
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`the United States “direct and immediate allegiance.” Therefore, they cannot be
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`“subject to the jurisdiction” of the United States under the Citizenship Clause.
`
`C. Wong Kim Ark’s permission requirement was a holding of
`the Court.
`
`
`Not to regard this Court as holding permission to reside in the country
`
`to be a prerequisite for being subject to the jurisdiction of the United States for
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`Citizenship Clause purposes would be to truncate the reasoning the Court gave
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`for its judgment, ignore the precedents it cited, and make nonsense of its
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`opinion. For example, this Court would then have left open the possibility
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`(which it explicitly foreclosed, and had earlier foreclosed, Fong Yue Ting, 149
`
`U.S at 724)) that those residing in the country while being prohibited from
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`doing so were within the allegiance and protection of the United States, or the
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`possibility that one could be outside of the nation’s allegiance and protection
`
`but still owe it “direct and immediate allegiance,” as required for being subject
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`to its jurisdiction.
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`The Court’s proviso requiring permission to reside also is clearly part of
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`its holding, not dicta, because that proviso was part of the rule of law the Court
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`stated and applied when considering the particular facts of the case. These
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`10
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`

`
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`were that Wong Kim Ark’s parents were not merely resident aliens, but
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`Chinese subjects residing in the United States at a time when some Chinese,
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`uniquely among nationalities, were excluded from the country. It was when
`
`considering these particular facts that the Court had the need to articulate its
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`proviso about permission to reside, and that proviso is thus part of the rule of
`
`law it announced and applied to reach its judgment concerning those particular
`
`facts.
`
`And, of course, this Court may set forth a standard as part of its holding
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`in a case even when the Court finds that the standard has been met in that
`
`case. For example, in Jackson v. Virginia, 443 U.S. 307 (1979), the Court held
`
`that a federal court hearing habeas corpus must consider whether there was
`
`legally sufficient evidence to support a conviction, not just whether there was
`
`some evidence, even though it found that the prosecution had met the former,
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`higher standard. Likewise, Wong Kim Ark did not leave open the question of
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`whether those born in this country to persons who did not lawfully reside in
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`the country were birthright citizens merely because it was undisputed that
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`Wong Kim Ark’s parents lawfully resided here. Rather, the standard the Court
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`announced and applied was part of its holding, even though Wong Kim Ark
`
`met that standard. Any view of “holding” that is more restrictive, at least if
`
`applied to this Court, would rob the Court of its ability to set forth general
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`11
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`

`
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`principles of law to guide lower courts in any case where the general principle
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`it discerned, and relied on to reach its judgment, happened to be met.
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`It is true that the Court in Wong Kim Ark stated, in dicta, that
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`“jurisdiction” had a unitary meaning in the Fourteenth Amendment. 169 U.S.
`
`at 687. It is also true that “jurisdiction” for purposes of the Equal Protection
`
`Clause of that amendment was later held to be merely geographical. Plyler v.
`
`Doe, 457 U.S. 202, 215 (1982). But that is not enough to conclude that the Plyler
`
`holding alters Wong Kim Ark’s holding—with which it is fully consistent—
`
`about the meaning of “jurisdiction” in the Citizenship Clause. This
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`insufficiency goes double for lower courts. A fortiori, Rodriguez de Quijas v.
`
`Shearson/American Express, Inc., 490 U.S. 477, 484 (1989) (“If a precedent of
`
`this Court has direct application in a case, yet appears to rest on reasons
`
`rejected in some other line of decisions, the Court of Appeals should follow the
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`case which directly controls, leaving to this Court the prerogative of overruling
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`its own decisions.”).
`
`II. Respondents have no likelihood of success in their facial
`challenges.
`
`
`
`It follows from Wong Kim Ark that the EO has innumerable valid
`
`applications, including to children born to illegal aliens, tourists, and others
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`who do not have permission to reside in the United States. Therefore, the lower
`
`courts erred in concluding that Respondents were likely to succeed on the
`
`12
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`

`

`
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`merits of their facial challenge. United States v. Salerno, 481 U.S. 739, 745
`
`(1987) (“A facial challenge to a legislative Act is, of course, the most difficult
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`challenge to mount successfully, since the challenger must establish that no
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`set of circumstances exists under which the Act would be valid.”); see also
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`AFSCME Council 79 v. Scott, 717 F.3d 851, 857-858 (11th Cir. 2013) (applying
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`the rule of Salerno to a facial challenge to an executive order). In light of Wong
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`Kim Ark’s holding that, to have birthright citizenship under the Fourteenth
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`Amendment, one’s parents must have been permitted to reside in the United
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`States at one’s birth, the EO is far from invalid on its face.
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`
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`CONCLUSION
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`For the foregoing reasons, the Court should grant the Applications.
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`Dated: March 19, 2025 Respectfully submitted,
`
`
`
`
`CHRISTOPHER J. HAJEC
`Counsel of Record
`GABRIEL R. CANAAN
`IMMIGRATION REFORM LAW INSTITUTE
`25 Massachusetts Ave., NW, Suite 335
`Washington, DC 20001
`chajec@irli.org
`(202) 232-5590
`
`Counsel for Amicus Curiae
`Immigration Reform Law Institute
`
`13
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