478. Luis H. Zayas & Laurie Cook Heffron, Am. Psychol.
Ass’n, Disrupting young lives: How detention and deportation
affect US-born children of immigrants (Nov. 2016), https://
www.apa.org/pi/families/resources/newsletter/2016/11/
detention-deportation.
479. Wendy Cervantes, Rebecca Ullrich & Hannah
Matthews, Center for L. & Soc. Pol’y, Our Children’s Fear:
Immigration Policy’s Effects on Young Children, (Mar. 2018),
https://www.clasp.org/sites/default/files/publications/2018/03/2018_ourchildrensfears.pdf; Maureen B.
Costello, S. Poverty L. Center, The Trump Effect: The
impact of the presidential campaign on our nation’s schools
(2016), https://www.splcenter.org/sites/default/files/
splc_the_trump_effect.pdf; Randy Capps et al., Migration
Pol’y Institute, Implications of Immigration Enforcement
Activities for the Well-Being of Children in Immigrant
Families: A Review of the Literature (Sept. 2015), http://
www.migrationpolicy.org/research/implications-immigration-enforcement-activities-well-being-children-immigrant-families.
480. Leila Schochet & Nicole Prchal Svajlenka, Center for
Am. Progress, How ending TPS will hurt U.S.-citizen
children (Feb. 11, 2019), https://www.americanprogress.
org/issues/immigration/reports/2019/02/11/466022/
ending-tps-will-hurt-u-s-citizen-children/; Kalina M.
Brabeck and Qingwen Xu, The Impact of Detention and
Deportation on Latino Immigrant Children and Families: A
Quantitative Exploration, 32 Hisp. J. Behav. Sci. 341 (2010),
https://www.researchgate.net/publication/247721989_
The_Impact_of_Detention_and_Deportation_on_Latino_
Immigrant_Children_and_Families_A_Quantitative_Exploration.; Hirokazu Yoshikawa, Erin B. Godfrey & Ann C.
Rivera, Access to institutional resources as a measure of social
exclusion: relations with family process and cognitive
development in the context of immigration, 2008 New
Directions for Child & Adolescent Dev. 63 (2008), https://
nyuscholars.nyu.edu/en/publications/access-to-institutional-resources-as-a-measure-of-social-exclusio.
481. 328 U.S. 654.
482. Cassandra Burke Robertson and Irina D. Manta.,
(Un)Civil Denaturalization, 94 New York University Law
Review 402, 461 (2019), https://www.nyulawreview.org/
wp-content/uploads/2019/06/NYULawReview-94-3-RobertsonMantapdf.pdf.
483. Unicorn Riot, Icebreaker Pt 1 – secret Homeland
Security ICE/HSI manual for stripping US citizenship (Feb.
14, 2018), https://unicornriot.ninja/2018/icebreaker-pt-1-secret-homeland-security-ice-hsi-manual-stripping-us-citizenship/.
484. Civil Division, FY 2020 Budget & Performance Plans
(Mar. 2019), at 16, https://www.justice.gov/jmd/page/
file/1143936/download.
485. See Mathews v. Diaz, 426 U.S. 78 & n.12 (1976): “The
Constitution protects the privileges and immunities only
of citizens, Amdt. 14, § 1; see Art. IV, § 2, cl. 1, and the right
Endnotes
to vote only of citizens. Amdts. 15, 19, 24, 26. It requires
that Representatives have been citizens for seven years,
Art. I, § 2, cl. 2, and Senators citizens for nine, Art. I, § 3, cl.
3, and that the President be a ‘natural born Citizen.’ Art. II,
§ 1, cl. 5. “A multitude of federal statutes distinguish
between citizens and aliens. The whole of Title 8 of the
United States Code, regulating aliens and nationality, is
founded on the legitimacy of distinguishing between
citizens and aliens. A variety of other federal statutes
provide for disparate treatment of aliens and citizens.
These include prohibitions and restrictions upon
Government employment of aliens, e.g., 10 U.S.C. § 5571;
22 U.S.C. § 1044(e), upon private employment of aliens,
e.g., 10 U.S.C. § 2279; 12 U.S.C. § 72, and upon investments
and businesses of aliens, e.g., 12 U.S.C. § 619; 47 U.S.C. §
17; statutes excluding aliens from benefits available to
citizens, e.g., 26 U.S.C. § 931 (1970 ed. and Supp. IV); 46
U.S.C. § 1171(a), and from protections extended to
citizens, e.g., 19 U.S.C. § 1526; 29 U.S.C. § 633a (1970 ed.,
Supp. IV); and statutes imposing added burdens upon
aliens, e.g., 26 U.S.C. § 6851(d); 28 U.S.C. § 1391(d).
Several statutes treat certain aliens more favorably than
citizens. E.g., 19 U.S.C. § 1586(e); 50 U.S.C.App. § 453
(1970 ed., Supp. IV). Other statutes, similar to the one at
issue in this case, provide for equal treatment of citizens
and aliens lawfully admitted for permanent residence. 10
U.S.C. § 8253; 18 U.S.C. § 613(2) (1970 ed., Supp. IV). Still
others equate citizens and aliens who have declared their
intention to become citizens. E.g., 43 U.S.C. § 161; 30
U.S.C. § 22. Yet others condition equal treatment of an
alien upon reciprocal treatment of United States citizens
by the alien's own country. E.g., 10 U.S.C. § 7435(a); 28
U.S.C. § 2502.”See also Brubaker, Citizenship and
Nationalism in France and Germany 21 (“There is a
conceptually clear, legally consequential, and ideologically charged distinction between citizens and foreigners.”).
486. Demore v. Kim, 538 U.S. 510, 521 (2003) (quoting
Mathews, 426 U.S. at 79-80). See also Rachel E. Rosenbloom, The Citizenship Line: Rethinking Immigration
Exceptionalism, 54 B.C.L. Rev. 1695, 1982 (2013) (quoting
Demore v. Kim).
487. See James C. Scott, Seeing Like a State: How Certain
Schemes to Improve the Human Condition Have Failed
(1998).
488. See Judge Kozinski in Angov v. Lynch, 788 F.3d 893,
901 (“Those born with U.S. citizenship cannot imagine
what this is worth to the world’s poor and oppressed
billions, most of whom would come here tomorrow if they
could. Gaining a lawful foothold in America is an
incalculable benefit. It sets an immigrant on a the path to a
peaceful life in a free society, economic prosperity,
citizenship and the opportunity to bring family members
in due course. A prize like this is worth a great deal of
expense and risk. Telling an elaborate lie, and coming up
with forged documents and mendacious witnesses to back
it up, is nothing at all when the stakes are so high.”). See
also Sarah Igo, The Known Citizen 89 (2018) (On the Social
Security Number: “Never simply a means of tracking
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