42 Jacqueline Bhabha unaccompanied and accompanied by their families, are denied their liberty in the absence of any criminal charges, but merely because of their immigration status. Flores’s complex and tortuous history spans the past three decades of violence in Central America, from the murderous civil wars of the 1980s to the pervasive gang criminality of the twenty-first century, violence in which the United States has continually been deeply implicated. In the 1980s, the United States was a key supporter of paramilitary activity shoring up the Central American dictatorships by providing them with military training, arms, and other forms of support. Many young adults targeted by military were forced to flee; Jenny Flores was one of thousands of children left behind in El Salvador, who traveled unaccompanied to reunify with a US-based parent.30 In the 1990s and through the twenty-first century, the United States has been the entity responsible for the export of gang violence from its metropolitan cities, a clear example of the spill-over effect of misguided and poorly considered punitive measures against young migrants. As discussed in more detail later, the violence has turned the so-called Northern Triangle countries of Central America, Guatemala, Honduras, and El Salvador into murder capitals of the world. The gang export process originated with the deportation from US cities, primarily Los Angeles, of sizeable numbers of convicted young Central American migrants, who had been brought to the United States as infants. These young immigrants, many living in impoverished neighborhoods and in families with parents working very long hours to make ends meet, had become ensnared in the drug and gang warfare in inner city Los Angeles. After serving their criminal sentences, they were ordered deported. By forcibly sending these long resident offenders to “homes” to which they had no ties, the United States was operating a discriminatory form of double jeopardy – piling on the draconian sanction of deportation after the young migrants had already served their criminal sentences. The United States was also creating what Dan Kanstroom memorably terms a new “American diaspora,” a community of deracinated youth who found status and a means of survival through the launch of gang warfare in the impoverished environments to which they were forced back.31 A new chapter in the story of punitive and misguided policies targeting child migrants from Central America is now starting with the attack on Flores. The fascinating history of the Flores case, a decades-long battleground for the protracted fight over the length and conditions of child migrant confinement, is brilliantly recounted by Phil Schrag in his new book, Baby Jails.32 He highlights the contestation between constitutional principle (children’s liberty interests), represented by activist immigrant rights advocates, and administrative discretion in the service of 30 Schrag, Baby Jails. D. Kanstroom, Aftermath: Deportation Law and the New American Diaspora (Oxford: Oxford University Press, 2012). 32 Schrag, Baby Jails. 31 https://doi.org/10.1017/9781108914994 Published online by Cambridge University Press