DACA litigation, the “illegal/undocumented alien/immigrant” issue, and a surprise

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In the recent decision enjoining the suspension of DACA (but giving the government a 90-day mulligan), the court referred to the people who are affected by DACA’s suspension as “undocumented aliens” rather than “illegal aliens,” and it dropped a footnote explaining why it made that choice:

Some courts, including the Supreme Court, have referred to aliens who are unlawfully present in the United States as “illegal” instead of “undocumented.”  See, e.g.,  Texas  v.  United  States, (explaining that this “is the term used by the Supreme Court in its latest pronouncement pertaining to this area of the law”); but see  Mohawk Indust., Inc. v. Carpenter (using the term “undocumented immigrants”). Because both terms appear in the record materials here, and because, as at least one court has noted, “there is a certain segment of the population that finds the phrase ‘illegal alien’  offensive,” Texas v. United States, the Court will use the term “undocumented.” [pdf (citation details omitted)]

Although the court didn't similarly decide to use immigrant instead of alien, that may well be due more to the fact that alien is a frequently used term in the context of immigration law than to any view about the term's possible offensiveness.

The first case mentioned in the footnote, Texas v. United States, is the decision by the U.S. Court of Appeals for the Fifth Circuit that had enjoined the DAPA program (Deferred Action for Parents of Americans and Lawful Permanent Residents, which was related to but separate from DACA, which stands for Deferred Action for Childhood Arrivals). That decision used the term illegal aliens rather than undocumented aliens, but like Tuesday’s DACA decision, it explained its choice of terminology.

The court in Texas v. United States relied mainly on Bryan Garner, who it quoted as follows:

The usual and preferable term in [American English] is illegal alien. The other forms have arisen as needless euphemisms, and should be avoided as near-gobbledygook. The problem with undocumented is that it is intended to mean, by those who use it in this phrase, “not having the requisite documents to enter or stay in a country legally.” But the word strongly suggests “unaccounted for” to those unfamiliar with this quasi-legal jargon, and it may therefore obscure the meaning.

More than one writer has argued in favor of undocumented alien . . . [to] avoid[] the implication that one’s unauthorized presence in the United States is a crime . . . . [However],  it is wrong to equate illegality with criminality, since many illegal acts are not criminal. Illegal alien is not an opprobrious epithet: it describes one present in a country in violation of the immigration laws (hence “illegal”).

That quote comes from the third edition of Garner’s Dictionary of Legal Usage (2011). An identical entry appears in the third edition of Garner’s Modern American Usage (2009). (If you want to read the entries, look under undocumented alien.)

Among the points that are noteworthy about these entries is that they express no discomfort with the fact that their preferred phrasing, if read literally, ascribes the property of illegality to a category of human beings. In contrast, both of these volumes did express discomfort with the semantically parallel phrase illegitimate child, which, if read literally, ascribes the property of illegitimacy to a different category of human beings: “Though the phrase is still often used, it is undeniably insensitive. As a far-sighted judge once observed, ‘There are no illegitimate children, only illegitimate parents.’” Did Garner see any inconsistency between his acceptance of illegal alien and his condemnation of illegitimate children? And if he did, does that explain that the two volumes I've been discussing, the heading for the entry dealing with illegal alien began with undocumented rather than illegal, so that it wouldn't show up on the same page as the entry for illegitimate child? Beats me.

[Update: After looking at some of the comments, it occurs to me that I may not have been clear about what it was that I thought was noteworthy about the apparent inconsistency between Garner's acceptance of illegal alien and his condemnation of illegitimate child. What I wanted to focus on was not so much the syntactic/semantic constraints regarding adjectival modification, as on the emotional resonance that results from the use of the adjectives in question (although those two things may be related). While Garner thought that illegal alien "is not an opprobrious epithet," he regarded illegitimate child as "insensitive."]

In any event, the fourth edition of Garner’s general-purpose usage manual came out in 2016, under the title Garner’s Modern English Usage. And in place of the entry I’ve been discussing, there is a completely new entry, alphabetized under illegal immigrant and therefore separated from illegitimate child only by the four-line entry for illegible.

In this new entry, rather than continuing to confidently insist that illegal alien “is not an opprobrious epithet,” Garner presents both sides of the controversy:

The terminology relating to those who come to live in another country without official permission is highly charged—increasingly so since about 1980. From 1930 on, illegal immigrant has been the usual phrase in BrE, but only from about 1945 to 1970 was it the predominant term in AmE.

About 1970, illegal alien surged into common use in AmE, and it remains predominant today. But some think it doubly tendentious: coupling the dysphemistic alien with the negatively charged illegal makes it easy, the argument goes, to dehumanize people who struggle to improve their lives without complying with bureaucratic requirements for entry. People who hold views something like this consider illegal alien a snarl-phrase and prefer instead a euphemism such as undocumented immigrant (or, even more euphemistically, undocumented worker).

Those who, on the other hand, prefer illegal alien note that alien is the age-old legal term for a noncitizen within a country—that there are resident aliens who have green cards that allow them to stay indefinitely. Those taking this position note that both unsanctioned entry into the United States and overstaying one’s visa are infractions—hence illegal. On this view, illegal alien is therefore a denotatively accurate phrase for someone who is present in a country in violation of the immigration laws. People with this view scorn undocumented as doublespeak because the word ordinarily means “unaccounted for” but in this instance seems to bear the anodyne sense “not having the requisite documents to enter or stay in a country.”

There are those who take the (very) long view that, anthropologically speaking, people have always migrated across land masses according to their needs. Notions of national sovereignty, they might say, are relatively recent constructs.

Although few might be thought to share this radical view, something like it has become fairly mainstream. On 7 March 2015, addressing the nation from Selma, Alabama, 50 years after Martin Luther King Jr.’s famous march, President Barack Obama said (as part of a long litany): “We are the people who swim across the Rio Grande in search of a better life.” In his very next utterance (after completing the litany), he disclaimed the idea that “some of us are more American than others.”

In such a climate, the phrase illegal alien is perceived as hostile—mostly by those on the left. Undocumented immigrant has gradually become preferable in their eyes. Yet that phrase is viewed as hopelessly evasive and misleading by those on the right.

So the terminology is shifting. Big data tell us that as of 2008, illegal alien remained prevalent in AmE print sources, followed closely by illegal immigrant, which itself was nearly three times as common as undocumented immigrant. Least common of all was undocumented alien. Meanwhile, in the Republican-primary presidential debates of 2015, the attributive noun illegals was used by moderators and candidates alike—which is rather like the 1920s habit of referring to people afflicted with tuberculosis as tuberculars.

The resolution of these political and terminological struggles is yet to be documented.

Although I’ve been critical of Garner (and I have more criticism in the works), I give him credit for what I think is a pretty remarkable change in his treatment of this emotionally- and politically-loaded usage issue. Garner seems to me to be making a genuine effort to be evenhanded, so for once I’m not going to give him a hard time.

Garner’s new entry—specifically, his reference to the state of usage as of 2008—inspired me to check out the current state of legal usage, and to see how it compares to legal usage in the year Garner mentioned. Using Westlaw, I searched the caselaw in all U.S. jurisdictions, both federal and state, for the search terms illegal alien, undocumented alien, illegal immigrant, and undocumented immigrant. (The plural forms for those terms are automatically included in those searches.) One set of searches covered the past 12 months; the other covered 2008.

I found that in 2008, the patterns illegal NOUN and ADJECTIVE  alien accounted for 80% and 81% of all the hits, respectively. (The total adds up to more than 100% because the two patterns overlap, with illegal NOUN including both illegal alien and illegal immigrant, and ADJECTIVE alien including both illegal alien and undocumented alien.)

However, in the past year (April 25, 2017–April 25, 2018), illegal NOUN was down to 57% and ADJECTIVE alien was down to 67%. The phrase that showed the biggest change in frequency was undocumented immigrant, which increased nearly 400%, from 5% of the total number of hits to 19%.

It would be interesting to chart out the changes each year since 2008, so those of you with Westlaw access, have at it, and report back in the comments. And put a note in your tickler file to remind you to run the searches again a year from now.

Previous Language Log posts about illegal aliens:
Subsective adjectives and immigration
Are we Americans, Donald and I?”

h/t Mike Scarcella, “Why Judge John Bates Embraced 'Undocumented' Over 'Illegal' in DACA Ruling” ($), via Ben Zimmer


  1. CL Thornett said,

    April 26, 2018 @ 3:47 am

    The 'Windrush generation' in the UK is a good example of people who are undocumented rather than illegal immigrants, the landing cards which showed that they entered the UK legally as children of legal immigrant workers, on their parents' documentation, having been destroyed several years ago. The government's 'hostile environment' (their description) for immigrants was demanding four pieces of documentary evidence per year of residence in the UK to prove legal status. That would be 200 pieces of evidence required for a 50-year residence since childhood. Various people have pointed out that most people born in the UK would find this level of documentation impossible.

    When the term 'illegal alien/immigrant' is combined with a widespread assumption that anyone who is not part of the dominant ethnicity is not only an immigrant rather than native born, but is probably an 'illegal' until they can prove otherwise, the justification for insisting the term 'illegal alien' is the neutral one seems rather dubious.

  2. AntC said,

    April 26, 2018 @ 5:37 am

    @CLT, yes I immediately thought of the 'Windrush generation'. Britain was more than happy to staff its hospitals with these people over many years, and trust them with day-to-day caring for any Britons. No suggestion they were in the country illegally.

    I can personally vouch that I couldn't produce that level of documentation for myself, born/educated/working in the UK for 40 years (until I emigrated — at which point I had to prove I was British, so that I could become something else).

    Similarly, America has been very happy for 'Dreamers' to contribute to its economy, with successive governments 'looking the other way' on their immigration status. Come to that: how many living in America of European descent can prove their immigration status?

  3. Saurs said,

    April 26, 2018 @ 5:56 am

    Divorced of context, the explanation for favoring "undocumented" — that laypeople may interpret it to mean the person described doesn't exist on some state database somewhere and thus their existence is unknown and uncounted and their true identity unestablished — makes a certain amount of sense, but given that it is evermore frequently used to describe a real person with a real name whose identity is known and vetted, it doesn't really stand up to much interrogation.

    Something like "unpermitted" or "lapsed" would serve to clarify the issue (since there is no single universal immigration experience or status) if, indeed, this is the reason the anti-immigration set prefers to call all manner of people "Illegals." However, given that the "crimes" such people are accused of are largely ephemeral — for example, DACA recipients do, indeed, possess documents and did not commit any crime by accompanying their parents or relatives wherever they traveled — "illegal" is equally obfuscatory, emotive, and imprecise, particularly when one considers that substantively establishing the question of one's legal residence dating back several decades is no mean feat, and an absolutely subjective one on the part of state actors and arbiters. Besides which, DACA was an agreement; it is not the recipients and promised recipients who are betraying both the spirit and the literal terms of that agreement.

    The comparison to "tuberculars" is utterly, risibly disingenuous. Incidentally, I wonder if Garner is aware of the phenomenon of tuberculosis on the US-Mexican border and its social and political consequences.

  4. Saurs said,

    April 26, 2018 @ 5:59 am

    Excuse me, first line of that comment should begin: "[d]ivorced of context, the explanation for disfavoring 'undocumented[.]'"

  5. Michael P said,

    April 26, 2018 @ 6:57 am

    Although I am American, I do not remember seeing "illegal alien" often enough for it to register as a thing. I have regularly seen "illegal immigrant", and always understood it to refer to someone alleged to have immigrated to the country in violation of the immigration laws, which (contra Saurs's comment) certainly applies to DACA applicants.

    Using the phrase "undocumented" seems blatantly dishonest — either the person is documented as being present in the country illegally, or is not documented because he or she entered the country illegally, and in either case the public concern is the illegality rather than the status of the person's documents. In practice, we need a single term to encompass both those whose authorization to be in the country has "lapsed" and those who were always "unpermitted", because the shared "experience [and] status" is that they violated immigration laws and are legally not supposed to be in the country.

    I hope the Supreme Court will step in soon and tell lower courts to stop entering nationwide injunctions against the government. When a district or appeals court enters such an injunction, it implicitly declares that it has more power to determine the laws of the United States than Congress or the executive branch. There should be at most one court with that much legal power.

  6. CL Thornett said,

    April 26, 2018 @ 7:20 am

    Michael P:
    'Undocumented' usually means not possessing the nationality documents that satisfy legal conditions. A person may be in a country legally, but not have documents to prove that to the satisfaction of immigration authorities, as is the case of many child immigrants to the UK from the 1950s and 60s. A native-born citizen may not have a copy of their birth certificate in their immediate possession. Not everyone owns a passport. In the UK instance, documents were destroyed by a government department, and the documents most adults keep were not considered adequate proof of nationality. Document archives, especially older paper-based ones, can be destroyed by fire or flood as well as administrative error.

  7. Kristina said,

    April 26, 2018 @ 7:25 am

    I agree that "undocumented" is not fully accurate, but really do think "illegal alien" sounds quite odd (although, any Englishmen in New York who could check this one for me?). "Illegal immigrant" is a little better, but honestly: if I park illegally in a handicap zone (without a permit, even though I could get a note from my doctor to get a permit) am I now an "illegal parker"? I'd asterisk that myself as dubiously grammatical, although I'd be hard pressed to make an agency rule that would describe why that seems wrong to me.

    Perhaps my variety of English does not like bringing the adjective along when nominalizing a verb to refer to the actor–because that involves changing the grammatical inflection of the descriptor as well, even though the descriptor refers to the action more than the actor. "Illegally resident alien" sounds awkwardly long, but does not set off any bells. Neither does "illegal entry." But "illegal enterer," ick.

    Of course, Law English is a completely different dialect.

  8. Tom S. Fox said,

    April 26, 2018 @ 7:57 am

    So, why don’t you have a problem with the property of illegitimacy being ascribed to parents?

  9. Tom S. Fox said,

    April 26, 2018 @ 8:25 am

    I’d also like to point out that Obama also said this:

    “We all agree on the need to better secure the border, and to punish employers who choose to hire illegal immigrants. You know, we are a generous and welcoming people here in the United States, but those who enter the country illegaly, and those who employ them, disrespect the rule of law, and they are showing disregard for those who are following the law. We simply cannot allow people to pour into the United States undetected, undocumented, unchecked, and circumventing the line of people who are waiting patiently, diligently, and lawfully to become immigrants in this country. So that’s why we need to start by giving agencies charge with border-security new technology, new facilities, and more people to stop, process, and deport illegal immigrants.”

  10. Coby Lubliner said,

    April 26, 2018 @ 8:50 am

    I will quote a blog post I wrote a few years ago.

    On April 2, the Associated Press’s Senior Vice President and Executive Editor Kathleen Carroll wrote that

    [the AP] Stylebook no longer sanctions the term “illegal immigrant” or the use of “illegal” to describe a person. Instead, it tells users that “illegal” should describe only an action, such as living in or immigrating to a country illegally.

    Is this supposed to be a pronouncement on English syntax? That is, an adjective describing an action should not modify the person committing that action?

    There is a certain logic to that judgment. But then what about, say bad writer? Someone who writes badly can be a perfectly good person. (Or vice versa.) An abstract artist may produce abstract art, but is usually a concrete person. A criminal lawyer may practice criminal law, but is most probably a law-abiding citizen. I wonder if the AP will, for the sake of consistency, drop these usages.

    Probably not.

  11. Doug said,

    April 26, 2018 @ 9:22 am

    Michael P wrote:
    "Although I am American, I do not remember seeing "illegal alien" often enough for it to register as a thing. "

    My impression is that "illegal alien" is long past its peak.

    There was a song "Illegal Alien" in 1984:


    and I recall that the movie "Alien" (1979) had a joke about illegal aliens.
    "Illegal immigrant" seems to have supplanted "illegal alien" since then.

  12. Doug said,

    April 26, 2018 @ 9:32 am

    Or perhaps it was a sequel to the original "Alien."

  13. Neal Goldfarb said,

    April 26, 2018 @ 10:32 am

    @Saurs: "The comparison to 'tuberculars' is utterly, risibly disingenuous."

    Could you explain why you regard the comparison is disingenuous?

    I ask, not out of snarkiness (snarky, moi?), but out of genuine puzzlement. Not having been around, back when people with tuberculosis were referred to as tuberculars, and not having previously encountered the word, I don't have the background knowledge that would enable me to understand what your getting at.

    For that matter, I don't completely understand what Garner was getting at, either. However, in his case I can make what I think is a half-decent guess. In yours, on the other hand, I'm lost.

  14. J.W. Brewer said,

    April 26, 2018 @ 11:18 am

    "Illegal worker" is apparently standard jargon if you're the Australian government. https://www.homeaffairs.gov.au/lega/lega/form/immi-faqs/who-is-an-illegal-worker

    An individual human being can be an "illegal contractor" in the view of the State of California. http://www.cslb.ca.gov/Consumers/Report_Unlicensed_Activity/What_Is_Illegal_Contractor_Activity.aspx

    You can be penalized for being an "illegal man downfield" in (American) football. http://www.al.com/sports/index.ssf/2016/02/college_football_rules_committ.html

    As often happens with taboo or controversial expressions, attempts to formulate a broader principle of usage that the controversial expression violates will perhaps turn out not to be evidence-based.

  15. J.W. Brewer said,

    April 26, 2018 @ 11:28 am

    Let me make one broader point about the ambiguity of "illegal" in at least AmEng. There's a broad-scope sense that's something like "doing anything that if push comes to shove a court will rule you were not supposed to do" (or even, as above, the referee in a football game will rule you were not supposed to do) and a narrow-scope sense that's something like "doing anything that if push comes to shove will get you charged with a crime and sentenced to prison." So things like breaching a contract (which will get you sued but not criminally charged) or failing to put money in the parking meter under conditions where you were supposed to (which will get you fined but not criminally charged) are within the broad scope but not the narrow scope. That most violations of the US immigration laws are not, in practice, dealt with by criminal sanctions, is probably one of the things going on here, with people who find "illegal" offensive thinking (perhaps not consciously?) that something that's only broad-scope illegal is being pejoratively characterized as narrow-scope illegal. (Of course, one of the reasons this is an emotionally-charged issue is that while technically deportation is not a criminal sanction, it is often taken to be almost as severe, if not more so, in its consequences for the affected individual.)

  16. J.W. Brewer said,

    April 26, 2018 @ 11:40 am

    One example on usage of the alternative adjective: I once represented pro bono an incarcerated client who, among other inadvisable things, had sold some guns under informal circumstances to a supposed buddy who turned out to be a government informant. One of the relevant federal felonies my client was convicted of was transferring a firearm while not holding a valid federal firearm dealer's license. That was pretty much all the government had to prove to establish guilt – he made the transfer (under circumstances where no exception to the license requirement was applicable) and he didn't have the license. And he most definitely did not have such a license – whether he would or would not have been eligible for one had he applied was not legally relevant to his guilt. I think, however, that I would be accused of being misleadingly euphemistic if I referred to him as an "undocumented gun seller." (I did point out in written court submissions that his offense was, in and of itself, non-violent and regulatory in nature, but tried to be careful not to oversell that point to the degree it might undercut my credibility.)

  17. Neal Goldfarb said,

    April 26, 2018 @ 12:15 pm

    J.W. Brewer lists several expressions that follow the pattern illegal NOUN yet don't have the same unfavorable connotations as illegal alien and then adds, "As often happens with taboo or controversial expressions, attempts to formulate a broader principle of usage that the controversial expression violates will perhaps turn out not to be evidence-based.

    The examples he gives do seem to suggest that the connotations associated with illegal alien aren't the result of semantics alone. But I don't think that means that semantics has nothing to do with it. It seems to me that what makes the connotation possible is the availability of a simplemindedly literal reading in which illegality is treated as a trait of a person.

    Also, negative connotations are already triggered by the use of alien (for discussion, see "Stop calling people 'aliens'"), and that probably makes it more likely that the potential negative connotations from the use of illegal will be evoked.

  18. J.W. Brewer said,

    April 26, 2018 @ 3:00 pm

    Is there a middle-ground adjective neither as harsh as "illegal" nor as euphemistic as "undocumented"? "Unauthorized worker" might work, as it were, for me, but "unauthorized alien" sounds somewhat weird, although whatever reasons a bureaucratic sentence saying that such-and-such function may only be performed by "a U.S. citizen or authorized alien" doesn't sound weird. But maybe that's because the authorized/unauthorized distinction in that sort of context would apply to the presence or absence of authority to perform some activity more narrowly focused than physical presence in the U.S.?

  19. Andrew (not the same one) said,

    April 26, 2018 @ 3:04 pm

    As far as I can see J.W. Brewer's examples are not parallel to 'illegal alien'. They are parallel to 'illegal immigrant', and do indeed show that that is not objectionable simply in virtue of its form: 'illegal [actor]' can mean 'one who does [action] illegally'. But 'alien' is not a word connoting action, so the same thing would not apply there.

    As for 'tuberculars', that means 'people who are tubercular', not 'people who have done [action] tubercularly', so it does not provide a suitable parallel for 'illegals' used as an abbreviation for 'illegal immigrants'.

  20. J.W. Brewer said,

    April 26, 2018 @ 3:08 pm

    (Should probably have typed "authorization" rather than "authority" in the last sentence of prior comment.)

  21. Ghili said,

    April 26, 2018 @ 3:45 pm

    I personally prefer the term "unlawful resident". "Unlawful" has a softer connotation, being generally used to describe matters of civil law, but doesn't attempt to obfuscate the principal issue: that the given person is in violation of immigration law by their continued residence in the country, regardless of whether their initial act of immigration was in accordance with it. I suppose it could be misinterpreted as a euphemism for a squatter though.

  22. J.W. Brewer said,

    April 26, 2018 @ 3:48 pm

    While it's true that "alien" seems more a description of a status than an actor who has taken a specific action, in the relevant U.S. context, at least, "alien" does necessarily connote an action, i.e. the action of having traveled to and entered the U.S. at some previous point in time, since if you'd been born in the U.S. (absent statistically rare situations like your parents being foreign diplomats) you'd be a U.S. citizen. "Alien" is a contextual, one might perhaps say, almost deictic word. When I lived in Japan, I was, in context, an alien. Now that I again live in the U.S., I'm not.

    There is the not-uncommon situation of people whose original entry into the U.S. was lawful on e.g. a tourist or student visa but who then overstayed. But there are lots of situations in the law where failure-to-do-X-when-required-to-do-so is conceptualized as an action, or at least you can't avoid legal responsibility by claiming that you took no affirmative act but just allowed the status quo to continue. E.g. you might be thought to have committed the "act" of trespassing regardless of whether you originally entered the property without proper permission or whether, having originally entered with proper permission, you refused to leave after that permission was revoked and/or expired under its original terms. Or you could conceptualize continuing-to-remain-in-the-U.S. as an ongoing action that continues until you leave (or until your immigration status is regularized so that your continued presence is an action but a lawful one), the way possession of contraband is conceptualized.

    (There are of course circumstances where we might not think someone morally or legally responsible for any of these actions, as when e.g. they were a small child at the time, but that's true of a wide variety of actions.)

  23. Gregory Kusnick said,

    April 26, 2018 @ 9:10 pm

    Driving without a license is illegal (in J.W.'s broad sense), but few would argue that "unlicensed driver" is an unacceptable euphemism for "illegal driver".

  24. Alyssa said,

    April 27, 2018 @ 1:35 pm

    There are a number of ways a person can be a lawful but undocumented immigrant. For instance, when I first moved to Canada, I spent about 6 months undocumented, because as someone born and raised outside Canada to Canadian parents, I had citizenship from birth but no paperwork to prove that citizenship directly. It was legal for me to live and work here (I checked), but I had to apply for a "Certificate of Citizenship" in order to open a bank account / get my Social Insurance Number / sign up for provincial health insurance / etc.

  25. Pietro said,

    April 27, 2018 @ 2:15 pm

    Re: "illegal gun seller". In that phrase, "illegal" clearly modifies "gun" and not "seller", which makes it a less than ideal analogy to what we're discussing. "Undocumented gun seller" would be especially odd in this case, not because undocumented is a poor synonym for illegal in all cases, but because it would make it seem that the guns themselves lack proper documentation when, in the narrow case described, the issue was the lack of necessary documentation regarding the seller himself.

  26. Doug said,

    April 27, 2018 @ 5:26 pm

    @Gregory Kusnick

    'Driving without a license is illegal (in J.W.'s broad sense), but few would argue that "unlicensed driver" is an unacceptable euphemism for "illegal driver".'

    I suspect that many people who oppose the term "undocumented immigrant" do so precisely because it sound analogous to things like "unlicensed driver" and therefore seems to imply that the infraction is a similar one, and could similarly be rectified by filling out some documents, paying a fee, passing a test, and the like.

  27. Gregory Kusnick said,

    April 27, 2018 @ 7:19 pm

    Doug: In my state*, you can go to jail for driving with a suspended license, which arguably makes it illegal in a stronger sense than entering the country without permission (which does not automatically entail a criminal charge).

    * This is, by the way, a state that happily issues driver's licenses to undocumented immigrants, provided they can establish their identity and demonstrate their competence.

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