DOCSLIB.ORG

Report on the Nomination of Judge Merrick B. Garland As an Associate Justice of the United States Supreme Court

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Report on the Nomination of Judge Merrick B. Garland As an Associate Justice of the United States Supreme Court REPORT ON THE NOMINATION OF JUDGE MERRICK B. GARLAND AS AN ASSOCIATE JUSTICE OF THE UNITED STATES SUPREME COURT May 5 2016 Th e Lawyers’ Committee for Civil Rights Under Law About the Lawyers’ Committee for civil rights Th e principal mission of the Lawyers’ Committee for Civil Rights Under Law is to secure equal justice for all through the rule of law, targeting in particular the inequities confronting African Americans and other racial and ethnic minorities. Th e Lawyers’ Committee is a nonpartisan, nonprofi t organization, formed in 1963 at the request of President John F. Kennedy to enlist the private bar’s leadership and resources in combating racial discrimination and the resulting inequality of opportunity – work that continues to be vital today. 1401 New York Avenue, NW, Suite 400 Washington, DC 20005 Phone: (202) 662-8600 Toll Free: (888) 299-5227 Fax: (202) 783-0857 ©2016. Th is publication is covered by the Creative Commons “Attribution” license (see http://cre- ativecommons.org). It may be reproduced in its entirety or modifi ed as long as the Lawyers’ Committee for Civil Rights Under Law is credited, a link to the license is included, and if changes were made to the original document, notifi cation that changes were made. 2 Th e Lawyers’ Committee for Civil Rights Under Law Judge Merrick Garland Chief Judge, U.S. Court of Appeals for the District of Columbia Circuit Nominated March 16, 2016 to United States Supreme Court 3 Th e Lawyers’ Committee for Civil Rights Under Law Table of Contents I. Executive Summary..................................................................................1 A. Judge Garland’s Jurisprudence in Civil Rights Cases.......................1 B. Jurisprudence on Criminal Justice...................................................2 C. Other Considerations......................................................................3 1. Experience and Education.....................................................3 2. Judicial Philosophy and Style.................................................3 D. Conclusion......................................................................................4 II. Th e Lawyers’ Committee’s Policy Regarding Nomintions To Th e Supreme Court........................................................................................................6 III. Biography..................................................................................................7 IV. Testimony From Previous Confi rmation Hearings....................................9 V. Analysis Of Judge Garland’s D.C. Circuit Opinions...............................11 A. Employment.................................................................................11 1. Title VII Cases.....................................................................12 2. Other Employment Cases....................................................15 B. Housing........................................................................................19 C. Voting Rights................................................................................21 D. Environmental Law and Environmental Justice............................24 E. Jurisprudence on Criminal Justice.................................................29 1. Overview.............................................................................29 2. General Criminal Appeals....................................................29 A. Ineff ective Assistance Claims......................................29 B. Other alleged Sentencing Errors................................31 C. Other Harmless Error And Procedural Affi rmances...33 3. Guantanamo Cases..............................................................34 4. Prisoners’ Rights/Prison Condition Cases............................35 VI. Other Sources Of Information................................................................38 VII. Judicial Diversity.....................................................................................40 4 Th e Lawyers’ Committee for Civil Rights Under Law I. executive summary On March 16, 2016, President Obama nominated Judge Merrick Garland, Chief Judge of the U.S. Court of Appeals for the District of Columbia Circuit, to the United States Supreme Court. Th is nomination followed the sudden death of Justice Antonin Scalia. Th e question of whether Judge Garland would be considered by the Senate in a presidential election year has been the subject of much public dialogue.1 Th is report focuses on Judge Garland as a nominee, and examines his record on issues central to the Lawyers’ Committee’s mission. As Judge Garland has been on the Court of Appeals for 18 years, the analysis is based primarily on the opinions he has authored or joined as a judge on that court. A. Judge Garland’s Jurisprudence in Civil Rights Cases We believe that Judge Garland has demonstrated views that are consistent with core civil rights principles. Most of the civil rights opinions he has authored are in employment cases. He has generally found grounds to overcome motions to dismiss. Th ese suggest support for the notion that cases alleging actionable discrimination should advance at least to the discovery stage. Opinions reviewing summary judgments and trial verdicts are mixed, with some favoring employees and some favoring employers. In other categories of civil rights cases – housing, voting, education and environmental justice – Judge Garland does not have as many written opinions. But those he has written are consistent with his opinions in employment cases. He supports the claims to the extent they are actionable under the relevant statute and binding precedent. We also note that safeguarding access to the courts is a key element of respect for civil rights. Th ere is no hint in Judge Garland’s written opinions of any interest on his part in creating judicial policy regarding discrimination beyond that established by clear precedent, apart from the indication that, in unsettled questions regarding statutory interpretation, he may be guided by a statute’s remedial purpose and other indications of legislative history and intent. As with all nominees, we believe that Judge Garland’s civil rights record is an area appropriate for evaluation during Senate hearings. 1 Th e Senate Republican leadership has reaffi rmed its intention not to consider the nomination. Other Senators, however, and approximately two-thirds of voters polled, favor a hearing for Judge Garland. 1 Th e Lawyers’ Committee for Civil Rights Under Law B. Jurisprudence on Criminal Justice With respect to the criminal justice issues currently in center focus for the Lawyers’ Committee – racial disparities in arrest, conviction and sentencing rates, clemency for nonviolent off enders, barriers to reentry, right to counsel, debtors’ prisons, etc. – Judge Garland has not written any opinions directly on point. With respect to the scores of opinions he has written in criminal appeals, however, he appears to lean toward an understanding of the cases from the perspective of the prosecutor. Th is is perhaps not surprising given the decade Judge Garland spent as a federal prosecutor. In any event, Judge Garland, in voting to affi rm criminal convictions about which questions were raised, has found many prosecutorial and judicial errors to have been “harmless.” He has also rejected claims of ineff ective assistance of counsel where he has found strong evidence of guilt, on the basis that even eff ective counsel could not have achieved an acquittal. Similarly, in cases reviewing departures up or down from mandatory sentencing guidelines, Judge Garland’s opinions show rigorous attention to what the statute does or does not permit to be considered, and very little to the equities of the individual defendant’s situation. His opinions tend not to create or expand any law or precedent favoring prosecutors as much as they fi nd a way to affi rm convictions on narrow grounds. Of particular concern for some progressives has been Judge Garland’s positions on appeals from detainees at Guantanamo. On the fi rst panel to hear such an appeal, Judge Garland joined a majority opinion holding that the District Court lacked jurisdiction to issue writs of habeas corpus to aliens detained outside the United States. Th at position was later reversed by the United States Supreme Court. Judge Garland has also ruled for the government in other Guantanamo cases, although in one opinion he found that the government had failed adequately to establish that a detainee was an enemy combatant. Related to the category of criminal justice, however, Judge Garland has shown appropriate sensitivity in prison condition cases to plaintiff s who appeared to have meritorious claims. 2 Th e Lawyers’ Committee for Civil Rights Under Law C. Other Considerations 1. Experience and Education After college (summa) and law school (magna) at Harvard, Judge Garland clerked- for Judge Henry Friendly and then Justice William Brennan. He then spent a year as an assistant to Attorney General Benjamin Civiletti, who said that Garland had a “resume that makes you cry.”2 His subsequent years as an associate and then a partner at Arnold & Porter, as a federal prosecutor in extremely high profi le cases and as a very well respected federal appellate judge for almost two decades also shape the experience he would likely bear as a jurist on the Court. 2. Judicial Philosophy and Style Th e hallmark of Judge Garland’s approach to resolving statutory claims is absolute fi delity to the intent of the statutory text, as
Load more

Recommended publications
  • US Policy Scan 2021
    US Policy Scan 2021 1 • US Policy Scan 2021 Introduction Welcome to Dentons 2021 Policy Scan, an in-depth look at policy a number of Members of Congress and Senators on both sides of at the Federal level and in each of the 50 states. This document the aisle and with a public exhausted by the anger and overheated is meant to be both a resource and a guide. A preview of the rhetoric that has characterized the last four years. key policy questions for the next year in the states, the House of Representatives, the Senate and the new Administration. A Nonetheless, with a Congress closely divided between the parties resource for tracking the people who will be driving change. and many millions of people who even now question the basic legitimacy of the process that led to Biden’s election, it remains to In addition to a dive into more than 15 policy areas, you will find be determined whether the President-elect’s goals are achievable brief profiles of Biden cabinet nominees and senior White House or whether, going forward, the Trump years have fundamentally staff appointees, the Congressional calendar, as well as the and permanently altered the manner in which political discourse Session dates and policy previews in State Houses across the will be conducted. What we can say with total confidence is that, in country. We discuss redistricting, preview the 2022 US Senate such a politically charged environment, it will take tremendous skill races and provide an overview of key decided and pending cases and determination on the part of the President-elect, along with a before the Supreme Court of the United States.
    [Show full text]
  • Entire Issue (PDF)
    E PL UR UM IB N U U S Congressional Record United States th of America PROCEEDINGS AND DEBATES OF THE 114 CONGRESS, SECOND SESSION Vol. 162 WASHINGTON, THURSDAY, MARCH 17, 2016 No. 43 House of Representatives The House met at 9 a.m. and was point of order that a quorum is not Gunny Stanton first began his train- called to order by the Speaker. present. ing, he attended the basic EOD course f The SPEAKER. Pursuant to clause 8, at Eglin Air Force Base. While in train- rule XX, further proceedings on this ing, his block tests and final examina- PRAYER question will be postponed. tion scores were so high that his The Chaplain, the Reverend Patrick The point of no quorum is considered records remain intact to this day. J. Conroy, offered the following prayer: withdrawn. In the course of his 18 years in the Marine Corps, Stanton earned many Merciful God, thank You for giving f us another day. awards too numerous to list in this Your care and wisdom are shown to PLEDGE OF ALLEGIANCE space. He is preceded in death by his fa- us by the way You extend Your king- The SPEAKER. Will the gentleman ther, Michael Dale Stanton Sr.; and a dom into our world down to the present from Texas (Mr. VEASEY) come forward brother, Brian Stanton. Gunny Stanton day. Your word reveals every aspect of and lead the House in the Pledge of Al- is survived by his loving family: his Your saving plan. You accomplish Your legiance. wife, Terri Stanton; his mother, Gloria designed purpose in and through the Mr.
    [Show full text]
  • FOR IMMEDIATE RELEASE August 3, 2012
    WLF News Release Washington Legal Foundation Advocate for freedom and justice® 2009 Massachusetts Avenue, NW Washington, DC 20036 202.588.0302 FOR IMMEDIATE RELEASE August 3, 2012 FORMER ATTORNEYS GENERAL URGE DISMISSAL OF CONSTITUTIONAL CHALLENGE TO FOREIGN SURVEILLANCE STATUTE (Clapper v. Amnesty International USA, No. 11-1025) A bipartisan group of six former Attorneys General yesterday urged the U.S. Supreme Court to throw out a lawsuit challenging the constitutionality of a 2008 federal statute that expanded the authority of federal officials to engage in overseas electronic surveillance. In a High Court brief drafted by the Washington Legal Foundation (which also joined in the brief), the group argued that allowing the case – filed by individuals and organizations that are not permissible surveillance targets – to proceed to trial threatens to interfere with efforts to protect national security. WLF’s brief was written with the substantial pro bono assistance of Megan Brown, Claire Evans, and Matthew Dowd of Washington, D.C.’s Wiley Rein LLP. The former Attorneys General who signed the brief were John D. Ashcroft, William P. Barr, Benjamin Civiletti, Edwin Meese III, Michael B. Mukasey, and Dick Thornburgh. The brief was filed in support of the Obama Administration, which has asked the Supreme Court to overturn a decision of the U.S. Court of Appeals for the Second Circuit reinstating the suit. WLF and its clients argued in their brief that the appeals court erred in concluding that the plaintiffs have suffered a cognizable injury and thus have standing to assert their claims. The Foreign Intelligence Surveillance Act (FISA), adopted by Congress in 1978, governs the conduct of “electronic surveillance” for national security purposes.
    [Show full text]
  • United States District Court for the District of Rhode Island
    Case 1:20-cv-00302-WES-LDA Document 8 Filed 07/22/21 Page 1 of 3 PageID #: <pageID> UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND ______________________________ ) FELIPE DUBON, ) ) Plaintiff, ) ) v. ) C.A. No. 20-302 WES ) MERRICK GARLAND1, et al., ) ) Defendants. ) ______________________________) MEMORANDUM AND ORDER Before the Court is Defendants’ Motion to Dismiss, ECF No. 5. Plaintiff filed this instant action after Defendants denied his Form I-212 Application for Permission to Reapply for Admission into the United States After Deportation or Removal. Compl. ¶ 1, ECF No. 1. He asks that this Court compel Defendants to “re- adjudicate his Form I-212” as it was “improperly decided.” Id. Defendants move to dismiss under Fed. R. Civ. P. 12(b)(1), 12(b)(3), and 12(b)6). For the reasons set forth below, the Court will GRANT the Defendants’ 12(b)(1) motion and dismiss the case for lack of jurisdiction. Federal courts are courts of limited jurisdiction and require a jurisdictional prerequisite, which “implicates a court’s 1 Merrick Garland is now the United States Attorney General. Pursuant to Fed. R. Civ. P. 25(d), U.S. Attorney General Merrick Garland has been substituted for U.S. Attorney General William Barr as Defendant. Case 1:20-cv-00302-WES-LDA Document 8 Filed 07/22/21 Page 2 of 3 PageID #: <pageID> constitutional and statutory power to hear and resolve a case.” Alphas Co., Inc. v. William H. Kopke, Jr., Inc., 708 F.3d 33, 36 (1st Cir. 2013). It is the plaintiff’s burden to prove this jurisdictional prerequisite and establish that the court has subject matter jurisdiction.
    [Show full text]
  • August 25, 2021 the Honorable Merrick Garland Attorney General
    MARK BRNOVICH DAVE YOST ARIZONA ATTORNEY GENERAL OHIO ATTORNEY GENERAL August 25, 2021 The Honorable Merrick Garland Attorney General 950 Pennsylvania Ave NW Washington, DC 20530-0001 Re: Constitutionality of Illegal Reentry Criminal Statute, 8 U.S.C. § 1326 Dear Attorney General Garland, We, the undersigned attorneys general, write as chief legal officers of our States to inquire about your intent to appeal the decision in United States v. Carrillo-Lopez, No. 3:20-cr- 00026-MMD-WGC, ECF. 60 (D. Nev. Aug. 18, 2021). As you know, in that decision, Chief Judge Du found unconstitutional 8 U.S.C. § 1326, the statute that criminalizes the illegal reentry of previously removed aliens. We appreciate that you recently filed a notice of appeal, preserving your ability to defend the law on appeal. We now urge you to follow through by defending the law before the Ninth Circuit and (if necessary) the Supreme Court. We ask that you confirm expeditiously DOJ’s intent to do so. Alternatively, if you do not intend to seek reversal of that decision and instead decide to cease prosecutions for illegal reentry in some or all of the country, we ask that you let us know, in writing, so that the undersigned can take appropriate action. Section 1326, as part of the Immigration and Nationality Act of 1952, is unremarkable in that it requires all aliens—no matter their race or country of origin—to enter the country lawfully. In finding the law racially discriminatory against “Latinx persons,” Chief Judge Du made some truly astounding claims, especially considering that, under the Immigration and Nationality Act, Mexico has more legal permanent residents in the United States, by far, than any other country.1 Chief Judge Du determined that, because most illegal reentrants at the border are from Mexico, the law has an impermissible “disparate impact” on Mexicans.
    [Show full text]
  • The Nomination of Chief Judge Merrick B. Garland to the Supreme Court of the United States
    THE NOMINATION OF CHIEF JUDGE MERRICK B. GARLAND TO THE SUPREME COURT OF THE UNITED STATES A REPORT BY THE NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. MAY 6, 2016 TABLE OF CONTENTS Introduction ................................................................................................................... 3 Background .................................................................................................................... 6 Early Life, Education, and Clerkships ...................................................................... 6 Private Practice and Initial Government Service ..................................................... 6 Clinton Justice Department ...................................................................................... 8 Nomination to the D.C. Circuit ............................................................................... 10 Service as a Judge .................................................................................................... 11 Employment and Housing Discrimination ................................................................. 13 Employment Discrimination .................................................................................... 13 Notable Cases ....................................................................................................... 13 Mixed Rulings ....................................................................................................... 18 Reversals ..............................................................................................................
    [Show full text]
  • Hon. Merrick Garland Attorney General of the United States United States Department of Justice 950 Pennsylvania Avenue, NW Washington, D.C
    Hon. Merrick Garland Attorney General of the United States United States Department of Justice 950 Pennsylvania Avenue, NW Washington, D.C. 20530 July 9, 2020 Re: Support for Granting Clemency to Individuals Placed on Home Confinement Pursuant the CARES Act Dear Attorney General Garland: I write on behalf of Law Enforcement Leaders to Reduce Crime & Incarceration, a national coalition including over 200 current and former law enforcement officials, across the political spectrum, dedicated to protecting public safety and reducing unnecessary incarceration. We are deeply troubled by the U.S. Department of Justice’s (“DOJ”) inaction as it pertains to the approximately 4,500 individuals who face the threat of reincarceration due to the prior administration’s January 15, 2021, Office of Legal Counsel memo (“OLC memo”). The OLC memo advises that these individuals — placed on home confinement pursuant the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act — be returned to full custody in federal prison upon the end of the COVID-19 pandemic.1 For the reasons outlined below, we respectfully urge the DOJ to recommend that President Biden grant clemency to these individuals, who have already been safely returned to their communities.2 Enacted by Congress in March of 2020, the CARES Act granted the Attorney General emergency authority to expand home confinement as long as emergency conditions “materially affect” the functioning of the Bureau of Prisons (BOP).3 As a result, Attorney General Bill Barr directed the BOP to place eligible incarcerated
    [Show full text]
  • June 7, 2021 the Honorable Merrick Garland Attorney General
    June 7, 2021 The Honorable Merrick Garland Attorney General of the United States The Department of Justice 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Cc: Joe Gaeta, Deputy Assistant Attorney General Dear Attorney General Garland, We write you today to follow up on a letter was sent to U.S. Attorney General William P. Barr on August 20, 2019. That correspondence is included as a separate attachment. We wrote at the time because we were concerned about reports regarding the involvement of agents of the United States Department of Justice (DOJ) in recent Brazilian prosecutorial and judicial proceedings which have generated substantial controversy and are perceived by many in Brazil as a threat to democracy and rule of law in that country. This issue is still of concern to us today. Regrettably, we did not receive a substantive response from Attorney General Barr to the questions we raised at the time. Given your demonstrated commitment to government transparency, rule of law and impartial justice in both the United States and throughout the world, we trust that you will respond to our earlier inquiries with more detail and substance. Since August of 2019, there have been important developments in Brazil. In March of this year, the Brazilian Supreme Federal Court (STF) annulled the outstanding convictions against former President Luiz Inácio Lula da Silva, also known as President Lula. These convictions resulted from a Brazilian prosecutorial and judicial process, also known as the Lava Jato operation, that raised serious questions about impartial justice and due process in the former President’s case.
    [Show full text]
  • In Search of the Solicitor Generalâ•Žs Clients
    LECTURE In Search of the Solicitor General's Clients: A Drama with Many Characters* By DREW S. DAYS m** I want, first, to express my sincerest appreciation for the invitation to deliver the Ninth Judge Mac Swinford Lecture at the University of Kentucky College ofLaw. It is a pleasure for me to get out ofWashing­ ton for a change - to begin with, to remind myself of what life is like "outside ofthe Beltway." I also saw this as an opportunity to see friends here at the law school whom I can no longer plan on encountering each year at the annual meeting ofthe Association ofAmerican Law Schools, since I am on leave from my law faculty. But, most importantly, there is a certain "rightness," I think, in being here as the Fortieth Solicitor General, since the first person to occupy my position was Benjamin H. Bristow, a Kentuckian.1 Benjamin H. Bristow, the first Solicitor General ofthe United States, was one of the leading lawyers of his generation. A Kentuckian, he served as a colonel during the Civil War. He later became United States Attomey for the District of Kentucky, where he was renowned for his vigor in enforcing the federal Civil Rights Acts.2 Before becoming Solicitor General in 1870, he practiced law with his fellow Kentuckian and future Supreme Court Justice, the first John Marshall Harlan.3 • This is an edited and embellished version ofthe Ninth Judge Mac Swinford Lecture, delivered at the University ofKentucky College ofLaw on November 10, 1994. •• Solicitor General of the United States. 1 BIOGRAPIDCAL DIRECTORY OF THE UNITED STAlES ExEcunvE BRANCH, 1774­ 1971, at 35-36 (Robert Sobel ed, 1971).
    [Show full text]
  • California Dnc Press Democrat
    CALIFORNIA DNC PRESS DEMOCRAT MAY 2017 PAGE 1 DNC CHAIR NAMES TRANSITION ADVISORY TEAM BY MICHAEL KAPP, DNC MEMBER At the end of February, the DNC met in Atlanta for our Winter Meeting. Our main responsibility was electing new DNC officers. For me, this meeting was a culmination of months of organizing and campaign- ing nationally for my can- didate for DNC Chair (and the clear favorite of Cali- fornia Democrats): Keith Ellison, the congressman from Minnesota. While the DNC elections California DNC Members in Atlanta did not turn out the way many California Demo- crats wanted (for the rec- ord, 18 out of 20 of Cali- DNC DEPUTY CHAIR PLAYS A SIGNIFICANT ROLE fornia’s elected DNC members voted for El- BY ALEX GALLARDO ROOKER AND KEITH UMEMOTO, DNC RBC MEMBERS lison), I was pleased that the first act of new DNC Chair Tom Perez was to New DNC National Chairper- specify that the Treasurer and ask the membership to son Tom Perez’s first act was to National Finance Chair are suspend the rules and get unanimous consent to have members of the DNC Budget appoint Keith Ellison as Rep. Keith Ellison named the and Finance Committee, but Deputy Chair. DNC’s Deputy Chair. that is essentially it. In March, Chair Perez What does it mean for Rep. Does this mean that Deputy announced a 36 member Ellison to be the DNC Deputy Chair Ellison holds a simply Transition Advisory Com- Chair? ceremonial position? No, there mittee that drew from The Charter and Bylaws of is precedence for having a Dep- Democratic leaders the Democratic Party of the uty Chair of the DNC, or in an- throughout the country.
    [Show full text]
  • Partners in Leadership
    I " r []J::; year::; UJ enjamin Civiletti was bone tired. At thirty-eight years of age, he was heading up the litigation department at one of Baltimore's most presti- gious law firms. The hours were long and the work challenging, yet Civiletti yearned for a change of pace. "I had been at Venable for thirteen years and I was starting to repeat myself," Civiletti says. "I had always appreciated public service, and I thought it was a good time to go in a different direction." That direction led Civiletti to the nation's capital, where President Jimmy Carter appointed him assistant attorney general of the United States. Civiletti earned this coveted Justice Department appointment as a result of experience trying cases with colleagues of Attorney General Griffin B. Bell. It was 1977, and Civiletti embarked on a four-year journey of public service to the country that saw him rise to deputy attorney general and ultimately to the top job of attorney general of the United States in 1979. He argued before the Supreme Court for the right of the government to denaturalize Nazi war criminals, and was the first attorney general to appear before the International Court of Justice at The Hague. "I thought it would be fun," Civiletti recalls of his decision to leave his practice and join the ranks of public servants. Looking back on his time in the Justice Department, he notes that the thrill of having access to the White House was tempered by the enormous responsibility of making decisions that affected the entire country.
    [Show full text]
  • Obscure but Powerful: Shaping U.S. Immigration Policy Through Attorney General Referral and Review
    RETHINKING U.S. IMMIGRATION POLICY INITIATIVE Obscure but Powerful Shaping U.S. Immigration Policy through Attorney General Referral and Review By Sarah Pierce U.S. IMMIGRATION POLICY PROGRAM Obscure but Powerful Shaping U.S. Immigration Policy through Attorney General Referral and Review By Sarah Pierce Migration Policy Institute January 2021 Contents Executive Summary ....................................................................................................................................... 1 1 Introduction .............................................................................................................................................. 2 2 History of the Attorney General’s Referral and Review Power ........................ 3 A. The Homeland Security Act and Its Effects .................................................................................................6 B. Referral and Review as an Administrative Tool .........................................................................................9 3 The Trump Administration’s Use of Self-Referral ...................................................... 12 A. Restricting Access to Asylum ............................................................................................................................13 B. Eliminating Immigration Judge Discretion ..............................................................................................17 4 The Future of Self-Referral .........................................................................................................
    [Show full text]