INTENT

“The legislature finds that there is a compelling interest in the cooperative enforcement of federal immigration laws throughout all of Arizona. The legislature declares that the intent of this act is to make attrition through enforcement the public policy of all state and local government agencies in Arizona. The provisions of this act are intended to work together to discourage and deter the unlawful entry and presence of aliens and economic activity by persons unlawfully present in the United States.”

ENFORCEMENT OF IMMIGRATION LAWS

The most controversial part of the new law empowers Arizona law enforcement officers to enforce federal immigration laws by detaining a person and determining his or her immigration status before release.  The law creates a presumption that certain forms of identification establish lawful status in the U.S.  Here’s what these sections of the law say:

“NO OFFICIAL OR AGENCY OF THIS STATE OR A COUNTY, CITY, TOWN OR OTHER POLITICAL SUBDIVISION OF THIS STATE MAY LIMIT OR RESTRICT THE ENFORCEMENT OF FEDERAL IMMIGRATION LAWS TO LESS THAN THE FULL EXTENT PERMITTED BY FEDERAL LAW.  FOR ANY LAWFUL CONTACT MADE BY A LAW ENFORCEMENT OFFICIAL OR A LAW ENFORCEMENT AGENCY OF THIS STATE OR A LAW ENFORCEMENT OFFICIAL OR A LAW ENFORCEMENT AGENCY OF A COUNTY, CITY, TOWN OR OTHER POLITICAL SUBDIVISION OF THIS STATE WHERE REASONABLE SUSPICION EXISTS THAT THE PERSON IS AN ALIEN WHO IS UNLAWFULLY PRESENT IN THE UNITED STATES, A REASONABLE ATTEMPT SHALL BE MADE, WHEN PRACTICABLE, TO DETERMINE THE IMMIGRATION STATUS OF THE PERSON, EXCEPT IF THE DETERMINATION MAY HINDER OR OBSTRUCT AN INVESTIGATION. ANY PERSON WHO IS ARRESTED SHALL HAVE THE PERSON’S IMMIGRATION STATUS DETERMINED BEFORE THE PERSON IS RELEASED. THE PERSON’S IMMIGRATION STATUS SHALL BE VERIFIED WITH THE FEDERAL GOVERNMENT PURSUANT TO 8 UNITED STATES CODE SECTION 1373(C). A LAW ENFORCEMENT OFFICIAL OR AGENCY OF THIS STATE OR A COUNTY, CITY, TOWN OR OTHER POLITICAL SUBDIVISION OF THIS STATE MAY NOT SOLELY CONSIDER RACE, COLOR OR NATIONAL ORIGIN IN IMPLEMENTING THE REQUIREMENTS OF THIS SUBSECTION EXCEPT TO THE EXTENT PERMITTED BY THE UNITED STATES OR ARIZONA CONSTITUTION. A PERSON IS PRESUMED TO NOT BE AN ALIEN WHO IS UNLAWFULLY PRESENT IN THE UNITED STATES IF THE PERSON
PROVIDES TO THE LAW ENFORCEMENT OFFICER OR AGENCY ANY OF THE FOLLOWING:

1. A VALID ARIZONA DRIVER LICENSE.
2. A VALID ARIZONA NONOPERATING IDENTIFICATION LICENSE.
3. A VALID TRIBAL ENROLLMENT CARD OR OTHER FORM OF TRIBAL IDENTIFICATION.
4. IF THE ENTITY REQUIRES PROOF OF LEGAL PRESENCE IN THE UNITED STATES BEFORE ISSUANCE, ANY VALID UNITED STATES FEDERAL, STATE OR LOCAL GOVERNMENT ISSUED IDENTIFICATION.”

The new law then requires Arizona officials to contact federal immigration officials whenever it is determined that a detainee is here unlawfully.  A court order must be obtained if Arizona officials must travel outside of Arizona to transport and present a detainee to federal immigration officials.

EXCHANGING INFORMATION

Senate Bill 1070 allows officials to send, receive and maintain information about a person’s immigration status for the following purposes:

1. DETERMINING ELIGIBILITY FOR ANY PUBLIC BENEFIT, SERVICE OR LICENSE PROVIDED BY ANY FEDERAL, STATE, LOCAL OR OTHER POLITICAL SUBDIVISION OF THIS STATE.
2. VERIFYING ANY CLAIM OF RESIDENCE OR DOMICILE IF DETERMINATION OF RESIDENCE OR DOMICILE IS REQUIRED UNDER THE LAWS OF THIS STATE OR A JUDICIAL ORDER ISSUED PURSUANT TO A CIVIL OR CRIMINAL PROCEEDING IN THIS STATE.
3. IF THE PERSON IS AN ALIEN, DETERMINING WHETHER THE PERSON IS IN COMPLIANCE WITH THE FEDERAL REGISTRATION LAWS PRESCRIBED BY TITLE II, CHAPTER 7 OF THE FEDERAL IMMIGRATION AND NATIONALITY ACT.
4. PURSUANT TO 8 UNITED STATES CODE SECTION 1373 AND 8 UNITED STATES CODE SECTION 1644.

ARIZONA RESIDENTS CAN ENFORCE NEW LAW

An Arizona resident can obtain a court order to compell a government official to enforce the new law.  Any Arizona official failing to enforce the new law is subject to penalties of upto $5,000 per day per violation.  The penalties collected are to be deposited into and used for the GANG AND IMMIGRATION INTELLIGENCE TEAM ENFORCEMENT MISSION FUND. A court can also award attorneys’ fees and costs.

STATE CRIME

Under the new Arizona law, it is a crime to be present in Arizona in violation of federal immigration law.  The penalties for violating this new Arizona law include:
1.    Imprisonment
2.    Jail costs And other assessments
3.    Monetary penalties, starting at $500 for the first vilation
4.    Much greater penalties, if a person violates the Arizona law while commiting another crime, such as using, distributing or transporting drugs, for example.

HIRING, TRANSPORTING, AIDING & CONCEALING ILLEGAL IMMIGRANTS

It is unlawful to stop a car on a street to hire an illegal immigrant worker.  Similarly, an illegal immigrant workercannot seek work, either as an employee or independent contractor.  It is also illegal now to transport, move, conceal, harbour, sheild or aid an illigal immigrant in Arizona.  Nor can anyone encourage or enduce an illigal immigrant to come to Arizona under Senate Bill 1070.  The statute contains a detailed process for investigating and prosecuting violations of these prohibitions.  The penalties become more severare for knowing or multiple violations of therse new rules.  For example, on a second violation, an employer could lose all its state licenses and ordered to cease operations in Ariozona.  An employer can rely on the federal government’s e-verify program, which creates a rebuttable presumption that an employer did not knowingly employ an unauthorized alien.  Employers can assert a defense, if the employer has complied in good faith with certain requirements under federal law or the employer can demonstrate that it was entrapped.  An entrappment defense is detailed in the new law.

IMPOUNDMENT OF A VEHICLE

A vehicle used to violate the new law, such as transporting an illigal immigrant through Arizona, can be immobilization or impounded.  The driver’s license can be suspended or revoked for any reason.

NAME & EFFECTIVE DATE

The new Arizona law is called the “Support Our Law Enforcement and Safe Neighborhoods Act.”  It was approved by the Arizona Governor on April 23, 2010.

On March 31, 2010, the United States Supreme Court issued its decision in the case of Padilla v. Kentucky, holding that criminal defense attorneys must advise their noncitizen clients about the risk of deportation if they accept a guilty plea.

The case involved the Petitioner, Mr. Padilla, a lawful permanent resident of the United States for over 40 years, who faced deportation after he pled guilty to drug distribution charges in Kentucky.  Mr. Padilla filed for post-conviction relief claiming that his counsel failed to advise him of the immigration consequences to his guilty plea and told him not to worry about deportation since he had lived in the United States for so long.  Mr. Padilla alleged that had he not received incorrect advice, he would have gone to trial.

The Kentucky Supreme Court denied Mr. Padilla’s request for post-conviction relief citing that the Sixth Amendment’s effective assistance of counsel guarantee does not protect a defendant from erroneous deportation advice because deportation is only a “collateral” consequence of conviction.

In its ruling, the United States Supreme Court recognized the dramatic changes in immigration law over the years which have raised the stakes of a noncitizen’s criminal conviction. Where there was once only a small class of deportable offenses and judges had broad discretionary authority to prevent the deportation of an individual, changes in immigration laws have led to an expanded class of deportable offenses and have resulted in limited discretionary authority of judges to prevent the harsh consequences of deportation. Because deportation is now almost inevitable for a great number of noncitizens convicted of crimes, it is more than ever important for noncitizens to have accurate legal advice. The Court determined that deportation is not merely a “collateral” consequence of a conviction. Rather, it is an essential part of the penalty that may be imposed upon noncitizen defendants who plead guilty to certain crimes.

In the past few days, four additional rank-and-file Democrats have announced their opposition to Obama’s healthcare plan being pushed by Democrats. Reps. Ben Chandler of Kentucky, Luiz Gutierrez of Illinois, Stephanie Herseth-Sandlin of South Dakota and Heath Shuler of North Carolina now are indicating that they will vote against their party’s health care plan. The plan could be subject to an “up or down” vote late next week or later.

For a few Congressmen, immigration issues are having a huge impact on the healthcare debate. “At this time, I am a ‘no’ vote on health care,” said Gutierrez in a written statement. “It’s no secret that I have been critical of proposals that would exclude our nation’s hardworking immigrants from the health care exchange, and I would find it extremely difficult, if not impossible, to vote for any measure that denies undocumented workers health care purchased with their own dollars.”

Immigration advocates met with Mr. Obama this week and are planning rallies later this month in Washington, D.C.

In addition to providing aid to Haiti, on January 15, 2010, the United States government designated Haiti for Temporary Protected Status (TPS) which is a country designation to help Haitian nationals in the United States who are unable to return to Haiti due to the recent earthquake. A country is given TPS designation because temporary conditions such as ongoing armed conflict, environmental disaster or other extraordinary circumstances prevent nationals of a particular country from returning safely to their home.

To qualify for Haitian TPS, one must:
1. Be a national of Haiti or one with no nationality who last habitually resided in Haiti and have resided continuously in the United States since January 12, 2010;
2. Not have been convicted of a felony or of 2 or more misdemeanors in the United States;
3. Have been continuously present in the United States since January 21, 2010 and meet certain immigrant admissibility and TPS eligibility requirements; and
4. Complete all TPS application procedures according to the Federal Register notice announcing TPS for Haiti.

The TPS registration period began on January 21, 2010 and will continue for 180 days from that date. Filing for TPS must occur during the 180 day registration period and the application package must be postmarked on or before the last day of the registration period.

It is important to have a thorough and well documented packet when applying for TPS. The success of a TPS application will depend on the details contained in the packet.

We’re going to crack down on violations of equal pay laws — so that women get equal pay for an equal day’s work. And we should continue the work of fixing our broken immigration system — to secure our borders and enforce our laws and ensure that everyone who plays by the rules can contribute to our economy and enrich our nation.

In the end, it’s our ideals, our values that built America — values that allowed us to forge a nation made up of immigrants from every corner of the globe, values that drive our citizens still. Every day, Americans meet their responsibilities to their families and their employers. Time and again, they lend a hand to their neighbors and give back to their country. They take pride in their labor and are generous in spirit. These aren’t Republican values or Democratic values that they’re living by, business values or labor values. They’re American values.

Many immigration advocates were disappointed in the lack of details in the President’s SOTU address.  Clearly, the financial crisis, the war in Iraq and Afghanistan and the Health Care debate have dominated President Obama’s agenda, even though Candidate Obama stressed the importance of immigration reform as a critical issue facing the country.  After the Republican win in Massachusetts, which enables Republicans to block the 60-vote super-majority the Democrats had previously enjoyed in the Senate, the President is changing his legislative priorities.  It now appears that the President intends to devote his attention to job creation and expanding government programs in transportation and energy consumption.  That will push immigration reform lower on the list of priorities and will likely delay immigration reform for another year or longer.

These diseases include the following:

Hepatitis B

Influenza Type B

Mumps

Measles

Pertussis

Polio

Rubella

Tetanus and Diphtheria Toxoids

And any other vaccine-preventable diseases recommended by the Advisory Committee for Immunization Practices (ACIP).  Vaccines against herpes zoster (zoster) and HPV are no longer required vaccines effective December 14, 2009.

The ACIP is an advisory committee to the Department of Health and Human Services (HHS)/Centers for Disease Control and Prevention (CDC) whose responsibility is to recommend immunizations for the general U.S. population.  Beginning December 14, 2009, when the ACIP recommends new vaccines for the general U.S. population, CDC will determine if these recommended vaccines should be required for immigration purposes on a regular basis and on an as needed basis, in addition to those specifically listed in the INA.  In making the determination, the CDC applies the following criteria:

• the vaccine must be an age-appropriate vaccine as recommended by the ACIP for the

general U.S. population, and at least one of the following:

• the vaccine must protect against a disease that has the potential to cause an outbreak;

OR

• the vaccine must protect against a disease eliminated in the United States, or is in the

process of being eliminated in the United States.

The CDC publishes the Technical Instruction for the Medical Examination of Aliens

in the United States (Technical Instructions), which can be found at www.cdc.gov/ncidod/dq/civil.htm.  These instructions set the requirements for the immigrant medical examination and are binding on civil surgeons who conduct these examinations. The Technical Instructions include a vaccination component which specify the requirements for civil surgeons when conducting the vaccination assessment.

The civil surgeon will review an applicant’s vaccination records at the time of the examination and will determine if the applicant has had disease preventing vaccinations appropriate for his or her age category.  It is therefore important for the applicant to have on hand documentation of their vaccination records.  If an applicant is immune to certain vaccinations or has a medical condition that the applicant cannot receive certain vaccinations, the applicant should provide documentation of this as well.  The civil surgeon will administer those vaccines which the applicant had not previously received and which the applicant is able to receive based upon the applicant’s vaccination and medical history.  The applicant is responsible for paying the civil surgeon for the vaccines.  An applicant may also choose to have their healthcare provider administer the vaccine; however, only a civil surgeon is authorized the vaccination assessment.  The applicant must therefore return to the civil surgeon with proof that their healthcare provider did administer the vaccine.  The results of the medical examination as well as the vaccination assessment are recorded by the civil surgeon on USCIS Form I-693, Report of Medical Examination and Vaccination Record.  If an applicant refuses to receive vaccines required for immigration purposes, the applicant’s request for immigration benefits may be denied.  The applicant should inform the civil surgeon of the reason for the refusal and a waiver may be available to the applicant.  Waivers are available in the following circumstances:

• the applicant is opposed to vaccinations in ANY form– meaning the applicant cannot obtain a waiver based on an objection only as to one vaccination;
• the applicant’s objection must be based on religious beliefs or moral convictions; and
• the applicant’s religious or moral beliefs must be sincere.

If one is applying for an immigrant visa abroad, s(he) must  receive a medical examination by a panel physician designated by the U.S. Department of State (DOS).  The CDC issues separate instructions to panel physicians abroad on how to conduct medical examinations.

Information about vaccinations in general can be found at www.cdc.gov/vaccines or, for information about vaccine requirements for immigration purposes, at www.cdc.gov/ncidod/dq/civil.htm.

Who is “Balloon Boy?,” others are asking.

Balloon Boy references the hoax that occurred on October 15, 2009, in Fort Colline, Colorado, when the parents of a six-year-old boy, Falcon Heene, claimed the boy floated away in a homemade balloon.  At the time, it was reported that the boy was traveling in the balloon at altitudes reaching 7,000 feet (2,100 m).  Falcon was nicknamed “Balloon Boy” by the media following the story.

After hours in a flight that coveved more than 50 miles across three counties, the balloon landed about 12 miles (19 km) northeast of Denver International Airport.  Authorities closed down the Denver airport, and sent several National Guard helicopters and local police in pursuit.  After the balloon landed and the boy was found not to be inside it, authorities began a manhunt of the entire area.  Their fear was that he had fallen from the balloon while in flight.  Later that afternoon, the boy was reported to have been hiding at his house the entire time.

Eventually, it was discovered that the incident was a hoax and publicity stunt staged by the boy’s father, Richard Heene.  On October 18, 2009, the local sheriff decided that the parents would likely face several felony charges.  The sheriff also expressed his intent to recover the more than $62,000 spent in the search and rescue effort.

Immigration Law Impacted the Guilty Plea.

On November 12, 2009, an attorney for both parents announced that they intended to plead guilty to charges filed against them.  In exchange, the prosecutor would recommend probation.  The attorney’s statement said that the threat of deportation of Balloon Boy’s mother, Mayumi Heene, who is a Japanese citizen, was a factor in the plea negotiations.  On November 13, Richard Heene pleaded guilty to a felony charge of attempting to influence a public servant.  The mother, Mayumi Heene, did not appear with him, and will face a misdemeanor charge of false reporting to authorities.  Another hearing in the case is scheduled for mid-December.

What is significant about the case of Balloon Boy from an immigration law perspective is the fact that criminal convictions can impact a person’s immigration status.  In the case of  Mayumi Heene, she could have been subject to mandatory deportation, had she been tried and convicted of a major felony.  In her case and the case of many other immigrants, it is often necessary to prevent deportation by pleading to a lesser crime as a strategy to reduce the chances of being tried and convicted of a more serious crime.  Often, this is the case where an innocent immigrant lacks the funds necessary to present an adequate defense.  An immigrant facing a felony charges should weigh the risks of a felony conviction and deportation against the odds of gaining an acquital.

Criminal Defense Attorneys Need to Consult With Immigration Counsel

Criminal defense attorneys often fail to consider or properly weigh the impact a criminal conviction can have on an immigrant’s immigration status.  The extent to which a criminal attorney should consider the impact of a client’s immigration status is currently before the United States Supreme Court.  On February 23, 2009, the Supreme Court granted certiorari in Commonwealth v. Padilla, 253 S.W.3d 482 (Ky. 2008), cert. granted, 2009 U.S. LEXIS 1453 (U.S. Feb. 23, 2009) (No. 08-651).   The issue in the case is whether criminal defense counsel must inform a client of the immigration consequences of a plea and if not, whether counsel’s gross misadvice about the consequences is a ground for setting aside a plea.  Specifically, the Court will address:

1.       Whether the mandatory deportation consequences that stem from a plea to trafficking in marijuana, an “aggravated felony” under the Immigration & Nationality Act, is a “collateral consequence” of a criminal conviction which relieves counsel from any affirmative duty to investigate and advise; and

2.       Assuming immigration consequences are “collateral”, whether counsel’s gross misadvice as to the collateral consequence of deportation can constitute a ground for setting aside a guilty plea which was induced by that faulty advice.

The Kentucky Supreme Court’s position on whether the petitioner should be allowed to seek post-conviction relief represents the minority view.  The majority of state and federal courts that have ruled on the issue have held that misadvice can be ineffective assistance of counsel, even in jurisdictions where there is no affirmative duty to advise defendants of the immigration consequences of a plea.

The Court heard oral arguments on October 13, 2009.

I am pleased to announce that the Widow’s Penalty has finally come to an end.

The Congress recently approved the Department of Homeland Security Appropriations Conference Report (HR 2892), which included an amendment to abolish the Widow’s Penalty.  President Obama signed it into law.  The new law has finally end the Widow’s Penalty.

The new law means that the death of a U.S. citizen spouse will no longer result in automatic deportation of widows, widowers and their children.  The new law eliminates the two-year marriage requirement, permitting widows and widowers of U.S. citizens to apply for a green card for themselves and on behalf of their foreign-born children.  It is also retroactive so anyone qualifying for relief can file a petition for permanent residency up to two years after passage of the measure.

Tiffany U. Vivo is an Indianapolis immigration lawyer.  She also practices family law.  Ms. Vivo appears before the Immigration Court (EOIR), the United States Citizenship & Immigration Service (USCIS), the Board of Immigration Appeals (BIA) and state and federal courts in Indiana and Illinois.  She is a member of the Indiana State Bar, and the national and local chapters of the American Immigration Lawyers Association (AILA).   Her immigration law offices are located in Indianapolis, from where she serves immigration clients across the country.

MS. VIVO’S ANSWER:       Yes, you need a K1 or “Fiancée Visa.”  It takes some time to acquire a Fiancée Visa, and that process frustrating.  So, be patient and follow the instructions of a qualified and knowledgeable immigration attorney.

Often, a couple will have to wait up to six months before being granted preliminary approval from the United States Citizenship and Immigration Service (“USCIS”).  After approval, an application for a K1 Visa is sent to the National Visa Center and then finally, in the case of a Filipina fiancée visa application, to the United States Embassy in Manila.  Again, the process can be long and frustrating.  But, hopefully and is the case most often, the wait ultimately results in the issuance of a valid K1 fiancée visa.

After the visa is issued, engaged couples often become concerned about the information and dates printed on the visa itself.  For example, the visa states: “K-1 Petition Expires on MM DD, YYYY.”  Couples often mistakenly believe that this is the end of the visa’s validity.  What is really the case is that the visa is valid for travel to the USA until the expiration date expressly stated on the visa.  Usually, a K1 visa is issued with a validity of six months.  The Consular Officer adjudicating the case at the United States Embassy in Manila has discretion to issue a visa with a shorter validity period.

A K1 visa is valid for six months after it is issued.  After your fiancée arrives in the United States and after she is admitted at the port of entry, she is only entitled to 90 days presence in the United States.  If you and your fiancée get married, you should then apply for adjustment of her status.  She would be entitled to remain indefinitely, provided the adjustment of status is approved and any conditions are lifted.  

If you and your Filipina fiancée do not marry while she is in the United States, she will need to depart the U.S. before the visa’s expiration.

In circumstances where a Petition is based upon marriage to a U.S. citizen, a foreign fiancé(e) has to pass scrutiny by the U.S. government, whose purpose is to determine whether the parties entered into a bona fide marriage.  In other words, the U.S. government will want to ensure that the couple married for love and not for immigration reasons.  Essentially, the inquiry begins when a U.S. citizen petitions a foreign fiancé(e) through a K-1 visa.  The Petition is filed with the United States Citizenship & Immigration Services (USCIS), which then refers the Petition to the National Visa Center (NVC).  The NVC forwards the Petition to the U.S. Consulate of the foreign fiancé(e)’s residence who is responsible for interviewing the fiancé(e) to determine the true intent of the couple.  The Consular Officer will ask a number of questions of the fiancé(e) and will require certain documents to be submitted to support the couple’s intentions to marry.  If the Consular Officer is satisfied, a K1 visa is issued to the foreign fiancé(e) to travel to the United States.  A visa, however, will not always guarantee the fiancé(e) entry into the United States.  Agents of the Department of Homeland Security (DHS), who will meet the arriving fiancé(e) at the port of entry, will have to determine if the fiancé(e) is admissible according to immigration laws.

If granted entry into the United States, the U.S. citizen and foreign fiancé(e) have 90 days to get married.  If the marriage does not occur within that timeframe, the foreign fiancé(e) becomes out of status.  The K1 visa is sponsor specific, so a foreign fiancé(e) who does not marry the original petitioning U.S. citizen cannot use the same visa to marry another U.S. citizen.  Once married to the U.S. citizen spouse, the foreign fiancé(e) will be eligible to apply for permanent resident status and obtain a green card.  If approved, the permanent resident status and the green card that is issued are conditional, which means that the couple must file another Petition with the USCIS to lift the conditions of that status.  The Petition must be filed within 2 years of the conditional green card being issued or as early as 90 days prior to the expiration of the conditional green card.  If the couple’s request to lift the conditions of the green card is granted, the foreign spouse will receive the 10 year unconditional green card.  The foreign spouse will be eligible to file for U.S. citizenship within 3 years of being issued the conditional green card or as early as 90 days before the 3 year date for eligibility.

So, what happens if the U.S. citizen spouse dies before either the conditional green card is issued or the conditions of the green card are not lifted?  The “Widow’s Penalty” places the immigrating spouse in a difficult position.  As a result of the untimely death of the U.S. citizen spouse, the foreign spouse, now a widow(er), could be considered out of status because he or she is no longer married to the U.S. citizen spouse.  This seems a harsh consequence for the foreign widow(er)s, and the U.S. Federal Courts and DHS have taken a sympathetic approach to addressing these unfortunate circumstances by allowing foreign widow(er)s to remain in the United States, deferring inspection and granting amnesty-like relief to those who find themselves in this difficult situation.  The application of the law continues to be arbitrary and conflicting.  However, the Courts appear to be moving towards favoring eliminating this harsh penalty in an effort to promote fairness to the innocent immigrant spouses already residing in the United States.

Tiffany U. Vivo is an Indianapolis immigration lawyer.  She also practices family law.  Ms. Vivo appears before the Immigration Court (EOIR), the United States Citizenship & Immigration Service (USCIS), the Board of Immigration Appeals (BIA) and state and federal courts in Indiana and Illinois.  She is a member of the Indiana State Bar, the Indianapolis Bar Association, and the national and local chapters of the American Immigration Lawyers Association (AILA).