Mr Cogito on the Need for Precision, Zbigniew Herbert, 1983

This post is dedicated to the memory of the refugees and migrants who died en route

Polish poet Zbigniew Herbert (1924-1998) first included Mr Cogito on the Need for Precision (Pan Cogito o potrzebie ścisłości) in the 1983 collection Report From The Besieged City and Other Poems (Raport z obłężonego miasta i inne wiersze). A commentary on the situation in Poland following the imposition of the martial law on 13 December 1981, the book was published in Paris and did not become officially available in Poland until 1992.

Mr Cogito on the Need for Precision is often quoted in works on the role of memory in the aftermath of widespread serious human rights violations (see, for example, this blog post by Patrick Krup). More practically, I like to think about it as a manifesto for accuracy and documentation in human rights work.


 

1

Mr Cogito
is alarmed by a problem
in the domain of applied mathematics

the difficulties we encounter
with operations of simple arithmetic

children are lucky
they add apple to apple
subtract grain from grain
the sum is correct
the kindergarten of the world
pulsates with a safe warmth

particles of matter have been measured
heavenly bodies weighed
and only in human affairs
inexcusable carelessness reigns supreme
the lack of precise information

over the immensity of history
wheels a spectre
the spectre of indefiniteness

How many Greeks were killed at Troy
– we don’t know

to give the exact casualties
on both sides
in the Battle of Gaugamela
at Agincourt
Leipzig
Kutno

And also the number of victims
of terror
of the white
the red
the brown
– O colours innocent colours –

– we don’t know
truly we don’t know

Mr Cogito
rejects the sensible explanation
that it was long ago
the wind has thoroughly mixed the ashes
the blood flowed to the sea

sensible explanations
intensify the alarm
of Mr Cogito

because even what
is happening under our eyes
evades numbers
loses the human dimension

somewhere there must be an error
a fatal defect in our tools
or a sin of memory

2

a few simple examples
from the accounting of victims

in an aeroplane disaster
it is easy to establish
the exact number of the dead

important for heirs
and those plunged in grief
the insurance companies

We take the list of passengers
and the crew
next to each name
we place a little cross

it is slightly harder
in the case
of train accidents

bodies torn to pieces
have to be put back together
so no head
remains ownerless

during elemental
catastrophes
the arithmetic
becomes complicated

we count those who are saved
but the unknown remainder
neither alive
nor definitely dead
is described by a strange term
the missing

they still have the chance
to return to us
from fire
from water
the interior of the earth

if they return – that’s fine
if they don’t – too bad

 

3

now Mr Cogito
climbs
to the highest tottering
step of indefiniteness

how difficult it is to establish the names
of all those who perished
in the struggle with inhuman power

the official statistics
reduce their number
once again pitilessly
they decimate those who have died a violent death
and their bodies disappear
in the abysmal cellars
of huge police buildings

eyewitnesses
blinded by gas
deafened by salvos
by fear and despair
are inclined toward exaggeration

accidental observers
give doubtful figures
accompanied by the shameful
word ‘about’

and yet in these matters
accuracy is essential
we must not be wrong
even by a single one

we are despite everything
the guardians of our brothers

ignorance about those who have disappeared
undermines the reality of the world

it thrusts into the hell of appearances
the devilish net of dialectics
proclaiming there is no difference
between the substance and the spectre

therefore we have to know
to count exactly
call by the first name
provide for a journey

in a bowl of clay
millet poppy seeds
a bone comb
arrowheads
and a ring of faithfulness

amulets

Zbigniew Herbert, ‘Mr Cogito on the Need for Precision’, in Report from the Besieged City and Other Poems, Translated with and Introduction and Notes by John Carpenter and Bogdana Carpenter, Oxford University Press 1987


 

For additional information on the human rights violations during the Polish martial law, see Amnesty International’s Annual Report 1982 (p280-285) and Annual Report 1983 (p265-270).

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Global #migration and #refugee governance outlook 2016

Thank you to Stefan Rother for this precious advocacy diary!

The GFMD, Migration, Development and Human Rights

GFMD Bangladesh“2016 has well become THE migrant year”, stated Peter Sutherland, UN Secretary Generals’ Special Representative for International Migration, in a recent webinar. Obviously, migration has been brought to the top of the international agenda for some time now, but this year will see a number of high-level events addressing the issue. This post will provide an overview – without neglecting the agency of migrants and their organizations themselves and their upcoming events.

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The EU is in dangerous territory with “safe” country lists for asylum-seekers

Lampedusa (Photo: noborder network/ Sara Prestianni)

Lampedusa (Photo: noborder network/ Sara Prestianni)

On 20 July the EU Justice and Home Affairs Council recommended that EU member states assess whether to include Western Balkan countries (Albania, Bosnia and Herzegovina, the former Yugoslav Republic of Macedonia, Montenegro, Serbia and Kosovo) in a possible common EU list of “safe countries of origin”. However, the “safe countries of origin” concept has little to do either with EU member states’ human rights obligations or with an evidence-based, rational assessment of the current reality of asylum in Europe.

Since 2005, EU law allows member states to designate certain countries as “safe” to make the asylum process quicker and cheaper. The asylum applications of those from “safe” countries can be examined at the border or in transit zones and in fast-track procedures. But quick and cheap can come at the expense of legality and fairness.

“Safe countries of origin” procedures are inherently unfair. The general presumption is that a country on the “safe” list does not “normally” produce refugees, so its nationals’ asylum claims are unfounded. It is up to the asylum seeker to prove otherwise – which is difficult to do, since documents and other evidence are often lost during long and turbulent journeys. The task becomes almost impossible since national accelerated procedures for “safe” countries impose strict time limits, which can be as short as two or three days.

Not only is this unfair; it is inherently discriminatory. What “safe countries of origin” procedures ultimately boil down to is that some asylum seekers are presumed to be bogus solely on the basis of their nationality. The prohibition of discrimination based on nationality is one of the most fundamental principles of international law, recognized in the EU Charter of Fundamental Rights and numerous others international agreements. Only three days after the EU decision, Canada’s Federal Court struck down as unconstitutional and discriminatory a government decision to designate 26 EU countries and the USA as “safe countries of origin” (2015 FC 892).

The assumption that people coming from certain countries do not need protection because their country is inherently “safe” runs against one of the key foundations of refugee law, i.e. the individual nature of the need for international protection. The idea that someone’s risk of being persecuted may be assessed on the basis of whether or not there is “generally” persecution in their country is simplistic. In fact, specific individuals (journalists, lawyers, opposition leaders, human rights defenders or members of ethnic or religious minorities) face persecution exactly because of what makes them the individual that they are: their gender, race, ethnicity, political and religious beliefs, sexual orientation, etc.

For this reason, even countries that portray themselves as “generally safe” can produce asylum seekers and refugees. EU countries are no exception. According to the UN Refugee Agency (UNHCR), at the end of 2014 nearly 50,000 people from the 28 EU member states had been recognized as refugees around the world, while a further 3,000 EU nationals were waiting for their asylum case to be decided (source: UNHCR Global Trends 2014).

With respect to Western Balkan countries, the EU decision ignores that in 2014 the French Conseil d’Etat and the Belgian Conseil d’Etat respectively withdrew Kosovo and Albania from their country’s list of “safe countries of origin”. The decision also ignores the fact that in certain states within the Balkans, specific groups may be at real risk of persecution. Few countries are, for example, able to provide LGBTI people or independent journalists whose lives are at risk with adequate protection. In Kosovo, UNHCR has identified a number of groups at “particular risk of persecution or serious harm… including through cumulative discriminatory acts”, including Serbs and Albanians in a minority situation and Roma.

So, if there is no such thing as a “safe country of origin”, what was behind the EU decision to potentially consider Western Balkan states as “safe”? The decision mentions these countries’ “European perspective” and the fact that their nationals are exempt from visa requirements. In other words, Western Balkans countries may be considered to be “safe” merely because they are or may become candidates for EU accession, not because of their ability to respect, protect and promote human rights. The arbitrary nature of any determination of “safe countries of origin”, either at the EU or at the national level, is evident.

In sum, “safe countries of origin” procedures are unfair, unlawful and absurd. The possible selection of Western Balkans countries is superficial and arbitrary. The very substantive danger of returning to persecution someone whose asylum claim is valid should outweigh any consideration based on expediency.

Thank you to: Nicola Delvino, Conor Fortune, Sian Jones and Anna Shea.

How to cite this article:
Francesca Pizzutelli, “The EU is in dangerous territory with “safe” country list for asylum-seekers”, The Rights Angle, https://therightsangle.wordpress.com/, 24 July 2015.

Link

Written submissions on behalf of Amnesty International acting as amicus curiae in the case of Amjad Hussein v Labour Court before the Supreme Court of Ireland

The issue of principle which Amnesty International wishes to address is whether an irregular migrant worker is prohibited from obtaining redress against his or her employer where their contract of employment was not permitted under domestic legislation. Amnesty International submits that the common law doctrine of illegality does allow for the protection of irregular migrant workers in contract and/or tort law where they are exploited by their employer.

The human rights of migrants as limitations to states’ control over entry and stay in their territory

(C) Valerio Rinaldi for Amnesty International

(C) Valerio Rinaldi for Amnesty International

This post was published on 21 May 2015 on EJIL Talk!, blog of the European Journal of International Law

As Juan Amaya-Castro points out, (domestic) migration legislation is about selecting among potential or prospective migrants, i.e. creating two categories of migrants: ‘documented’ or ‘regular’ migrants, whose migration status complies with established requirements, and ‘undocumented’ or ‘irregular’ migrants, whose migration status does not so comply. Where does this leave international law and, as Juan Amaya-Castro calls it, its humanist-egalitarian tradition? This post will argue that Amaya-Castro underestimates the strict and strong limitations on the sovereignty of states established by international human rights law, international refugee law and international labour law. In particular, states’ discretion in the adoption and enforcement of migration policies is limited by their obligation to respect, protect and promote the human rights of all individuals within their territory and subject to their jurisdiction (UN Human Rights Committee, General Comment No. 15, para. 5). This post discusses some of the far-reaching consequences of this principle, focusing on three types of limitations on state sovereignty with respect to migration: limitations on the prerogative to control entry; limitations on the prerogative to establish conditions for entry and stay; and limitations on the treatment of irregular migrants.

Limitations on the prerogative to control entry

The obligation not to reject refugees and asylum-seekers at the frontier may be an exception to state sovereignty conceptually, but it is far from exceptional in practice, especially in certain European contexts. Of the 19,234 people “intercepted” along EU borders by the joint border control operation Mos Maiorum between 13-26 October 2014, 11,046 people (57%) claimed asylum (Mos Maiorum final report, p. 25). More than a quarter of those “intercepted” were Syrians, followed by Afghans, Eritreans, Somalis, Iraqis – individuals whose need for international protection can easily be argued (ibid., p10). Nikolaos Sitaropoulos expertly discussed the limitations imposed on states’ sovereign prerogative to control entry and stay by the Council of Europe human rights framework, in particular its obligation of non-discrimination. Outside that framework, the guidance provided by the UN Committee on the Elimination of Racial Discrimination (CERD) is also worth mentioning. In 1998 the Committee criticised Switzerland’s so-called three-circle-model migration policy, which classified foreigners on the basis of their national origin, as ‘stigmatizing and discriminatory’ (UN Doc. CERD/C/304/Add.44, para. 6). Four years later, the Committee expressed concern at the possible discriminatory effect of Canadian migration policies (in particular, a high ‘right of landing fee’) on persons coming from poorer countries (UN Doc. A/57/18, para. 336). On these grounds, this post argues that the general principle of non-discrimination is a limitation to states’ discretion in the adoption and enforcement of all migration policies, including their prerogative to control entry.

Limitations on the prerogative to establish conditions for entry and stay

While the limitations imposed by international law on a state’s prerogative to control entry into its territory are relatively well-established, at least on paper, visa regimes are often perceived to be an area where state sovereignty has little boundaries. Once the state has complied with its international obligations in selecting who is allowed into the country, it seemingly enjoys a broad freedom in determining how long they can stay and under which conditions (the generally recognised exception being, again, refugees and those protected by the obligation against refoulement). In fact, the rules of international labour law protecting workers from labour exploitation, forced labour and servitude, and the international legal rules against trafficking in human beings, profoundly impact the prerogative of states to establish conditions for entry and stay in the form of visa regimes. As the requirements of some visa regimes may ultimately be in breach of a state’s international obligations to protect individuals from labour exploitation, forced labour, servitude and trafficking, such obligations limit its sovereignty in establishing visa conditions. In 2014, Amnesty International published an analysis of selected visa regimes in five countries of destination (China/Hong Kong, Italy, Qatar, South Korea and the United Kingdom), showing that some visa requirements, such as the inability to change employer and the employer’s control over the worker’s migration status, increase migrant workers’ risk of suffering labour exploitation and other abuses at the hand of private actors such as recruitment agencies and employers. Recently, the link between visa requirements stopping migrant workers from changing employers and vulnerability to labour exploitation has been at the centre of the debate on a new Modern Slavery Bill in the United Kingdom. NGOs have argued that the current system of overseas domestic workers visas “tied” to the employer (whereby the migrant worker is not allowed to change employer) is open to abuse, as the workers can only leave an exploitative labour relationship at the price of losing their visa. Amnesty International’s research also shows that the promise of regular documents is often used by abusive employers to induce irregular migrant workers to accept exploitative labour conditions. In countries where the administrative procedure to obtain or renew residence and work permits has to be initiated by, or requires the cooperation of, the employer, the employer’s effective power to determine their migration status can easily become a tool to intimidate or threaten workers, undermining further the irregular migrant workers’ limited ability to negotiate better wages and working conditions (Amnesty International, Abusive labour migration policies, 2014, p. 7-10).

Limitations on the treatment of irregular migrants: “firewalls”

The current European debate on irregular migration tends to focus on the limitations on state sovereignty during law-enforcement, i.e. on the procedures of arrest, detention and deportation. In fact, the international obligation to respect, protect and promote the human rights of migrants may require states not only to modify the procedures of their law-enforcement operations, but also to limit law-enforcement operations tout court. In his 2013 report to the United Nations General Assembly, the Special Rapporteur on the human rights of migrants, François Crépeau, called on states to allow migrants to access the public services needed for the enjoyment of their rights without fear of being arrested, detained and deported. In order to do so, states should implement “firewalls” between public services and migration enforcement, whereby public services (healthcare, education, housing, labour inspection, local police) would be instructed not to request migration status information unless essential; and migration enforcement would not have access to the information collected by public services relating to migration status (para. 82). The call for “firewalls” between the public officials charged with protecting and enforcing the human rights of irregular migrants (teachers, doctors, labour inspectors, etc.) and those charged with enforcing migration laws recognises and addresses a problem familiar to human rights advocates: irregular migrants are generally so concerned about coming to the attention of the authorities that they are reluctant to access public services, even when they would be entitled to do so to enjoy their human rights. While, in its first formulation, the “firewall” argument was built on ethical and policy grounds (Carens 2008 at pp. 167-168), this post argues that it also has strong grounds under the legal principle that the human rights of migrants limit the sovereign prerogative of states to control migration. Here again, the debate is far from being academic. The domestic legislation of several European states imposes on public officials a duty to report irregular migrants to migration-enforcement authorities, either expressly (such as in the Irish Immigration Act 2003, s. 8) or via the interplay of legislation criminalising irregular migration and a general requirement of any public officer to report all suspected criminal acts to law-enforcement authorities. Yet, many European states also impose direct or indirect reporting bans on public bodies and officials providing basic services, which either prohibit them or allow them not to report irregular migrants to the police. Although a complete review of state practice in this field is beyond the scope of this post, a few examples may illustrate the point. In Italy, irregular migrants are allowed free access to “urgent or essential” health services and “preventive care” services, including maternal health care, children health care, vaccinations and the care of infectious diseases and epidemics (Legislative Decree No. 286/1998, art. 35.3). To allow meaningful implementation of this right, Italian legislation expressly guarantees that access to health services by irregular migrants will not be reported to the authorities (ibid, art. 35.5). Germany’s migration legislation imposes upon all public administration bodies a general duty to report irregular migrants to the authorities in charge of migration enforcement (AufenthG, s. 87). In 2011, an explicit exception to this provision was introduced for schools and other educational and care establishments for young people (ibid.). In the same way as reporting bans on healthcare and education personnel are a simple measure to “firewall” irregular migrants’ rights to health and education, reporting bans on labour inspectors are a simple measure to “firewall” irregular migrants’ rights at work. Such bans are in fact required under the ILO Labour Inspection Convention, 1947 (No. 81). According to the ILO Committee of Experts on the Application of Conventions and Recommendations (CEACR), tasking labour inspectors with immigration control functions is incompatible with international obligations because it diverts resources from their primary duty “to protect workers and not to enforce immigration law” (General Survey on Labour Inspection, 2006, p25).

Conclusion

This post has attempted to provide a summary overview of the limitations imposed by international human rights law, international refugee law and international labour law on states’ sovereign prerogative to control entry and stay in its territory. The broad scope of these limitations strengthens the comparatively weaker position of the individual migrant vis-à-vis the state. By imposing a range of direct restrictions on law-enforcement operations, states are effectively hampered in their pursuit of the goal of migration control.

Why “illegal immigrant” is never the right description: Migration terminology for journalists

Last 30 May the BBC World News home page reported that Frontex, the EU border agency, had detected an increase in irregular border crossings from North Africa to Italy between January and April 2014. The story, titled Illegal EU migration surges as thousands flock to Italy, was illustrated by a photo taken a few days earlier during the police clear-out of a makeshift camp in Calais, France. BBC 30 May 1 Several NGOs, academics and civil society members expressed concern about the use of the term “illegal” to refer to the individuals attempting to cross into Europe by sea. According to the article, a third of the latest arrivals were Syrians fleeing the war – that is refugees and asylum seekers, not migrants. Other significant numbers were nationals of Afghanistan and Eritrea, traditional countries of origin of refugees and asylum seekers. So, in fact, up to a half of the “illegal migrants” trying to reach Europe were neither migrants nor “illegal”. Additionally, some pointed out, the term “illegal” is inaccurate and criminalising even when referring to economic migrants involved in irregular border crossings. Twitter 1 The BBC took these points on board, changing both the text and the title of the article, which now reads “Migration surge hits EU as thousands flock to Italy”. Here is a comparison between the two versions, courtesy of NewsDiffs. The rather alarmist original photo was later changed as well. BBC 30 May 3

The debate about “illegal” migration terminology

The article in question is far from being an isolated case, both within and outside the BBC. As of today, both The New York Times and The Telegraph are still running similar piece on a surge in “illegal” migration to the EU.

During the past few years, a strong debate about the best terminology to use to accurately and impartially describe people who are in a country without permission has been developing in the United States. Civil society organisations and activists such as Colorlines.com and Jose Antonio Vargas have been campaigning to eliminate the use of the word “illegal” in relation to migrants. In Europe, PICUM, the Platform for International Cooperation on Undocumented Migrants, has started a similar campaign.

The case against “illegal” migration terminology

As language shapes the way human beings understand the world, the words used to refer to people crossing borders do matter. Inaccurate terminology increases confusion and misinformation breeds prejudice. These are a few reasons to #droptheiword.

1. “Illegal” migration terminology is inaccurate and misleading

When referred to a person, the term “illegal” is linguistically inaccurate because committing an offence, whether of a criminal or of an administrative nature, does not make the offender “illegal”. In the same way as a driver who does not stop at a red light is not an “illegal” driver, a person who enters or remains in a country in breach of its domestic laws or regulations is not an “illegal” migrant. Since April 2013 the Associated Press Stylebook, a well-reputed style manual for news writing, recommends journalists to use “illegal” only to refer to an action, not to describe a person. USA Today and the Los Angeles Times changed their style accordingly shortly afterwards.

Additionally, the term “illegal” is often inaccurate even when referred to the acts of entering or remaining in a country in breach of its domestic laws or regulations. Contemporary migration flows are mixed, meaning that refugees, asylum-seekers and economic migrants move together. When such a heterogeneous group of people crosses a border, the terms “illegal arrivals” or “illegal border crossing” do not take into account that international law allows refugees and asylum-seekers to cross borders without the appropriate documentation or authorisation (article 31, 1951 Refugee Convention).

Similarly, “illegal” migration terminology does not take into account that people may cross borders as a result of violence, deception or fraud, including by employers who then exploit them. These are victims of trafficking who should not be penalised for their irregular migration status (Principle 7, Recommended Principles and Guidelines on Human Rights and Human Trafficking).

Even with respect to people who migrate for purely economic reasons, the use of “illegal” migration terminology does not reflect the complexities of reality. Many migrants find themselves in and out of a regular migration situation during their stay in the country of destination (for example, they enter their country of destination regularly, but then fall into irregularity when their original authorisation expires). Compliance with migration laws and regulations may also be partial, as a migrant may hold a valid residence permit but work in breach of its conditions.

Finally, “illegal” migration terminology fails to recognise the distinction between breaches of criminal law and breaches of administrative law. As highlighted by the UN Special Rapporteur on the human rights of migrants, irregular entry and/or stay in a foreign country are not offences against persons, property or national security and therefore they should be administrative, not criminal, offences.

2. “Illegal” migration terminology is harmful

The negative criminal connotations of “illegal” migration terminology are stigmatising and suggest that migrants, asylum-seekers and refugees do not deserve protection under the law or that their human rights have been forfeited. In fact, human rights are universal and not dependent on migration status.

In particular, the use of “illegal” migration terminology with respect to the entry or stay in a country prejudges the situation of refugees, asylum-seekers and victims of trafficking and may be detrimental to the official recognition of their status. It also prejudges the situation of individuals with shifting migration status, such as those who migrate or have migrated as children.

In the countries where irregular migration is a criminal offence, the use of “illegal” migration terminology breaches the presumption of innocence. Ethical journalism treats all breaches of laws and regulations as “alleged” – irregular migration should not be different.

More broadly, “illegal” migration terminology is often used to justify discrimination and contributes to negative public attitudes not only about migration and migrants (regular and irregular), but also about particular ethnic or racial groups and all those perceived to be of foreign origin.

3. “Illegal” migration terminology is biased

In many countries of destination the use of “illegal” migration terminology has political connotations as it is mostly used by advocates of restrictive labour migration and asylum policies.

Indeed, there seems to be a correlation between the diffusion of “illegal” migration terminology in common language and the increase of restrictions in migration policies. Although informal and limited, an analysis of migration terminology in books, via GoogleBooks, provides a powerful graphic representation of the relatively recent invention of “Illegal” migration terminology in the English language.

Evolution of terminology referring to irregular migration in English language books, 1900-2014, source Google Books Ngram viewer, June 2014

Evolution of terminology referring to irregular migration in English language books, 1900-2014, source Google Books Ngram viewer, June 2014

Which alternative?

A few weeks ago Chris Elliot, the Guardian readers’ editor, responded to complaints by several human rights organisations about the use of the term “illegal immigrant” in one of the paper’s articles, noting that they were making “perfectly reasonable arguments that have been accepted in relation to other terms” and opening a consultation with readers about possible alternative terminology.

A solution to the issue, however, cannot be left only to the editorial guidelines of specific media companies. The best guidelines are produced when journalists’ associations, the UN refugee agency (UNHCR), human rights and other civil society organisations work together. When done nationally, this exercise allows to take into account domestic legislation and the nuances of national languages. In Ireland, the National Union of Journalists (NUJ-Ireland) cooperated with UNHCR and the Irish Refugee Council to issue guidelines on reporting on refugees, asylum-seekers and migrants. In Italy, the Journalists’ Association and the National Press Federation, in collaboration with UNHCR and Amnesty International, adopted the Rome Charter, a code of conduct on reporting of asylum and migration issues. Other useful tools include the glossary provided by the Canadian Council for Refugees and the Key Migration Terms explained by the International Organization for Migration.

In short, journalists should use irregular or undocumented when talking about migrants and irregular or unauthorised when talking about entry or stay.

This is the language used in the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families (article 5) and recommended by the UN General Assembly, the Parliamentary Assembly of the Council of Europe and the European Parliament.

How to cite this article: Francesca Pizzutelli, “Why ‘illegal immigrant’ is never the right description: Migration terminology for journalists’”, The Rights Angle, https://therightsangle.wordpress.com/, 6 October 2014.

Illegal immigrants don’t exist … until after 1930

Reblogging a post by Fabio Rojas, Associate Professor of Sociology at Indiana University, about the use of “illegal” migration terminology over the last century. Graph sourced from Google books Ngram Viewer.

orgtheory.net

no_illegal

According to immigration scholar and advocate Francesca Pizzutelli, the phrase “illegal immigrant” did not exist in English (or was insanely rare) before the 1930s. Rather, people used the phrase “irregular immigrant” for transitory labor. The bias against outsiders exists in all societies, but this suggests that the modern legal and cultural edifice that bars people from migrating peacefully to the US did not exist till the series of anti-immigration laws passed by Congress in the 1920s.

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