The Removal File — Status, Process, and the Counts
Deportation in America: Visa Overstays, Removal Orders, and How the Law Actually Works
Deportation in the United States is an administrative process, not a criminal sentence: being present without status is a civil violation, while entering improperly and reentering after removal are federal crimes, and the system runs on that seam. Its caseload is majority non-criminal in the recent record—two-thirds of fiscal 2024 removals involved no criminal conviction or pending charge—its court backlog stands above three million cases, more than 1.4 million people carry final removal orders unenforced, and the statute that governs it, at the removability stage, asks nothing about whether the person removed is good. The desk files the law, the process, the counts, and the error file, in that order.
The File in Brief
The desk has no position on immigration policy in this file, for or against, and this report is written from that position: the law, the process, and the counts, with every side’s claims tested by the same instrument. On the verified record: unlawful presence in the United States is a civil violation, not a crime; improper entry (8 U.S.C. §1325) and reentry after removal (§1326) are crimes; and removal itself is an administrative proceeding under the Immigration and Nationality Act, run through two statute lists—the grounds of inadmissibility at INA §212, applied to people seeking entry, and the grounds of deportability at INA §237, applied to people already admitted. The standard track runs from a notice to appear through master calendar and merits hearings before an immigration judge, with appeal to the Board of Immigration Appeals, and three faster tracks run beside it: expedited removal at the border and, since January 2025, by designation nationwide; administrative removal for aggravated felons without a judge; and reinstatement of an old order without a new hearing. The consequences are tiered by how a person leaves: a removal order carries reentry bars of five, ten, or twenty years under INA §212(a)(9)(A), permanent for aggravated felons, while voluntary departure—taken before or after proceedings conclude, under different conditions—carries no removal-order bar, though the separate three- and ten-year unlawful-presence bars at §212(a)(9)(B) turn on time accrued, not on the manner of leaving. The counts: ICE removed 271,484 people in fiscal 2024, of whom 88,763, or 32.7 percent, had criminal convictions or pending charges; the no-criminal-history share of removals has risen every recent year, reaching roughly two-thirds in 2024 and higher in 2025 by independent reconstruction, and in ICE’s interior enforcement—arrests away from the border—the criminal share runs the other way, about 93 percent of interior removals in fiscal 2024. The overstay, not the border crossing, has been the larger source of new unauthorized residents since about 2007 by the Center for Migration Studies’ estimates: the Department of Homeland Security counted 538,548 suspected overstay events in fiscal 2024 against 46.7 million expected departures, a rate of 1.15 percent, with Mexico, Colombia, India, and Canada the largest counts and European visa-waiver states contributing about 61,000 suspected overstays against 1,540 European removals in the last full yearbook year. The system holding these cases is backlogged and exposed: 3,037,800 cases pending in immigration court at the end of September 2026 by TRAC’s count, an estimated 1.6 million people on ICE’s non-detained docket carrying final orders, 65,765 people in detention on a July 2026 count of whom 70.6 percent had no criminal conviction, and a resident population of lawful permanent residents whose exposure to the deportability grounds never expires—a conviction from the third year of a forty-year residence is chargeable in the thirty-seventh, because the statute carries no limitations period and only naturalization ends the exposure. The public, polled by Pew and Gallup in 2025, holds a model the statute does not contain—65 percent for a requirements-based path to stay, 97 percent of the selective majority for deporting the violent, 15 percent for deporting the employed—in the language of this report, a ripening doctrine whose only living statutory relative is cancellation of removal’s ten-year presence rule and whose ancestor, the 1986 legalization, has not been rerun; and the precarity the system manufactures is a priced commodity in adjudicated fact, from smuggling fees of $6,500 to $18,000 a person in the sentencing records, through the sanitation contractors’ child-labor judgments, the $14 million Signal verdict, and the $65.5 million au pair settlement, to the lawful tether of the H-1B and the 1.1-million-deep Indian green-card queue. The desk closes the file with the definitions the argument uses loosely—naturalization is a statutory process with stated requirements, not a ripening of residence into entitlement—and with the error file, in which the government’s own auditors have documented citizens arrested, detained, and removed, graded by the same instrument as every other claim in the report.
1. The Legal Architecture: A Civil System with Criminal Edges
Presence is civil; entry is criminal; the distinction organizes the whole system. A noncitizen who is present in the United States without lawful status commits no federal crime by being present. The Supreme Court stated the point in Arizona v. United States, 567 U.S. 387 (2012): “As a general rule, it is not a crime for a removable alien to remain present in the United States.” What the criminal code reaches is conduct at the border and after removal. Improper entry—crossing at an undesignated place, evading inspection, or entering on false documents—is a federal misdemeanor for a first offense under 8 U.S.C. §1325, punishable by up to six months, and a felony on repetition. Reentry after a removal order is a felony under §1326, punishable by up to two years, rising to ten years after removal following certain convictions and twenty years after an aggravated felony. Removal itself—the process the public vocabulary calls deportation—is neither: it is an administrative proceeding conducted by the executive branch, in which the respondent has the right to counsel at no expense to the government, no right to a jury, and a burden structure set by statute rather than by the criminal standard. Since the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, the proceeding has had one name: “removal,” which merged the old exclusion and deportation tracks into a single process under INA §240.
Two lists in the statute book decide who may enter and who must leave, and they are not the same list. INA §212(a) (8 U.S.C. §1182(a)) states the grounds of inadmissibility—the charges applied to a person seeking admission at a port of entry, applying for a visa, or, in specified circumstances, adjusting status or returning from travel. INA §237(a) (8 U.S.C. §1227(a)) states the grounds of deportability—the charges applied to a person who was admitted and is now alleged to have forfeited the admission. The deportability list, which is the operative one for residents, runs in classes: persons inadmissible at the time of entry or adjustment; persons present without admission or parole; persons who violated the conditions of their status, including failure to maintain student or exchange status; persons who fail to register a change of address; document fraud and false claims to citizenship; and the criminal classes at §237(a)(2)—crimes involving moral turpitude, aggravated felonies, high-speed flight, controlled-substance offenses, firearms offenses, and crimes of domestic violence, stalking, and child abuse or neglect. Which list governs a given person is a threshold litigation point in real cases, because the burdens differ: in deportability cases the government must prove alienage and the ground by clear and convincing evidence; in inadmissibility postures the applicant bears more of the burden. The architecture is therefore dual by design—one list for the door, one list for the house—and much of the case law in this field is argument about which list a particular life falls under.
The visa and the status are different instruments, and confusing them misreads the overstay problem. A visa is a travel document: it permits the holder to present at a port of entry during its validity window. Status is the authorization to remain, and its clock is set at admission, on the Form I-94 record, by the inspecting officer—typically six months for a B-2 visitor, the duration of a course for an F-1 student, a fixed term for a worker. A traveler may hold a visa valid for ten years and a status that expires in six months; overstaying the status is the violation, and the visa’s printed dates do not extend it. Three consequences follow in the statute. Under INA §222(g), the visa of a person who overstays is void automatically, by operation of law, and a future visa may be sought only in the home country absent exceptional circumstances. Unlawful presence begins accruing the day after the status expires (or the day after an immigration judge or the agency so finds), and it is the accrual, not the overstay itself, that arms the reentry bars in section 5 below. And the overstay converts the person’s posture from the deportability list to a hybrid: overstays are charged as present without admission or in violation of status, and if they later seek to adjust or reenter, the inadmissibility list—including its unlawful-presence bars—applies to them in full.
2. The Ladder: From Notice to Appear to the Plane
The standard track begins with a charging document and runs through a court that is not a court of the judiciary. Proceedings open when the Department of Homeland Security files a Notice to Appear (Form I-862) with the immigration court and serves it on the respondent, stating the charges from the two lists. The immigration courts belong to the Executive Office for Immigration Review, a component of the Department of Justice; their judges—557 of them by USAFacts’ 2026 count, down from a peak of 735 in fiscal 2024—are executive-branch adjudicators, and the department’s own prosecutors, ICE trial attorneys, argue the government’s side. The first hearing is the master calendar hearing: pleadings are taken, the respondent admits or denies the charges, counsel is sought—at the respondent’s expense; there is no appointed counsel in removal proceedings—and applications for relief are identified. The case then moves to an individual, or merits, hearing: testimony, evidence, cross-examination, and a decision from the bench or in writing. Either side may appeal to the Board of Immigration Appeals within thirty days; a further petition for review lies to the federal circuit court, and removal is ordinarily stayed while a timely petition is litigated. When the Board’s order becomes administratively final and no stay is in force, the order is a final order of removal, and its execution passes to ICE.
The ladder has branch points, and every branch is a form of relief with statutory elements. An asylum application (INA §208) asks for protection on account of race, religion, nationality, political opinion, or particular social group, with a one-year filing deadline and statutory bars; withholding of removal (§241(b)(3)) and protection under the Convention Against Torture run beside it on a higher burden and confer no path to a green card. Cancellation of removal (§240A) is the long-resident’s branch: for a lawful permanent resident, seven years of continuous residence and no aggravated felony; for a non-resident, ten years of physical presence, good moral character, and exceptional and extremely unusual hardship to a qualifying citizen or resident relative, under an annual cap of 4,000 grants for the non-resident form. Adjustment of status (§245) converts the proceeding into a grant where an immigrant visa is immediately available and the applicant is admissible. Waivers—§212(h) for certain criminal and fraud grounds among them—excuse specified inadmissibility. A respondent who concedes removability and asks for none of this may instead ask the judge for voluntary departure, the branch treated in section 5. A respondent who does not appear receives an order in absentia under §240(b)(5), entered on proof of written notice; it may be rescinded on a motion to reopen for lack of notice or exceptional circumstances, and it carries the final order’s full consequences plus a ten-year bar on most relief. Each branch is charged, pled, and proven like a claim, because that is what it is: the ladder is not a conveyor but a decision tree, and the overwhelming majority of its traffic is resolved at the branches, not at the top.
Three faster tracks run beside the court track, and most removals never see a judge. Expedited removal (INA §235(b)(1)) authorizes a DHS officer, without a hearing, to order removed a person who arrives without documents or with fraudulent ones; the 1996 statute permits its application to persons already inside the country who cannot prove two years of continuous presence, and by designation it was long confined to ports of entry and the border zone before the designation was extended nationwide in January 2025—an expansion that has been litigated since, with the litigation continuing at filing. A person who expresses fear of return is routed to a credible-fear screening and, if the screening is passed, into the court track; a negative screening is reviewable by an immigration judge on request. Administrative removal (§238(b)) applies to non-residents convicted of an aggravated felony: the agency itself issues the order, with notice and a chance to rebut, and no immigration judge sits. Reinstatement (§241(a)(5)) applies to a person who reentered after a prior removal: the old order is reinstated on the agency’s finding of identity and the prior order, “not subject to being reopened or reviewed,” and the person may be removed on it directly. Stipulated orders, in which the respondent waives the hearing in writing, complete the set. The arithmetic of the system follows from the tracks: in any recent year the majority of formal removals are executed through the fast tracks at and near the border, while the court track—the ladder the public picture shows—carries the minority and accumulates the backlog recorded in section 12.
Between the final order and the plane stands an enforcement apparatus with its own queue. ICE’s Enforcement and Removal Operations directorate executes final orders. Its non-detained docket—persons in proceedings or under orders but not in custody—stood above 7.6 million at the end of fiscal 2024 by ICE’s annual report and at 7.3 million in February 2026 by the Congressional Research Service’s estimate, of whom an estimated 1.6 million carry final orders (the figure stood at 1,445,549 in November 2024). Persons under orders who are not detained report on orders of supervision—scheduled check-ins at field offices, in person or, increasingly since 2025, through reporting applications—and receive letters directing them to present for removal on a date, with travel documents requested from consulates in the interval; a passport or laissez-passer from the country of nationality is ordinarily required before a removal flight can be boarded, and uncooperative consulates are a standing mechanical bottleneck the statute answers with visa sanctions under INA §243(d), invoked against a rotating list of states. Persons who do not report are classified absconders and assigned to fugitive operations teams for arrest. Detention, where it is used, is civil custody in a network of county jails and contract facilities; the average daily population and the counts are filed in section 12. The ladder thus ends not in a single act but in a logistics chain—order, documents, custody or compliance, flight—each link of which has its own failure modes, which is why final orders outstanding are counted in the millions and removals in the hundreds of thousands.
3. Status Killers: What Voids a Life Built Here
For the lawful permanent resident, deportability is a defined list, and the list is mostly a criminal code annex. A green-card holder is removable under §237(a)(2) on conviction of: an aggravated felony, at any time after admission; one crime involving moral turpitude committed within five years of admission for which a sentence of one year or longer may be imposed, or two such crimes at any time not arising from a single scheme; a controlled-substance offense, with exactly one exception in the statute—a single offense of simple possession of thirty grams or less of marijuana; a firearms offense; or a crime of domestic violence, stalking, child abuse, neglect, or abandonment, or violation of a protection order. The aggravated-felony term, defined at §101(a)(43), is the broadest instrument in the book and the least matched to its name: it includes murder, rape, and drug trafficking, and also theft or burglary with a sentence imposed of one year—a suspended year counts, under §101(a)(48)(B)—fraud or deceit with a loss to the victim over $10,000, tax evasion, commercial bribery, obstruction of justice, failure to appear, and, since Sessions v. Dimaya, 584 U.S. 148 (2018) voided the residual clause, a “crime of violence” only as the elements of the offense define one. Non-criminal grounds run beside the convictions: the admitted smuggler of another person (including, on the inadmissibility side, one who helped a family member enter), the person who falsely claimed citizenship, the person who voted unlawfully, the person who failed to register an address change, and the resident who, by conduct, abandoned the residence itself—a surrender that can be found in long absences, a home and job established abroad, and is formalized on Form I-407. None of these grounds inquires into the person’s record of work, family, tax compliance, or service; those inquiries live entirely on the relief side of the ledger, in section 9 below.
A resident’s travel is itself a screening event, governed by a provision the frequent flyer rarely meets until it is read to him. Under §101(a)(13)(C), a returning permanent resident is ordinarily not treated as seeking admission—the doctrine that descends from Rosenberg v. Fleuti, 374 U.S. 449 (1963), codified and narrowed in 1996—unless one of six conditions holds: he abandoned or relinquished the status; he was absent more than 180 days; he engaged in illegal activity after departing; he left while in proceedings; he committed an offense listed at §212(a)(2); or he is attempting entry without inspection. If any condition holds, the return is processed as an application for admission, the inadmissibility list replaces the deportability list, and grounds that could not touch him at home—including the public-charge ground at §212(a)(4) and the health-related grounds—are in play at the airport. Parallel machinery reaches the nonimmigrant: under §221(i), a consular officer or the Secretary of State may revoke a visa at any time, in discretion, and the State Department’s practice of prudential revocation—revoking on notice of an arrest, effective on the holder’s next attempt to travel, often without notice until then—means a visa can die before its holder learns it has. Status, in short, is not a possession but a standing, renewed at every border crossing, every filing, and every arrest report that crosses the desk.
The drunk-driving case states the current law exactly, and it is the opposite of the common account. A single ordinary DUI conviction is, under current federal law, not a ground of deportability for a permanent resident, and not a ground of inadmissibility either. The Supreme Court held unanimously in Leocal v. Ashcroft, 543 U.S. 1 (2004), that a state DUI offense—there, one causing serious bodily injury, committed with criminal negligence—is not a “crime of violence,” because the offense does not require the active use of force; it therefore cannot be an aggravated felony, the ground that would make removal near-automatic. The Board of Immigration Appeals held in Matter of Lopez-Meza, 22 I&N Dec. 1188 (BIA 1999), that ordinary DUI is not a crime involving moral turpitude, because the offense as commonly defined carries no corrupt or fraudulent intent; the same decision found turpitude in the aggravated variant before it—driving under the influence while knowing one’s license was suspended or revoked—because the knowing violation of the licensing order supplied the element the plain offense lacks. The edges, where DUI does become fatal to status, are specific and printable: drugs in the offense move it into the controlled-substance ground, which has no de minimis exception for a DUI formulation; a child endangered in the car changes the CIMT and child-abuse analysis; injury and flight stack further offenses onto the plea; repeat convictions operate on the discretionary side—under Matter of Castillo-Perez, 27 I&N Dec. 664 (A.G. 2019), two or more DUI convictions raise a presumption against the good moral character that cancellation of removal and naturalization require; a DUI history routes visa applicants and returning residents into the health-related screening at §212(a)(1)(A)(iii), under which alcohol abuse associated with harmful behavior is a ground of inadmissibility administered through panel physicians; and the State Department prudentially revokes the nonimmigrant visa on the arrest itself, before any conviction. The legislative proposal to close the gap between the common account and the law is pending and is filed as pending: H.R. 875, the Jeremy and Angel Seay and Sergeant Brandon Mendoza Protect Our Communities from DUIs Act, would add DUI to both lists—a new inadmissibility ground at §212(a)(2)(J) reaching convictions and admissions alike, and a deportability ground at §237(a)(2)(G)—with no misdemeanor exception, no waiver, and no limit on the age of the conviction. It passed the House on June 26, 2025, by 246 to 160, was referred to the Senate Judiciary Committee the next day, and no Senate action is recorded as of filing; a narrower companion aimed at undocumented drivers in fatal and serious-injury crashes was introduced in April 2026. As the law stands on the day of this report, the resident who drives drunk once has committed a crime the state will punish; he has not, by that act alone, forfeited the green card.
4. The Criminal Sequence: Jail First, Then the Airport
The sequence for the convicted runs in the order the public phrase reverses. A noncitizen arrested on a criminal charge is booked, and the booking fingerprints are shared with the Department of Homeland Security as a matter of automated routine. If ICE elects to act, it lodges a detainer (Form I-247A) asking the jail to notify the agency before release and to hold the person up to forty-eight hours beyond the release the criminal case has ordered. The criminal case proceeds first and on its own clock: plea or trial, then the sentence, served in full or as the court directs. Only at the end of that sequence—at release from criminal custody—does the detainer bite and the transfer to ICE custody occur. Removal proceedings, where a hearing is required, run after or, in detained practice, alongside the end of the sentence; for the aggravated felon the administrative track of section 2 substitutes. ICE’s own terminology for the pipeline is the Criminal Apprehension Program and its jail-based predecessors; the mechanical point the desk files is that the deportation facility is not an alternative to the jail in the convicted person’s itinerary. It is the last stop after the jail, and the share of removals drawn from this pipeline is a measured quantity, printed next.
The criminal share of removals is a series with a trend, and the trend runs against the frame in both directions. The desk prints the ICE series as the agency and its critics publish it, with the definitions attached, because the definitions move the number more than the operations do. In fiscal 2013, ICE’s own report counted 368,644 removals, of which 59 percent—216,810—were of persons previously convicted of a crime; of the 133,551 interior removals, 82 percent were convicted criminals. In fiscal 2015, the interior convicted share reached 91 percent while the overall convicted share held at 59 percent. In fiscal 2023, of 142,580 ICE removals, about 49 percent—69,902—involved criminal charges or convictions. In fiscal 2024, of 271,484 removals, 88,763—32.7 percent—had criminal histories, that category bundling convictions with pending charges; the interior cut of the same year inverts the headline: of 47,732 interior removals, 36,279 were of convicted persons and 8,028 of persons with pending charges—93 percent criminal-involved—while only 3,425 were of other immigration violators, because interior enforcement is fed by the jail pipeline and the fugitive docket, and the border fast tracks, which produce the bulk of the total, process recent entrants who carry no American criminal record to count. In fiscal 2025, independent reconstructions from ICE’s biweekly releases put total removals at about 320,000 to 329,000, and the Migration Policy Institute and others record the convicted share falling to the lowest of the modern series; the department’s separate public claim of 622,000 deportations since January 20, 2025, issued in December 2025, aggregates categories beyond ICE removals and is filed in the ledger as a claim whose methodology is not comparable to the series here. The detention snapshot agrees with the direction: of the people booked into ICE detention in November 2025, the Cato Institute’s analysis of ICE data counted 73 percent with no criminal conviction and 5 percent with a violent conviction. The “eighty percent non-criminal” figure that circulates in the argument matches no official series the desk could locate; the measured series runs from 41 percent non-convicted of all removals in fiscal 2013 to roughly two-thirds without conviction-or-charge in fiscal 2024, higher still in 2025—the direction of the claim is the direction of the record, at magnitudes the record states more precisely than the claim does.
5. Leaving: Voluntary Departure, Self-Deportation, and the Bars
American law prices departure by its form, and the price list is written in three subsections of §212(a)(9). A person removed under an order is inadmissible for five years if removed on arrival, ten years if removed after proceedings or having departed under an order, twenty years after a second or subsequent removal, and permanently if convicted of an aggravated felony—§212(a)(9)(A), with consent to reapply (Form I-212) the only door before the term runs. A person who accrued more than 180 days of unlawful presence and then departs—in any manner, including under a removal order or entirely unobserved—is barred for three years; more than a year of unlawful presence, ten years—§212(a)(9)(B), the departure itself being the trigger that arms the bar. A person who accrued an aggregate year of unlawful presence, or was removed, and then reenters or attempts reentry without admission is permanently inadmissible under §212(a)(9)(C), waivable only after ten years spent abroad. These bars stack: a long-term overstayer removed under an order ordinarily carries both the removal bar and the unlawful-presence bar, and each must expire or be waived on its own terms. Against this schedule stands the voluntary forms. Voluntary departure under §240B, granted by an immigration judge, is an order permitting departure at the person’s own expense by a set date in place of removal: requested before or at the master calendar stage, it may run up to 120 days and requires only removability conceded and ability to depart; requested after proceedings conclude, it is capped at sixty days and conditioned on good moral character, a clean recent record, a departure bond, and travel documents in hand—and in both forms, a person who departs on time carries no removal order, and therefore no §212(a)(9)(A) bar, while a person who accepts voluntary departure and does not leave is converted to a removal order by statute, fined, and barred from most relief for ten years. At the border itself, withdrawal of an application for admission and voluntary return dispose of arriving cases without orders at all. The framing that voluntary departure “preserves the ability to apply again” against removal’s forfeiture is therefore correct in structure and requires one filing correction: voluntary departure avoids the removal-order bars and the removal record, but it does not erase the unlawful-presence bars of §212(a)(9)(B), which turn on accrued time and are armed by any departure at all—the long-term overstayer who leaves voluntarily at year ten has preserved his channels and still serves the ten-year bar, absent a waiver.
“Self-deportation” is the policy name for inducing the voluntary forms at scale, and its 2025 instrument and its headline count grade differently. The instrument is documented: the CBP Home application, repurposed in 2025 to register intent to depart, with travel assistance and a $1,000 stipend offered to those who depart through it, inside a public campaign whose stated object is to make the voluntary forms the rational choice against the bars of the involuntary one. The count is a claim: the Department of Homeland Security announced in October 2025 that 1.6 million people had self-deported since January 20, 2025, and raised the figure to 1.9 million in December. The department has published no line-by-line methodology; reporting on the figure traces it to estimates of foreign-born population decline built from Current Population Survey data—the Center for Immigration Studies’ survey analysis, whose own authors describe it as a preliminary estimate from imperfect data—rather than to a count of departures. The counted instruments run orders of magnitude lower: the Deportation Data Project’s tabulation of the courts’ records shows 6,118 grants of voluntary departure between January 20 and July 29, 2025, and analysts put application-confirmed departures through CBP Home in the tens of thousands for the year. The desk files the mechanism as verified, the incentive as verified, and the million-scale count as claimed-but-unproven, in the ledger below—the same column, the reader will note, as the largest claims of the other side.
6. The Comparative Ledger: Windows Are the World Norm
Every state on the desk’s shelf grants the visitor a window and attaches consequences to outstaying it; the United States is unexceptional in kind and specific only in its numbers. The Schengen area—twenty-nine European states, including non-EU members Switzerland (a member since 2008), Norway, and Iceland—admits the visa-exempt short-stay visitor for ninety days in any 180-day period, and the clock is cumulative: it is a rolling window counted backward from each day of presence, so a departure does not reset it, and the traveler who has spent ninety days inside must spend ninety outside before the arithmetic admits him again; the popular border-hop reading of the rule is a misreading, and the strategy sometimes built on it—sitting out the clock in a nearby non-member state—works only where the waiting state is genuinely outside the area, as the United Kingdom and Ireland are, and fails where it is not, as Switzerland is not outside it. Overstay consequences inside the area include fines, recorded alerts, and entry bans that vary by state from months to years. Canada admits the ordinary visitor for up to six months as stamped or presumed at entry, extendable on application. Common grants elsewhere run thirty days (much of Southeast Asia’s visa-exempt practice), ninety days (Japan, Brazil, and the Schengen norm), and six months (the United Kingdom’s standard visitor, Canada, and the United States’ own B-2). Where clocks are per-entry rather than cumulative—in the thirty-day regimes—the visa run is a real institution, with its border towns and same-day return buses, and states that tire of it convert to cumulative counting or per-year caps, which is the direction of travel in the systems the desk examined. The structure is everywhere the same three parts: a window, an accounting, and a price for exceeding both.
Germany’s file is the desk’s exhibit of the accounting run as routine administration. A person who takes up residence registers the address with the municipal office—the Anmeldung, due within fourteen days of moving in, producing the registration certificate on which the rest of German administrative life depends: bank account, tax class, health insurance, the residence file itself. The non-European who stays beyond the Schengen short-stay window holds a residence permit, the Aufenthaltserlaubnis, issued for a stated purpose—work, study, family—by the local foreigners’ authority, time-limited, renewable on the purpose continuing, and ripening toward a settlement permit on years, language, and contributions. Nothing in the arrangement is ceremonial: it is a ledger of who is present, on what basis, until when, kept by clerks, and its premise—that presence in the territory is an accounted condition rather than a default—is the premise of every system in this section, including the American one. The desk files the comparison without a moral: the states differ in window length, in ripening rules, and in the price of the overage, and they do not differ in keeping the ledger.
7. The Overstay Category: The Larger Half of the Flow
The Department of Homeland Security counts the overstay every year, and the count is the largest single exhibit in this report. The Entry/Exit Overstay Report for fiscal 2024 records 46,657,108 expected departures of nonimmigrant visitors arriving by air and sea, and 538,548 overstay events—a total overstay rate of 1.15 percent—of which 482,954 were suspected in-country overstays at the report’s close, a figure that had fallen to 427,204 by February 2025 as late departures and status adjustments resolved. The largest national counts are Mexico (61,442), Colombia (28,409), India (27,585), and Canada (25,309, at a rate of only 0.27 percent of Canadian departures); the visa-waiver states’ suspected in-country rate is 0.43 percent, the non-waiver rate excluding Canada and Mexico 2.22 percent, and the student and exchange categories (F, M, J) run at 2.45 percent, while the highest rates belong to small programs—Myanmar at 43 percent, Suriname at 31, Haiti at 25—where a few thousand admissions produce the percentage. The category’s weight is in the accumulation: the Center for Migration Studies has estimated, in a series of studies running back a decade, that overstays have exceeded entries without inspection among new additions to the unauthorized population in every year since about 2007, reaching roughly three-fifths of new additions in peak years and about 40 percent of the newly unauthorized in fiscal 2023—which is to say, the characteristic modern entrant into unlawful status is a person who arrived inspected, with a visa, and stayed past the date on the I-94. The stock figures bound the flow: the Pew Research Center’s estimate puts the unauthorized population at about 14 million in 2023, a record, against about 11 million in the department’s own earlier series—estimates, both, built from census residuals, and filed as estimates wherever this report repeats them.
8. Exposure Over Time: The Resident’s Ledger of Tripwires
Consider the resident the system actually holds: admitted lawfully, employed for decades, remitting wages, raising citizen children—and carrying, for every day of those decades, the full deportability list of section 3. His exposure is not a mood but an inventory, and the desk files the inventory as he accumulates it. The moral-turpitude rules run on two clocks: one CIMT committed within five years of admission, on a charge carrying a possible year’s sentence, is a ground; two CIMTs not from a single scheme are a ground at any time. The aggravated-felony definition runs on sentence arithmetic: a theft or burglary plea with one year imposed—suspended in full, served not a day—is inside it, as is a fraud with $10,001 of loss and a drug offense that the charging statute calls trafficking at quantities the street calls personal. The controlled-substance ground admits one exception and one only, the single thirty-gram marijuana possession case. The domestic-violence ground, §237(a)(2)(E), reaches crimes against a protected person and violations of protection orders, and its definitions are litigated household by household. The false-claim ground—a claim to citizenship made for a purpose or benefit, on a driver’s license form or an I-9 as readily as at a naturalization interview—carries, on the inadmissibility side, a bar with no general waiver, relieved only by a narrow exception for the child of citizens who reasonably believed the claim. Unlawful voting is its own ground on both lists. Alien smuggling includes driving a relative across or paying his guide, subject to a discretionary family waiver on one list and not the other. The address-registration ground is rarely charged and entirely on the books. Abandonment can be found in the pattern of his trips home. And overlaying the whole inventory, the disposition of his case if charged depends on relief whose elements—good moral character above all—are themselves forfeited by entries in the same inventory. No single line is exotic; the exposure is the sum, carried without expiry.
The bar fight is the cleanest test of the inventory, and the desk runs it as the record runs it: the same night ends in three different countries of outcome depending on the charge, the plea, and the sentence. Simple assault—an ordinary fight, no weapon, no serious injury—is generally not a crime involving moral turpitude, because the offense requires no intent to steal, defraud, or commit an inherently base act; the immigration courts have found turpitude where the statute adds an aggravator: a weapon, intent to injure seriously, a protected victim. It is likewise not an aggravated felony as a “crime of violence” unless the offense is a felony under the elements clause of 18 U.S.C. §16 as preserved by Dimaya and the term of imprisonment imposed is at least one year—imposed, again, not served, the suspended year counting in full. The hinges are therefore clerical: whether the prosecutor charges the simple or the aggravated form; whether the plea is taken to assault, to disorderly conduct, to a theft count offered in substitution; whether the sentence negotiated is 364 days or 365—a distinction with no meaning in the criminal court’s own purposes and the whole meaning in the immigration court’s. A resident of forty years who pleads to a misdemeanor assault with a 364-day suspended sentence has ordinarily bought a criminal record and kept his residence; the same man, pleading to the same conduct on a differently drawn statute with a year imposed, has purchased an aggravated felony, mandatory detention, ineligibility for nearly all relief, and removal under the administrative track without a merits hearing on his equities. Between those two outcomes stands no finding about the man. There stands a charging document and a sentencing line.
Most charging documents are written in plea negotiations, and until 2010 the immigration consequences were not required to be in the room. In Padilla v. Kentucky, 559 U.S. 356 (2010), the Supreme Court held that the Sixth Amendment requires defense counsel to advise a noncitizen client when a plea carries a risk of deportation—precisely and personally where the statute makes the consequence clear, in general terms where it is not—because deportation is, in the Court’s words, a particularly severe penalty intimately related to the criminal process. Chaidez v. United States, 568 U.S. 342 (2013), confined the rule to cases after 2010, leaving the earlier decades’ pleas where they lie. The working system the two decisions describe is this: the criminal courts dispose of the overwhelming majority of their cases by plea; the plea’s immigration weight is fixed by category-matching between the statute of conviction and the federal lists, an exercise neither the prosecutor’s offer sheet nor the defendant’s intuition performs unaided; and the immigration-safe plea—the substituted count, the 364-day sentence—is a known technology, available where counsel on both sides know to ask for it and invisible where they do not. A large share of the conviction-based removals in section 4’s series originated in that room, on charges whose immigration valence nobody at the table had priced. The desk files this as the plea system’s operating description, supplied by the Supreme Court itself.
The time dimension completes the exposure: deportability has no statute of limitations. A conviction entered in the third year of a residence may be charged in the thirty-seventh, when it surfaces—in a naturalization fingerprint check, a travel screening, a later arrest’s booking referral—and the government’s delay is no defense in the proceeding. Lawful permanent residence does not ripen: there is no term of years after which the §237 list ceases to apply to the resident, no doctrine of repose in the deportability statute, and the resident’s protection is therefore never his longevity but only the absence of a chargeable event and the presence, if charged, of a relief whose character elements his record still satisfies. Exactly one event ends the exposure, and it is the subject of section 10: naturalization, after which the former resident is a citizen, removable no longer, and answerable to the immigration law only through the narrow door of denaturalization for fraud in the procurement itself. The exposure ledger and the definitions ledger are the same ledger read at two ends: between admission and oath, the resident carries the list; the oath is the only discharge the book provides.
9. Virtue Is Not a Defense: What the Statute Asks and What It Does Not
The grounds of removability in INA §237 contain no character credit. Read as a list—and section 3 above is the list—the grounds are categories of status and conduct: admitted or not, registered or not, convicted or not, of enumerated offenses, within enumerated periods. No subsection asks whether the respondent is industrious, charitable, devout, beloved, or the support of a household; no defense in the proceeding consists of being good. The statute’s character inquiry exists, but it is stationed elsewhere, and the placement is the point: “good moral character” is an element of benefits and relief—a condition of naturalization under §316(a), of cancellation of removal under §240A(b)(1), of post-conclusion voluntary departure under §240B(b)—where it operates as a gate the applicant must pass, defined in part by a disqualifier list at §101(f) that includes habitual drunkenness, certain convictions, and false testimony. Character, in the statute’s architecture, can qualify a person for mercy or for membership; it cannot excuse a status violation, because the violation is not charged as a failure of character. The removable saint and the removable felon stand in the same posture before §237, differentiated only by the relief each can reach—and the desk notes, as a matter of the same record, that the relief map is itself drawn in conduct: the felon’s aggravated felony closes doors the saint’s clean record leaves open. The system is not indifferent to virtue out of absent-mindedness. It is built so that virtue is currency in the relief market and legal tender nowhere else.
The public debate poses its version of the question through a hypothetical: a figure of universal charitable reputation—the standing example is Mother Teresa of Calcutta, Albanian-born, a citizen of India, founder of the Missionaries of Charity—entering the United States to do religious work without status. On the statute as written, she would be removable, because the grounds in section 3 would apply to her as to anyone, and her works would appear in her case only as equities in a discretionary request. The record files what the hypothetical leaves out. A dedicated lawful channel exists for exactly her case and has for generations: the R-1 nonimmigrant classification at §101(a)(15)(R) admits religious workers—ministers and persons in religious vocations, members of a denomination with a bona fide nonprofit religious organization in the United States, coming to work for it—for up to five years, and the EB-4 special-immigrant category admits religious workers to permanent residence. And the historical case itself ran through the law’s front door and past it: by Public Law 104-218, enacted October 1, 1996, Congress conferred honorary citizenship of the United States on her, making her one of eight persons so honored in the republic’s history and one of two—with Winston Churchill, in 1963—honored in her lifetime. The State Department’s own manual (8 FAM 306.1) records the honor’s legal content: honorary citizenship confers no special entry, travel, or immigration benefits, and its holder is not eligible for a United States passport. Which is to say, the republic’s highest civic compliment left its recipient’s immigration position exactly where the statute put it, and the honor and the removability coexisted in the same file without contradiction, because they answer different questions. The desk files the exhibit at that temperature: the removability grounds ask nothing about character; the channels exist; the actual case used them.
10. “Naturalization”: A Definitions Section
The word does one job in the statute and another in the argument, and the desk files both. In law, naturalization is the defined process by which a person not born a citizen becomes one, at INA §§310–347 (8 U.S.C. §§1421–1459). Its core requirements stand at §316(a): the applicant must be a lawful permanent resident for five years (three, under §319(a), if married to and living with a citizen); must show continuous residence and physical presence for at least half that period; must show good moral character for the statutory period against the §101(f) disqualifiers; must demonstrate English proficiency and knowledge of United States history and government under §312, subject to age, disability, and long-residence exceptions; must show attachment to the principles of the Constitution; and must take the oath of allegiance at §337, renouncing prior allegiances. Citizenship so acquired is near-absolute against the state: it can be undone only by denaturalization in federal court under §340, for illegal procurement or material concealment in the process itself—a door the government has used sparingly and the courts supervise closely. Beside the statutory word stands the colloquial one, in which long residence is said to “naturalize” a person into a place—to make him, in substance, of it—with entitlement argued to follow from the substance. United States law contains no such ripening for the non-resident, and it contains exactly one fossil of the idea: the registry provision, §249, which permits a person of good moral character present since a fixed date to register into residence—a date Congress set at June 28, 1940 in 1929, advanced by stages to June 30, 1948, and last advanced by the Immigration Reform and Control Act of 1986 to January 1, 1972, where it has remained for forty years, a door built for a generation that has now passed through it or died. Residence ripens into status by rule in other systems on the shelf—the European Union’s long-term resident status attaches after five years of legal residence under Council Directive 2003/109/EC—and the desk files the contrast as it files the others: a design choice, present there, absent here, its presence or absence a fact about statutes and not about the worth of the residents.
Acquisition at birth, the other door, runs on two principles whose distribution is itself a ledger. Jus soli—citizenship by birth on the territory—is the rule of the United States under the Fourteenth Amendment and INA §301(a) (“born in the United States, and subject to the jurisdiction thereof”), and of most of the Americas, Canada and nearly all of Latin America included. Jus sanguinis—citizenship by descent—is the rule of most of Europe and Asia, transmitted through a citizen parent wherever the birth occurs; the United States applies it abroad at §301(c)–(g) beside its soil rule. Pure forms are now rare: Germany, the historic sanguinis case, added a soil element in 2000 for children of long-resident foreigners; Ireland restricted its soil rule by referendum in 2004, the last European state to retire an unconditional one; France mixes both with residence-based acquisition at majority; Israel’s Law of Return is a descent-and-identity rule of its own kind. The desk’s observation is bookkeeping: every state on earth assigns membership at birth by some combination of soil and blood and then administers a defined door—naturalization—for everyone else, and the definitions, not the affections of the public, are what the doors are made of. What the colloquial usage asks for is that the door be deemed walked through by time served. No statute on the shelf deems it; some legislatures have built versions of it; the American registry stands in the book with its date unadvanced since 1986.
11. The Public Vocabulary: Two Phrases and a Frame, Examined
The desk applies its definitions instrument to the phrases the argument is conducted in, beginning with the enforcement side’s. “Bad hombres” entered the record in the third presidential debate of October 19, 2016, at Las Vegas, in the Republican nominee’s answer on immigration: “One of my first acts will be to get all of the drug lords, all of the bad ones—we have some bad, bad people in this country that have to go out. We’re going to get them out; we’re going to secure the border. And once the border is secured, at a later date, we’ll make a determination as to the rest. But we have some bad hombres here, and we’re going to get them out.” Grammatically the phrase names a class—in context, the drug lords and the “bad ones”—and the sentence around it makes a testable promise with two parts: enforcement’s first acts would fall on the criminal class, and the disposition of “the rest” would be determined later. The desk tests the promise against the record it has already filed, in section 4’s series, and states the fit plainly: in every year in the series, including the years of explicit priority enforcement before the phrase was coined and the years after, the convicted were a majority of interior removals—82 percent in fiscal 2013, 91 percent in 2015, 93 percent criminal-involved in 2024—and a minority of removals overall wherever the border fast tracks supplied the volume, falling to 32.7 percent conviction-or-charge in fiscal 2024 and lower in 2025, because the majority of the removed in the modern system are processed where they are caught, at the border, a population selected by geography rather than by record. The phrase’s class exists in the data; it has never described the whole of the removed, and in the most recent years it describes the smallest share of them since ICE began publishing the split. Whether that arithmetic honors or betrays the promise of October 2016 is an argument the desk leaves to its makers; the instrument’s reading is that the promise was kept in the interior, where it could be targeted, and swamped in the total, where it could not.
The opposition’s phrase is of a different grammatical species, and the desk files it as what it is: a claim about legitimacy, not about law. “No one is illegal on stolen land”—of uncertain coinage, in mass circulation on signs and murals by the late 2010s—asserts that the enforcing sovereign holds its territory by conquest, and that a title so acquired cannot make presence wrongful. As logic, the premise addresses the legitimacy of the United States’ jurisdiction, not the content of the Immigration and Nationality Act; nothing in the sentence engages §212 or §237, and it would stand or fall identically if both were repealed tomorrow and replaced. As law, it is not cognizable in the forum where removals are decided: an immigration judge’s jurisdiction runs to the statute and the regulations, challenges to the court’s authority over the respondent are resolved against the challenger as a matter of course, and the doctrinal ground was settled a century before the phrase—the federal power over admission and removal is an incident of sovereignty, in the line of cases from the Chinese Exclusion Case, 130 U.S. 581 (1889), through Fong Yue Ting v. United States, 149 U.S. 698 (1893), which held removal to be not punishment but the withdrawal of a privilege of residence, a holding never overruled. The forums in which the premise could be acted on are the legislative and constitutional ones—a Congress persuaded by it could repeal the bars, a constitutional amendment could restructure the power—which is to say the phrase is a political argument wearing a legal sentence’s clothes, and graded as politics it competes with other politics. The desk adds its one filed observation, as comparative record rather than rebuttal: the premise, taken at full strength, runs against every state on earth, since every administering state on the shelf—Canada, Australia, New Zealand, Mexico, and the European states included—governs entry on land acquired by conquest at some depth in its history, and each of them keeps a removals ledger of the kind filed in section 6. A principle that invalidates all of them equally distinguishes none of them, and the desk files it, at that grade, in the ledger.
The third specimen is not a phrase but a frame the two phrases share, stated here in its holders’ strongest form before it is graded. The deservingness frame holds that removal operates, or should operate, as a judgment on the person—that the good should be unremovable because good, and, in its mirror form, that the removed are by the fact of removal shown bad. Its articulated grounds, as its holders state them, are four: family unity—that removal of a parent or spouse inflicts a punishment on citizen family members who have violated nothing, a ground Congress itself has written into the hardship provisions of the statute; the 1986 precedent—that the legislature has once before converted long residence into status at scale, and a mechanism enacted once is a policy available again, not a category error; the prosecutorial-discretion tradition—that enforcement has always ranked its targets, from the deferred-action programs to the priority memoranda of successive administrations, so that selection by equities is the system’s own practice rather than an import; and reliance—that decades of tolerated presence, tax filings accepted under individual taxpayer identification numbers, and licenses issued by the states constitute a course of dealing on which lives were built in reasonable reliance. Graded against the record in this report, the frame in both its directions misdescribes the removability machinery it addresses: the grounds ask nothing about desert (section 9); the criminal series shows the removed to be, in the majority of recent years, persons with no conviction at all (section 4); and the resident’s exposure turns on charging decisions and sentence lines rather than on any assessment of his deserts (section 8). The grounds its holders cite are real—each is documented in the statute, the precedent, or the enforcement record cited—and each operates, where it operates, at the relief, discretion, and legislative stages of the system rather than at the removability stage the frame describes. The desk files the frame at that grade, and proceeds to the scale of the machine itself.
12. Scale: The System in Numbers
The machine’s dimensions, filed with their years and their counters, because the counters disagree in instructive ways. Removals. Counting ICE’s removals only: 142,580 in fiscal 2023; 271,484 in fiscal 2024; about 320,000 in fiscal 2025 by USAFacts’ compilation, 329,018 by the independent reconstruction from ICE’s biweekly releases; and 356,389 in fiscal 2026 through July 11, 2026, by ICE’s figures as reported—against a department-wide DHS removal count of 183,360 for fiscal 2023 and 329,990 for fiscal 2024 in the Office of Homeland Security Statistics’ series, which folds in CBP-executed removals, and a modern single-year record of 438,421 total removals set in fiscal 2013. The two families of numbers measure different machines—one agency’s execution docket against the department’s whole ledger—and any public figure for “deportations” that does not name its counter is filed by this desk as incomplete on its face. The courts. TRAC’s case-level count puts the immigration-court backlog at 3,037,800 pending cases at the end of September 2026, of whom 2,259,317 have filed asylum applications; EOIR’s aggregate tables print higher figures—3,722,776 at the end of fiscal 2025, 3,469,569 at fiscal 2026’s third quarter—the two series counting cases and files by different rules; the Justice Department recorded a decline of more than 447,000 from January 2025 to September 2025 against its own earlier peak above 4.18 million, while immigration judges issued 485,456 removal orders in fiscal 2025, up 57 percent on the year, 306,557 of them in absentia, by the Congressional Research Service’s figures. The court that carries this sits 557 judges, down from 735 at the fiscal 2024 peak. The dockets. ICE’s non-detained docket: above 7.6 million at the end of fiscal 2024; 7.3 million in February 2026 (CRS), carrying an estimated 1.6 million final orders, up from 1,445,549 counted in November 2024. Detention. On July 11, 2026, by TRAC’s tabulation of ICE data, 65,765 people were in ICE detention, of whom 70.6 percent—46,436—had no criminal conviction and 39.8 percent had neither a conviction nor a pending charge; the alternatives-to-detention population stood at 183,181; the detained count had touched roughly 73,000 at its late-2025 peak, a record, against funded capacity built for a fraction of it. The staff. ERO’s deportation officers numbered about 6,100 before 2025; the July 2025 reconciliation act carried $75 billion for ICE, including funding to hire 10,000; federal personnel data put the agency’s total workforce at about 20,000 in December 2025 and 29,000 in July 2026, with nearly 12,000 hired between January 2025 and June 2026, the agency announcing in January 2026 that its officer and agent ranks had grown from 10,000 to 22,000—and more than 2,900 employees departing in the first half of 2026, the highest half-year attrition in the agency’s records. The desk files the growth and the churn in the same line, as the personnel data files them.
13. The Public’s Model: What the Polls Say the Country Thinks the Law Is
The desk grades one more claim set: the public’s own account of what the law should be doing, measured by the pollsters of record. The Pew Research Center’s survey of June 2–8, 2025 found 65 percent of American adults saying there should be a way for immigrants living in the country illegally to stay legally if certain requirements are met—36 percent for a path that includes eligibility for citizenship, 29 percent for permanent residence without citizenship—against 31 percent favoring a national deportation effort. The same question read 64 percent in Pew’s August 2024 survey, down from 75 percent in 2020: the legalization majority is durable and narrowing. Pew’s companion survey of February 24–March 2, 2025 asked the removal question in the form this report has used throughout—all, some, or none—and recorded 32 percent for deporting all, 51 percent for deporting some, 16 percent for deporting none. Inside the selective majority, the sorting is nearly unanimous at the top and collapses as the criteria soften: 97 percent would deport those who committed violent crimes—97 percent of Republicans and 97 percent of Democrats within that group—52 percent those who committed nonviolent crimes, 44 percent those who arrived within the past four years, and 15 percent those who have a job. The Harvard CAPS–Harris polling of July 2025 found 79 percent favoring deportation of those here illegally who have committed crimes. Gallup’s review of February 14, 2025, “The Complex Landscape of Public Opinion on Deportation,” adds the methodological finding the desk files as the section’s caution: six probability polls in January 2025 asking the general deportation question in different wordings produced results from evenly split to 66–32 in favor, and in Gallup’s own earlier reading 70 percent favored a citizenship path with requirements while 47 percent simultaneously favored deporting the same population—the two majorities overlap, because the public is answering about different people under one label.
Stated as a doctrine, the public’s model prices time, work, and family as equity—and the statute prices two of the three in the opposite direction. The polls’ internal structure is consistent across houses and wordings: recency aggravates (the arrival of the last four years is the most deportable non-criminal class polled), employment mitigates nearly to zero, citizen children and long residence suppress support for removal wherever a question names them, and violent crime forfeits everything. It operates, in the language of this report, as a ripening doctrine: presence compounded by conduct becomes a claim. The statute book contains no such doctrine for the unauthorized. Time spent in unlawful presence compounds liability—the §212(a)(9)(B) bars lengthen with it, from three years to ten to, on a reentry, permanent—and residence alone has never adjusted anyone’s status since the registry froze. Exactly one provision in the current book weighs time for the respondent, and the desk prints it precisely because it is the public model’s only statutory relative: cancellation of removal under §240A(b), which requires ten years of continuous physical presence—the statute’s own decade—plus good moral character, plus a showing that removal would cause exceptional and extremely unusual hardship to a citizen or resident spouse, parent, or child, a standard the Board construed in Matter of Monreal-Aguinaga, 23 I&N Dec. 56 (BIA 2001), as hardship substantially beyond what would ordinarily be expected from a relative’s deportation, assessed on the factor line descending from Matter of Anderson, 16 I&N Dec. 596 (BIA 1978)—the qualifying relative’s age, health, and conditions in the destination country among them—all under an annual cap of 4,000 grants. Its ancestor operated at scale once: the Immigration Reform and Control Act of 1986 legalized roughly 2.7 million people on the basis of residence since 1982, and the registry at §249, the older mechanism of the same kind, still stands in the book at its frozen date of January 1, 1972. The desk’s conclusion is that the public is not inventing its doctrine from nothing; it is remembering, in poll answers, a mechanism its legislature last ran in 1986 and last advanced forty years ago—while the operative statute runs, on every day since, in the compounding direction.
14. The Exploitation Ledger: Who Captures the Value of Precarity
A population that cannot safely complain is a priced asset, and the file of who collects on it is adjudicated, not anecdotal. The desk files the case record of this section in the order the machinery runs: the crossing itself, the plants the crossed labor feeds, the visa channels that deliver workers already indebted, and then the two anchor judgments. The anchor judgments come last in that order; the section’s largest adjudicated exhibit is the first of them filed here. After Hurricanes Katrina and Rita, Signal International recruited nearly 500 welders and pipefitters from India into the H-2B guestworker program on promises of permanent residence the program cannot confer. The men paid recruiters and a lawyer between $10,000 and $25,000 each—borrowed, in the record, against land, jewelry, and high-interest village loans—and were charged $1,050 a month to live in guarded labor camps in Mississippi and Texas. On February 18, 2015, a federal jury in David v. Signal International found labor trafficking, forced labor, and racketeering, and awarded more than $14 million to the first five plaintiffs; the case stands among the largest labor-trafficking matters in the country’s record. The Thai file runs parallel: in EEOC v. Global Horizons, the courts found a labor contractor had trafficked hundreds of Thai H-2A farmworkers to Hawaii and Washington farms between 2003 and 2007—passports confiscated, movement restricted, deportation used as the standing threat—entering a pattern-or-practice liability ruling in 2014, $8.7 million in damages in the Hawaii case after settlement offsets (the farms themselves settled for $1.2 million and $2.4 million), and a further $7,658,500 award in the Washington case in 2016. The mechanism both juries priced is written into the criminal code: the forced-labor statute, 18 U.S.C. §1589, names as coercion the threat of serious harm and “abuse or threatened abuse of law or legal process”—which is to say, the threat of deportation itself is an enumerated instrument of the crime. The scale instruments bound the adjudicated floor: the National Human Trafficking Hotline recorded 30,162 substantive signals in 2023, identifying 9,619 potential cases involving 16,999 potential victims, of which 1,558 situations were classified labor trafficking and 1,021 more combined labor and sex trafficking; the Department of Homeland Security counted about 1,300 trafficking investigations and more than 2,300 arrests the same year. Between the hotline’s thousands and the courtroom’s dozens lies the unlitigated balance, whose size no instrument measures—the desk files the floor and the darkness above it in the same sentence, as it found them.
The crossing is the first collection point, and its prices are a matter of sentencing records. In the Central District of California, Eduardo Domingo Renoj-Matul was sentenced in 2025 to 262 months in federal prison after pleading guilty to conspiracy and hostage taking: his organization moved about 20,000 Guatemalans between 2019 and July 2024 at fees of $15,000 to $18,000 a person, collected in Guatemala, and the unpaid were held at a stash house on James M. Wood Boulevard in Los Angeles until the fee was paid—release contingent on payment, which is the definition of the hostage mechanism in commercial form. In the Western District of Texas, Enil Edil Mejia-Zuniga was sentenced in July 2025 to ten years for an organization that moved 2,500 to 3,000 people at $6,500 to $12,000 a head—$16 million to $30 million in receipts by his own admission—through stash houses in Monterrey and Piedras Negras, paying armed guides, drivers, and stash-house operators from the take. The hotel at the end of the crossing is of the same kind: the guilty pleas in the June 2022 San Antonio tractor-trailer case, in which fifty-three people died in a trailer whose air conditioning failed, record fees of up to $15,000 a person. The fee is charged before the labor begins, and it is the balance against which the next collectors in this section—the recruiters, the contractors, the employers—hold their leverage, because a worker who arrives owing five figures cannot walk away from the first workplace that takes him.
The plants the labor feeds are documented by the Labor Department’s own enforcement files, and the recurring defendant is a contractor, not the brand on the building. Packers Sanitation Services Inc., of Kieler, Wisconsin—one of the nation’s largest food-sanitation firms—paid $1,544,076 in civil penalties in February 2023, assessed at $15,138 per child, after the Wage and Hour Division found at least 102 children aged thirteen to seventeen working overnight shifts cleaning back saws, brisket saws, and head splitters with hazardous chemicals at thirteen meat-processing plants in eight states, plants operated by JBS, Tyson, Cargill, and others; at least three of the children were injured. The department’s release does not state what share of the 102 were migrant children, and the desk files the count as the department states it, without the status mix the public account assumes. Fayette Janitorial Service LLC, of Somerville, Tennessee, entered a consent judgment in May 2024 to pay $649,304 after investigators found at least twenty-four children, some thirteen, on overnight sanitation shifts at Seaboard Triumph Foods in Sioux City, Iowa, and at Perdue Farms’ plant in Accomac, Virginia—kill-floor equipment cleaned with corrosive chemicals—and in November 2025 a federal grand jury in the Eastern District of Virginia unsealed an indictment charging former Fayette personnel with conspiring, from October 2020 to January 2024, to supply undocumented workers, children among them, with fraudulent identification to work at the Accomac plant; the criminal case is an indictment, not a verdict, and a fourteen-year-old’s severe arm injury at that plant in February 2022 is what opened the file. Mar-Jac Poultry supplies the fatality. On July 14, 2023, Duvan Tomas Perez, sixteen, a Guatemalan immigrant placed at the company’s Hattiesburg, Mississippi, plant by a staffing agency, was pulled into a still-energized deboning machine while deep-cleaning it, with no lockout device in place; OSHA had proposed $212,646 for the failure, and the company settled in August 2024 for $164,814 with enhanced sanitation-shift supervision and training. The department’s wage division then found, at Mar-Jac’s Jasper, Alabama, plant, minors as young as thirteen, fourteen- and fifteen-year-olds eviscerating poultry, operating forklifts, and working the kill floor on overnight shifts; the consent judgment of May 21, 2025, assessed $385,000, on top of $150,000 assessed after the Mississippi investigation found seven minors in prohibited occupations there. In Ohio, the mechanism ran without a plant defendant: in 2014 and 2015, a labor contractor recruited Guatemalan boys of fourteen and fifteen on promises of good jobs and schooling, smuggled them north, and held them in dilapidated trailers in Marion, Ohio, working twelve-hour days at Trillium Farms’ egg operations—cleaning coops, de-beaking and vaccinating chickens—their paychecks withheld against smuggling debts until the FBI freed eight minors and two adults named in the indictment. The ring’s leader, Aroldo Castillo-Serrano, was sentenced to 188 months; his co-defendants drew ten years, fifty-one months, fourteen months, and shorter terms; Trillium itself was not charged, its labor having arrived, as in the sanitation cases, through a contractor.
The older file of the same industry is a court of appeals opinion, and it records the hiring logic in the employer’s own words. Case Farms’ Morganton, North Carolina, plant was staffed from 1989, when its human-resources manager drove a van to Indiantown, Florida, and recruited Guatemalan refugees from a Catholic parish there—the account is in Leon Fink’s The Maya of Morganton, drawn from the manager’s own interviews, and the reason he gave for preferring Guatemalans was the leverage itself: “Guatemalans can’t go back home. They’re here as political refugees. If they go back home, they get shot.” By the representation election of July 12, 1995, roughly 80 percent of the plant’s 514 eligible voters were Latino, nine in ten of those Guatemalan, and more than 70 percent were noncitizens, on the Fourth Circuit’s own recitation of the record in Case Farms of North Carolina v. NLRB, 128 F.3d 841. The workers struck in May 1995, the union won 238 to 183, the company refused to bargain, and the Board’s bargaining order was enforced by the court in 1997—the legal victory arrived, and no contract followed in the six years of talks that preceded the union’s withdrawal. The safety record is the Labor Department’s: sixty-six inspections between 1988 and 2015 produced citations in forty-two; in August 2015 OSHA assessed $861,500 at the Winesburg, Ohio, plant—two willful, twenty repeat, thirty serious violations—and placed the company in the Severe Violator Enforcement Program; in September 2015 it proposed $424,600 more at Canton, Ohio, where a seventeen-year-old employed by the cleaning subcontractor Cal-Clean lost his lower leg to a chiller machine he was cleaning and a Case Farms employee lost two fingertips the same spring; in December 2015 it proposed a further $462,000 for ammonia-refrigeration failures at the two Ohio plants—more than $1.4 million proposed for the year, in the department’s own arithmetic, each figure a proposal the company contested rather than a sum adjudicated. The pattern across three decades of this file is not a status count; it is a sequence: recruitment aimed at workers whose exit is blocked, a union answered with litigated delay, and the most dangerous cleaning assigned, in the later record, to a subcontractor’s employee.
The personal-service trades file their own version, in which the wage structure itself was the exhibit and the state, not a court, was the respondent. In May 2015, The New York Times’ investigation of New York’s nail salons—more than 150 workers and owners interviewed in four languages—documented the trade’s entry price: new manicurists paying a training fee of about $100 for the job itself, working weeks for tips alone, then starting at $30 or $40 a day, with day rates as low as $10 in the advertisements the paper examined; a majority of the workers interviewed were paid below the minimum wage, overtime was effectively unrecorded, and deductions for mistakes came out of pay—the average New York City manicure then cost about $10.50, roughly half the national figure, and the arithmetic of the price was the arithmetic of the wage. The investigation is journalism, filed in this report’s clippings under its subjective stamp, and it was contested in its particulars by other journalists within the year; what is not contested is the enforcement record it triggered, which is the state’s own. New York’s Labor Department had already found 116 violations in a 2014 sweep of twenty-nine salons. Within days of publication in May 2015 the governor imposed emergency regulations and a multi-agency Nail Salon Industry Enforcement Task Force; legislation signed that July imposed ventilation and protective-equipment rules and required every salon to carry a wage bond or insurance sufficient to cover back-wage awards, so that a judgment for stolen wages would have something to collect against; and on the task force’s first anniversary the state announced investigations opened into more than 450 salons and orders against 143 of them to pay $2 million in unpaid wages and damages to 652 workers. The desk files the sequence as it files the others: a documented wage structure, a state response measured in opened investigations and dollars ordered, and a retail price to the customer that the record ties to the wage structure beneath it.
The exchange-visitor channel runs the same economics at the level of the program’s design, and its two adjudicated exhibits are a warehouse and a courtroom. The J-1 visa is the State Department’s, administered not by the department but by designated private sponsors, who charge the participant program fees—commonly several thousand dollars, paid to the sponsor and its overseas recruiting partners before departure, frequently borrowed—and whose fees the program, uniquely among the guestworker channels, does not prohibit. The Southern Poverty Law Center’s 2014 report Culture Shock, filed as a clipping below, records the resulting inventory from hundreds of interviews: students placed in low-wage, long-hour jobs with little of the cultural content the visa exists for, employers relieved of the payroll taxes the channel exempts, and workers carrying sponsor debt into workplaces they cannot leave without ending their lawful presence. The warehouse exhibit is Hershey’s, and its structure is the section’s mechanism in one address: the Eastern Distribution Center III in Palmyra, Pennsylvania, was Hershey’s building, operated by the logistics contractor Exel, staffed through the SHS Group, which recruited J-1 Summer Work Travel students through the sponsor CETUSA. About four hundred students were put to night-shift work lifting fifty-pound boxes on a fast line at $8.35 an hour, charged about $395 a month for required housing, deducted from pay; on August 17, 2011, they walked out. The Labor Department’s settlement of November 14, 2012, recovered $213,042 in back wages for 1,028 students—the housing deductions had taken pay below the minimum wage and overtime had gone unpaid—and resolved $143,000 in OSHA fines against Exel for noise and safety violations at the facility. Hershey was not cited: it held no payroll in the chain. The State Department’s answer was programmatic—the May 2012 rule, still posted in the program’s exclusions, bars Summer Work Travel placements in warehousing, in goods-producing industries, and in jobs whose hours fall predominantly between 10 p.m. and 6 a.m. The courtroom exhibit is Beltran v. InterExchange, in which the designated sponsors of the J-1 au pair program were sued for conspiring to hold some 100,000 au pairs’ pay at a represented “fixed” rate of $195.75 a week; the sponsors settled in 2019 for $65.5 million, approved by the federal court in Colorado that August, without an adjudication of the conspiracy. The channel’s ordinary employments are documented by the sponsors’ own market: pool-management companies such as High Sierra Pools, operating more than a thousand commercial pools in the mid-Atlantic, recruit J-1 lifeguards by the hundreds each summer through overseas agencies, with employer-arranged housing deducted at published weekly rates, and summer camps and amusement parks staff their seasons from the same pool of students. For those employments the desk finds usage, fee schedules, and the SPLC’s interview record—and no adjudicated case of the kind this section files. Which brings the file to the name the public account attaches to the category.
On the record this section is built from, the amusement-park case does not exist. Disney’s documented immigration-labor litigation runs the other direction: in 2015 Walt Disney World replaced about 250 of its own information-technology employees with workers supplied by the outsourcing firms HCL and Cognizant on H-1B visas, required the departing Americans to train their replacements as a condition of severance, and was investigated by the Labor Department, which closed the matter without a violation—the H-1B workers were the contractors’ employees, not Disney’s, which was the legal point and the whole of it. Of J-1 or H-2B exploitation of foreign workers at Disney’s parks, adjudicated or charged, the desk finds no case in the record; what circulates on the subject is program-usage reporting and advocacy summary, which the desk does not file as findings. The finding the record does support is structural, and it is the one this section has been assembling: at the brand-name end of American leisure and food, the precarious worker is almost never on the brand’s payroll—he is on a sanitation contractor’s at the Tyson plant, a staffing agency’s at Mar-Jac, a logistics contractor’s at Hershey, an outsourcing firm’s at Disney—and the contractor layer is where the department’s penalties, the juries’ verdicts, and the indictments in this file consistently land.
The same tether operates inside the lawful channels, at professional wages, by design of the statute rather than by crime. The H-1B worker’s status is his employer’s petition: lose the job and a regulation of 2017 allows up to sixty days to find a new sponsor, change status, or depart. Behind him stands the employment-based green-card queue, capped at 140,000 a year worldwide with no country permitted more than 7 percent; the Cato Institute’s analysis of the government’s data puts the backlog at roughly 1.8 million people, about 1.1 million of them born in India, and the National Foundation for American Policy’s count of the queue in December 2025—1,264,495 people, 79 percent of them Indian—projects, at current rates, a wait of 179 years for an Indian national entering the second-preference queue today; the October 2026 Visa Bulletin was processing Indian second-preference applications filed in 2013. The result is a class of lawful residents a decade and more deep in American life—mortgages held, citizen children in school, careers compounded—whose presence renews annually at an employer’s pleasure and whose exposure, if the tether breaks, runs through the same overstay arithmetic as section 3’s. No one in this paragraph has violated anything; the precarity is a feature of the channel’s design. The desk closes the section with the pattern the adjudicated record supports: at every level of the system examined in this report at which a capture was litigated, the gap between a person’s economic value and his legal security was captured by someone—by the smuggler in the fee, by the recruiter in the debt, by the employer in the discount and the discipline, by the camp landlord at $1,050 a month a man. The desk files the pattern as the section’s finding, bounded by the cases that compose it; what enforcement or legalization would do to the pattern is a policy question the record does not answer, and the desk does not answer it here.
15. The Error File: Citizens, Wrongful Removals, and the Critics’ Claims on the Same Instrument
The critics’ central factual claim—that the machine removes people it has no authority to remove, including citizens—is documented by the government’s own auditors, at a scale those auditors themselves bound. The Government Accountability Office’s report GAO-21-487 (July 2021), examining fiscal 2015 through the second quarter of fiscal 2020, found that ICE had arrested 674, detained 121, and removed 70 individuals across the period whom its records identified as potential United States citizens; that detainers had been issued against at least 895 potential citizens, about 74 percent of them cancelled before action; and that ICE’s data on citizenship claims were too inconsistently recorded for the counts to be treated as more than floors. TRAC’s separate examination of the longer record counted at least 2,840 people wrongly flagged as removable between 2002 and 2017. Citizenship in these cases typically turns on derived and acquired citizenship through parents—the most documentarily tangled corner of the statute book—and the desk files the auditors’ own caveat with their counts: the record system that produces the removals does not reliably record the claims that would impeach them, so the true figure is unknowable from the published instruments, bounded below by the audits and asserted above them by advocates without an instrument of their own. The claim of wrongful removal of citizens is therefore filed as documented-but-small, with its denominator problem stated, and the claim of its nonexistence is filed, against the GAO, as disproven.
The single most litigated error of the current period is a matter of court record, and the desk files the record. In October 2019 an immigration judge granted Kilmar Abrego Garcia, a Salvadoran national who had entered without inspection in 2011, withholding of removal to El Salvador on a finding of likely persecution there, while leaving a removal order in place as to other countries. On March 15, 2025, he was removed to El Salvador and confined in its CECOT prison. In litigation filed by his family (Abrego Garcia v. Noem, No. 8:25-cv-00951, D. Md.), the acting ICE field office director declared under oath on March 31, 2025, that “[t]hrough administrative error, Abrego-Garcia was removed from the United States to El Salvador,” the removal having been carried out “in good faith based on the existence of a final order of removal” and the withholding grant overlooked. The district court ordered the government to facilitate and effectuate his return; the Supreme Court, on April 10, 2025, required the government to facilitate his release from custody in El Salvador. He was returned to the United States on June 6, 2025—into federal criminal custody, under a Tennessee indictment charging human smuggling, to which he has pleaded not guilty and against which a motion to dismiss for vindictive and selective prosecution is pending; the civil and criminal litigation continue at filing. The desk files the case for the machinery it exhibits and for nothing else: a subsisting court order was not executed by the system that held it, the error was conceded in the government’s own declaration, the judiciary’s corrective process ran for twelve weeks across two court systems and an international negotiation, and its resolution arrived fused with a prosecution. Claims that the case proves the system lawless, and claims that it proves the system self-correcting, are both filed as interpretations; the instrument records the sequence.
The conditions under which the machine holds people are litigated on the same record, and the desk files the litigation beside the error file. Deaths in ICE custody reached 38 in fiscal 2026 on the agency’s published detainee-death reports, the highest annual count in its series, up from 11 in fiscal 2024 and fewer than ten in earlier recent years on the Kaiser Family Foundation’s analysis of the agency’s own death reporting; the same analysis records that most of the 2025–2026 deaths involved people with existing medical conditions whose health deteriorated in custody. The administration’s detention expansion—a detained population that touched roughly 73,000 at its late-2025 peak against funded capacity built for a fraction of it (section 12)—has been accompanied, in 2025, by the winding down of the department’s internal detention-oversight offices, the Immigration Detention Ombudsman among them, a reduction Senate oversight letters of 2026 protest and the department defends as reorganization. The courts have entered the file directly: in late 2025 a federal judge issued a preliminary injunction ordering ICE to provide adequate health care and access to counsel to people detained at the California City facility, the state’s largest, after findings of unsanitary conditions and inadequate medical and mental-health care. The agency’s stated position, in its detention standards and its responses to the oversight letters, is that detainees receive comprehensive medical care, screening within hours of arrival, and round-the-clock emergency care. The desk files the injunction, the death series, and the oversight reduction as the adjudicated and official record of the conditions claim, and the agency’s standards as its stated answer; which account the full record supports, facility by facility, is a question the published instruments answer only in pieces, and the desk files it at that grade.
16. The Ledger
The whole subject, sorted by the state of its evidence. The desk closes the file with the four-column accounting the report has applied throughout, to every side’s claims at the same grade. Verified: established by statute, official record, or adjudication. Documented-but-small: real, proven, and measured against a baseline that bounds its size. Claimed-but-unproven: asserted by named makers, with no instrument at the scale claimed. Disproven: tested by the instrument built to test it and failed.
| Verified | Documented-but-small | Claimed-but-unproven | Disproven |
|---|---|---|---|
| Unlawful presence is a civil violation, not a crime (Arizona v. United States); improper entry and reentry after removal are crimes (8 U.S.C. §§1325–1326). The ladder runs NTA, hearings, BIA, final order, with expedited, administrative, and reinstatement tracks beside it. A removal order carries 5/10/20-year and permanent bars (§212(a)(9)(A)); voluntary departure carries no removal-order bar. Overstays have exceeded border entries among new unauthorized residents since about 2007 (CMS); 538,548 overstay events were counted in fiscal 2024 (DHS). The Schengen clock is cumulative, 90 in 180, and Switzerland is inside it. The removability grounds contain no character credit; good moral character gates benefits and relief only. A single ordinary DUI is not a deportability ground (Leocal; Lopez-Meza). Deportability has no statute of limitations; only naturalization ends a resident’s exposure. ICE removed 271,484 people in fiscal 2024, 32.7 percent with convictions or pending charges; the interior cut ran 93 percent criminal-involved. Europeans are removed—1,540 in fiscal 2023—under the same statute as everyone else. The public’s model is measured, not guessed: 65 percent for a requirements-based path to stay (Pew, June 2025); of the selective majority, 97 percent for deporting the violent and 15 percent for deporting the employed (Pew, February–March 2025). Precarity is monetized inside the system as a matter of adjudicated record—recruitment debt, confiscated passports, and deportation threats priced by juries and courts in the Signal and Global Horizons cases. The smuggler’s fee is documented in the sentencing record at $6,500 to $18,000 a person, with the unpaid held in stash houses until it was paid (Renoj-Matul, sentenced to 262 months; Mejia-Zuniga, ten years). At the brand-name end of the food and leisure industries, the exploited worker is on a contractor’s payroll, not the brand’s: PSSI, Fayette, Exel, Cal-Clean, HCL, and Cognizant are where the penalties and settlements in the file land. | Wrongful arrests, detentions, and removals of potential citizens: 674 arrested, 121 detained, 70 removed, fiscal 2015–2020, by the GAO’s audit, whose own caveats make the counts floors. European removals: 1,540 of 183,360 formal removals in fiscal 2023, under 1 percent, against about 61,000 European visa-waiver overstays in fiscal 2024. The Abrego Garcia removal: one case, fully documented, error conceded by the agency in court. Deaths in ICE custody: 38 in fiscal 2026, the highest year in the agency’s series, against tens of thousands detained on any given day. Documented voluntary departures: 6,118 court grants in the first six months of 2025—a real channel, at documented scale. Adjudicated exploitation: more than $14 million awarded in David v. Signal International (2015); $8.7 million and $7,658,500 in the Global Horizons cases (2014–2016); 1,558 labor-trafficking situations identified by the national hotline in 2023—floors, built only from cases that reached an authority. The case record of section 14, each item bounded by its instrument: a 54-count indictment of twenty-four defendants and more than $200 million in alleged proceeds in United States v. Patricio, resolved by guilty pleas running from a year and a day for the first-named defendant to thirty years in the related Mendoza case; $1,544,076 in penalties against PSSI for 102 children on overnight sanitation shifts, and $649,304 against Fayette Janitorial for at least twenty-four, with a criminal indictment of Fayette personnel unsealed in 2025 and untried at filing; $164,814 settled by Mar-Jac Poultry after the death of a sixteen-year-old on its sanitation shift, and $385,000 assessed against its Alabama plant for minors as young as thirteen; 188 months for the leader of the Ohio egg-farm ring that held eight Guatemalan minors against their paychecks; New York’s nail-salon task force ordering $2 million to 652 workers in its first year; $213,042 in back wages recovered for 1,028 J-1 students at the Hershey warehouse; and the J-1 au pair sponsors’ $65.5 million settlement in Beltran, paid without adjudication of the wage-fixing alleged. | DHS’s count of 1.6–1.9 million “self-deportations” in 2025: built on survey population estimates, with no published methodology or departure count beneath it. The claim of a million-scale population of unlawfully present Ukrainians and Eastern Europeans: no DHS table at scale supports it; the measured European overstay stock is real and smaller, and most post-2022 Ukrainians hold parole or TPS. The “80 percent” non-criminal share as a constant of the system: no official series states it; the measured series runs 41 percent non-convicted (fiscal 2013) to roughly two-thirds (fiscal 2024) and higher in 2025. The department’s 622,000-deportations claim for 2025 as a figure comparable to the ICE removal series. That elections—or removals—are administered on any basis other than the statutory one, asserted without an instrument: no specimen at scale has been produced in this file, from any direction. | That a single DUI forfeits a green card under current law: Leocal and Lopez-Meza dispose of it; the bill that would make it so, H.R. 875, passed the House in June 2025 and is not law. That criminals are put in deportation facilities instead of jail: the detainer record shows criminal custody and sentence first, ICE custody after. That the border hop resets the Schengen clock: the 90/180 rule is a rolling cumulative window. That “bad hombres” describes the removed population as a whole: the convicted have been a minority of total removals in every recent year of ICE’s published split. That wrongful removal of citizens does not occur: the GAO’s audit is the disposing instrument. That long residence alone ripens into lawful status in the United States: the registry door stands frozen at January 1, 1972, and no other provision enacts the ripening. That an adjudicated record of J-1 or H-2B exploitation by Disney at its parks exists to be cited: the desk’s search of the enforcement and court record finds none—Disney’s documented case is the 2015 replacement of its own American IT staff by a contractor’s H-1B workers, investigated and closed without a violation. |
As the file stands on Sunday, November 8, 2026: deportation in the United States is an administrative process built on two statute lists—inadmissibility for those at the door, deportability for those admitted—run through a court track with hearings and appeals and three faster tracks without them, ending in bars of five, ten, and twenty years for the removed, no removal bar for the voluntarily departed, and unlawful-presence bars that turn on time accrued however a person leaves; its recent caseload is majority non-criminal in the totals and majority criminal in the interior, its overstay flow has exceeded its border flow among new arrivals for nearly two decades, its court backlog stands above three million cases, its final orders outstanding above 1.4 million, its detention population near record levels with seven in ten detainees holding no conviction, and its statute asks nothing, at the removability stage, about whether the person before it is good; the resident it holds longest is exposed for the whole of his residence to a list of tripwires that never expire until the oath of naturalization discharges them; the government’s own auditors have documented its errors against citizens at small, real scale; and every large claim in the public argument—the millions self-deported, the eighty percent, the criminal flood, the spotless machine—grades, on the instruments available, below the arithmetic the record actually keeps.