Immigration Reform And Control Act Research Articles

Achieving the DREAM: The Effect of IRCA on Immigrant Youth Postsecondary Educational Access

This paper contributes to the existing literature on the effect of legal status on educational access among immigrant youth in the United States. The Immigration Reform and Control Act (IRCA) of 1986 granted amnesty to undocumented immigrants who entered the United States before 1982. Using a difference-indifferences framework, I analyze the effect of this large amnesty program on immigrant youth's postsecondary educational access. My main finding shows that immigrant youths who were granted amnesty under IRCA are more likely to enroll in postsecondary education.

Linking geomorphologic knowledge, RS and GIS techniques for analyzing land cover and land use change: a multitemporal study in the Cointzio watershed, Mexico

It is well-established that changes in land cover and land use (LCLU) are relevant to current local and global changes that are directly linked with food security, human health, urbanization, biodiversity, trans-border migration, environmental refuges, water and soil quality, runoff and sedimentation rates, and other processes. This paper examines LCLU change processes within the Cointzio watershed (Central Mexico). The analysis covers a 28-year time period from 1975 to 2003. LCLU changes were deduced from multi-temporal remote sensing analyses (1975, 1986, 1996, 2000 and 2003). Nearly all of the LCLU changes experienced in the Cointzio watershed occurred during the 1986-1996 period. Half of the 665 km² of the watershed have changed during this period, in what corresponds to a ten-fold increase in the rate of change as compared to the 1975-1986 and 1996-2003 periods. These massive changes are probably related to the Immigration Reform and Control Act (IRCA) of 1986, which limited the transit of undocumented Mexican workers to the United States of America. The methodology applied in this research constitutes a low-cost alternative for evaluating the impact of LCLU change in watersheds. The magnitude of land use change differed during the periods of analyses in the watershed, functional zones and geoforms. The methodological approach applied in this analysis integrates standard procedures to evaluate land cover and land use change in watersheds. Due to the practical value of the results, the data and information generated during the analysis have been made available to local authorities.

The Impact of Legal Status on Immigrants’ Earnings and Human Capital: Evidence from the IRCA 1986

The Immigration Reform and Control Act (IRCA), the largest amnesty in U.S. history, took effect in 1986 and legalized all immigrants who arrived before 1982. The IRCA creates a discontinuity, according to the year of entry, in the probability of having legal status. Therefore, I use the regression discontinuity approach to study the impact of legality on immigrants’ labor market outcomes and human capital. Using Californian Latino immigrants from Census 1990, I find that the 1975–81 arrivals, on average, outperform the 1982–86 arrivals in male wages, female employment probability, and male English-speaking ability. These findings are not due to a general trend in U.S. labor market conditions because the same analysis, using refugees, Puerto Rican migrants and U.S.-born Latinos—three comparison groups without legality issues—indicates no difference in outcomes between the 1975–81 and 1982–86 cohorts. However, the advantage of Latino immigrants of the earlier cohort over the later cohort diminishes in Census 2000.

What Drives Immigration Amnesties?

We develop a general model of legal and illegal immigration to understand the basic tradeoffs faced by a government in the decision to implement an immigration amnesty in the presence of a selective immigration policy. We show that two channels play an important role: an amnesty is more likely the more restricted are the occupational opportunities of undocumented immigrants and the less redistributive is the welfare state. Empirical evidence based on a novel panel dataset of legalizations carried out by a group of OECD countries between 1980-2007 broadly supports the role played by the channels identified in our theoretical model.

Shifts in the employment outcomes among Mexican migrants to the United States, 1976–2009

Although studies have examined the impact of U.S. immigration policy shifts in the 1980s and 1990s on the employment outcomes of migrants, scholars have paid less attention to how the federal government's shifting approach to worksite enforcement has transformed the conditions in which Mexican migrants work. Consistent with previous research, we find a worsening of conditions for both unauthorized and legal Mexican migrants in the years following the passage of the Immigration Reform and Control Act (IRCA) and that unauthorized status is associated with more unfavorable workplace conditions relative to legal immigrants. However, in the first decade of the 21st century, we also find that unauthorized immigrants’ employment outcomes more closely resemble those of legal immigrants now than in the past, suggesting a dramatic shift in the ways that employers treat unauthorized immigrants on the job. This convergence between authorized and unauthorized migrants is consistent with federal policies and practices related to workplace enforcement.

Factors Influencing the Re-Emergence of Immigrant Rights Coalitions in the United States

This study presents findings from research gathered on the landscape, formation, and characteristics of Immigrant Rights Coalitions (IRCs). The author proposes five factors to explain the widespread emergence of IRCs over the past two decades: (a) the passage of the 1986 Immigration Reform and Control Act (IRCA), (b) local law enforcement collaboration with Immigration and Customs Enforcement (ICE), (c) worksite enforcement actions, (d) anti-immigrant legislation, and (e) an increase of Latino immigrants in nontraditional settlement states.

The Impact of Amnesty on Labor Market Outcomes: A Panel Study Using the Legalized Population Survey

This paper tests whether amnesty, a provision of the 1986 Immigration Reform and Control Act (IRCA), affected the labor market outcomes of the legalized population. Using the Legalized Population Survey (LPS) and the National Longitudinal Survey of Youth (NLSY79) from 1987-1992, a quasi-experimental framework is developed to assess the differential impact of amnesty on the legalized population relative to a comparison group. After the implementation of the amnesty program, employment fell and unemployment rose for newly legalized men relative to the comparison group of already legal U.S. residents. For women, employment also fell and transitions out of the workforce increased among the newly legalized population. Increasing returns to skill, as captured by English proficiency, only played an important role in explaining the employment of newly legalized women. Finally, newly legalized men and women enjoyed higher wage growth rates than their working native counterparts, perhaps owing to their comparatively growing returns to U.S. educational attainment over this period.

Effects of the 1986 Immigration Reform and Control Act on Crime

I examine the effects that the 1986 Immigration Reform and Control Act (IRCA), which legalized almost 3 million immigrants, had on crime in the United States. I exploit the IRCA's quasi-random timing as well as geographic variation in the intensity of treatment to isolate causal impacts. I find decreases in crime of 2%-6%, primarily due to decline in property crimes, equivalent to 80,000-240,000 fewer violent and property crimes committed each year due to legalization. I calibrate a labor market model of crime, finding that much of the drop in crime can be explained by greater labor market opportunities among applicants.

GENDER DIFFERENCES IN NATIVE PREFERENCES TOWARD UNDOCUMENTED AND LEGAL IMMIGRATION: EVIDENCE FROM SAN DIEGO

I. INTRODUCTION Public views about immigration in the United States appear sharply divided--about half of respondents in a variety of U.S. surveys indicate they would prefer that the number of legal immigrants allowed to come to live in the United States decreased. (1) Likewise, the public is also divided in their views toward undocumented immigration. For instance, using data for San Diego County, we find that over 50% of natives believe that undocumented migrants should be required to go home, whereas slightly below 50% of natives believe that undocumented migrants should be granted some kind of legal status. These are all differences noted in the literature by studies that focus on native opinions regarding either legal or undocumented immigration, (2) as most surveys do not inquire natives about their preferences toward the two distinct types of immigrants. As such, lacking from the literature is an analysis for the same group of natives of the opinions they may hold with regard to legal as opposed to undocumented immigration, and of the factors driving their views. Using data for San Diego County we find that, while slightly more than half of natives in our sample oppose a generalized amnesty for undocumented immigrants, less than 30% of them want the number of legal immigrants admitted into the United States to be reduced. Therefore, it is crucial to distinguish between native opinions toward legal as opposed to undocumented immigration, avoiding any extrapolations of native views toward one group to the other group given that the factors shaping native opinions on legal and undocumented migrants are likely to differ. In this paper, we distinguish between individual attitudes toward legal as opposed to undocumented immigration into the United States by using data on: (1) native views toward legal immigration and (2) native preferences toward the passage of a generalized amnesty similar to the 1986 Immigration Reform and Control Act (IRCA). In particular, we are interested in finding out whether there are differences in how native men and women feel about legal as opposed to undocumented migrants and, if so, why. In line with the existing literature on native attitudes toward immigration, we examine the role played by a variety of economic and social factors in shaping native distinct preferences over legal and undocumented immigration. In particular, we focus on three broad explanations for differences in native male and female preferences over the two types of immigration; (1) fears of labor market competition, (2) the alleged economic burden imposed by undocumented migrants, and (3) prejudice toward immigrant groups. In sum, we ask ourselves the following questions: Are there differences in native views toward legal as opposed to undocumented immigration? Are these differences found in both native men and native women? And, if so, what explains such differences in native male and female opinions with regard to legal and undocumented immigration? A number of empirical studies have used survey data to assess the relevance of economic and social factors in explaining individual attitudes toward immigration. Some of the literature focuses on Great Britain, (3) some on the United States, (4) and, yet others, on a cross-section of countries. (5) Our study differs from the previous literature with regards to the questions being asked and the data being used. Indeed, owing to survey design, the past literature on native attitudes toward immigration has primarily centered on native preferences for legal immigration. (6) Only a few studies have focused on native attitudes toward undocumented immigration (Binder, Polinard, and Wrinkle 1997; Espenshade 1995; Espenshade and Calhoun 1993) and, to our knowledge, none has compared native preferences toward legal as opposed to undocumented immigration from the same group of male and female respondents. In this study, owing to the information on preferences over legal immigration as well as over an amnesty for undocumented immigrants collected from the same individuals, we are able to contrast and compare respondents' answers to both questions and learn about the factors driving their distinct opinions. …

The Impact of Amnesty on Labor Market Outcomes: A Panel Study Using the Legalized Population Survey

This paper tests whether amnesty, a provision of the 1986 Immigration Reform and Control Act (IRCA), affected the labor market outcomes of the legalized population. Using the Legalized Population Survey (LPS) and the National Longitudinal Survey of Youth (NLSY79) from 1987-1992, a quasi-experimental framework is developed to assess the differential impact of amnesty on the legalized population relative to a comparison group. After the implementation of the amnesty program, employment fell and unemployment rose for newly legalized men relative to the comparison group of already legal U.S. residents. For women, employment also fell and transitions out of the workforce increased among the newly legalized population. Increasing returns to skill, as captured by English proficiency, only played an important role in explaining the employment of newly legalized women. Finally, newly legalized men and women enjoyed higher wage growth rates than their working native counterparts, perhaps owing to their comparatively growing returns to U.S. educational attainment over this period.

Immigration amnesties

Barriers and border patrols complement amnesty in a coherent policy that creates incentives for illegal immigrants to self-select on the basis of ability in a way that benefits a rich host country. We consider the roles of barriers to migration and immigration amnesties in greater depth and, in particular, we examine the rich country's optimal policies. Encouraging self-selection is optimal under some, but not all, circumstances, because there are mixes of potential immigrants for which the cost of welfare migration is more than offset by the gains from productive workers enticed by a more lenient immigration policy. Furthermore, under plausible assumptions, the rich country's optimum may require a probabilistic rather than a certain amnesty to fine-tune the mix of migrants. Numerical examples illustrate that probabilistic or certain amnesties, addressed to different partitions of the migrant population, are each optimal as the mix of potential migrants changes.

Policy Shocks: On the Legal Auspices of Latin American Migration to the United States

In this paper, I compare the transition into legal permanent residence (LPR) of Mexicans, Dominicans, and Nicaraguans. Dominicans had the highest likelihood of obtaining residence, mostly sponsored by parents and spouses. Mexicans had the lowest LPR transition rates and presented sharp gender differentials in modes: women mostly legalized through husbands while men were sponsored through IRCA, parents. Nicaraguans stood in-between, presenting few gender differences in rates and modes of transition and a heavy dependence on asylum and special provisions such as IRCA and NACARA. I argue these patterns stem from the interplay of conditions favoring the emigration of and the specific immigration policy context faced by migrant pioneers; the influence of social networks in reproducing the legal character of flows; and differences in the actual use of kinship ties as sponsors. I discuss the implications of these trends on the observed gendered patterns of migration from Latin America.

Legalization and the Economic Status of Immigrants

This paper investigates the impact of legalization on the economic outcomes of the legalized population. It uses a natural experiment caused by the 1986 Immigration Reform and Control Act (IRCA) which gave amnesty for undocumented immigrants who could prove continuous residence in the U.S. after January 1, 1982. The arbitrary cutoff date on the eligibility criteria causes a discontinuity in the relationship between the year of immigration and the probability of being legal. This paper uses this discontinuity to identify the causal impacts of legalization on immigrants' outcomes. Regression discontinuity and difference-in-differences estimates show that immigrants eligible for the policy have a significantly higher probability of being naturalized citizens than those who were not. Legalization is also found to have a positive and significant effect on wages, a negative effect on the probability of working in a traditionally illegal occupation, and no significant effect on geographical mobility. The analysis for different demographic groups confirms such conclusions and shows that the estimated effects of legalization are larger for low-educated Latin American immigrants, the group that was disproportionably affected by the policy.

The why, when, and how of immigration amnesties

This paper deals with granting of an amnesty to illegal immigrants. We consider government behavior with respect to allocations on limiting infiltration (border control) and apprehending infiltrators (internal control) and with respect to the granting of amnesties, the timing of amnesties, and limitations on eligibility for those amnesties. We demonstrate the effects of government actions on allocations and the flow of immigrants, and how the interactions between these factors combine to yield an optimal amnesty policy. We also consider two extensions—intertemporal transfers of policing funds and “fuzziness” in declarations regarding eligibility for an amnesty aimed at apprehending and deporting undesirables.

Remittances to Latin America from migrants in the United States: Assessing the impact of amnesty programs

The magnitude of remittance flows to Latin America exceeds the combined inflows of foreign direct investment and official development assistance to the region. Since the United States is the destination country of the vast majority of migrants from Mexico, as well as from other Latin American countries, U.S. immigration policy can have a significant impact on the volume of remittances to the Latin American region. This paper studies how a generalized amnesty — a provision in the 1986 Immigration Reform and Control Act (IRCA) — affected immigrants' remitting patterns. In models that control for immigrants' length of residence in the United States and for economic conditions in both the U.S. state of residence and the country of origin, we estimate substantial post-legalization drops in remittances sent home by Mexican-born migrants who legalized through IRCA. Given the potential positive impact of remittances on investment levels, entrepreneurship rates and the development of the financial sector, this finding underscores the importance of gaining a better understanding of the impact that immigration policies in immigrant-receiving countries may have on the stream of remittance flows to immigrant-sending communities in developing regions.

Remittances to Latin America from Migrants in the United States: Assessing the Impact of Amnesty Programs

The magnitude of remittance flows to Latin America exceeds the combined inflows of foreign direct investment and official development assistance to the region. Since the United States is the destination country of the vast majority of migrants from Mexico, as well as from other Latin American countries, U.S. immigration policy can have a significant impact on the volume of remittances to the Latin American region. This paper studies how a generalized amnesty - a provision in the 1986 Immigration Reform and Control Act (IRCA), affected immigrants' remitting patterns. In models that control for immigrants' length of residence in the United States and for economic conditions in both the U.S. state of residence and the country of origin, we estimate substantial post-legalization drops in remittances sent home by Mexican-born migrants who legalized through IRCA. Given the potential positive impact of remittances on investment levels, entrepreneurship rates and the development of the financial sector, this finding underscores the importance of gaining a better understanding of the impact that immigration policies in immigrant-receiving countries may have on the stream of remittance flows to immigrant-sending communities in developing regions.

The new face of immigration raids

Takingthe Case to theWorld Whilecontinuing to fight on thestreets, in the courts, and in Congress, the Electrical Workers Union is also takingits case to international organisations. The unionis sendingdelegations to the International LabourOrganisation (ILO), partoftheUnited Nations, totheInter-American Commissionon Human Rights,and to the EuropeanParliament. Theunionwillarguebefore all oftheseorganisationsthatthe government has violatedthe labourrights, thehumanrights, and theindividual civil rightsof its members.While these venuesdo notprovidemandatory relief, theydo providean opportunity to bring thecase before worldpublicopinion. AnUphillBattle Still, thisremains an uphillbattle.The Mexican government reports that62 percent oftheworkers have accepted theirseverancepay - they wereoffered a bigbonustodo so -whichmeans thattheygiveup anylegal claimto their jobs. The FederalElectrical Commission, whichhas absorbedLightand Power,has said thatitwill hireatleast1,000former Light andPowerworkers ,buthas notyetannouncedexactly whatcategoriesofworkers itwillbe employing. Meanwhile, former Lightand Powerworkers saythat becausethey weremembers ofthemilitantMexicanElectrical Workers Union,theyare beingblacklisted by bothgovernment and privateemployers . The Mexican ElectricalWorkersUnion has called formoreactionsin December,a month whenmanyMexicanswillbe travelling or celebrating withtheir families, and itwillbe difficult to maintain the momentum of the movement. Still, theunionplanstotry, and manyhaveindicatedthat they areprepared tosacrifice time, tradition , andthefestivities tofight for theelectrical workers. The new face of immigration raids DAVID BACON IsaJournalist based In San Francisco "President Obama will removeincentives to enterthe country illegally bypreventing employersfrom hiring undocumentedworkers and enforcing the law" Ana for team Contreras the this national year. would She's taikwon have 14.For been do six championship a years competitor she's forthenational taikwondo championship teamthisyear.She's14.Forsixyearsshe's gonetopractice instead ofbirthday parties, giving up thefriendships mostteenagers livefor.Then two monthsago disasterstruck.Her mother Doloreslostherjob. The moneyforclasseswas gone,andnotjustthat. "Ionlybought clothes for heroncea year, when mytax refund checkcame",Dolores Contreras explains. "Nowsheneedsshoes,andI hadtotell herwe didn't haveanymoney. I stopped thecable and theinternet she needsforschool.Whenmy cellphonecontract isup nextmonth, I'llstopthat too.I've neverhad enoughmoneyfora car,and nowwe'vegonethree months without paying the light bill". Contreras shareshermisery witheighteen hundredother families. Alllosttheir jobs whentheir employer, American Apparel, fired themforlackingimmigration status. Shestill hasherletter from the Department of HomelandSecurity (DHS), handed her two monthsago by the company lawyer. Itsaysthedocuments sheprovided when she was hiredare no good, and without work authorisation, herworklifeis over. Ofcourse, it'snotreally over.Contreras still has tokeepworking ifsheandherdaughter aretoeat and payrent. So instead ofa job that barely paid herbills,she had to findanother one thatwon't evendo that. Contreras is a skilled sewingmachine operator. ShecametotheUSthirteen yearsago,after working many years in the garmentfactoriesof Tehuacan,Puebla. There companieslike Levis makeso many pairsofstonewashed jeansthat the town'swaterhas turnedblue. In Los Angeles, Contreras hopedtofind themoney tosendhome forhersister's weeklydialysis treatments, and to paytheliving andschoolexpensesforfour other siblings. Forfiveyearsshe movedfrom shopto shop.Likemostgarment workers, she didn't get paidfor overtime, herpaychecks wereoften short, and sometimes her employer disappeared overnight, owingweeksinback-pay. Finally Contreras gota jobatAmerican Apparel, famous foritssexyclothing, madeinLosAngeles insteadof overseas.She stillhad to worklikea demon.Herteamoftenexperienced seamstresses turned out30dozentee-shirts anhour. After dividingthepiece -rate evenly among them, she'dcome homewith$400fora four-day week,after taxes. ShepaidSocialSecurity too,although she'llnever see a dimein benefits becausehercontributions werecredited to a number thatdidn't belongto her. Now Contreras's working againina sweatshop at half what she earned before.Meanwhile, American Apparelis replacing thosewho were fired. Contreras saysthey're mostly olderwomen withdocuments, who can'tworkas fast. "Maybe theysew 10 dozena day",she claims."Theonly operators with papersaretheolderones.Younger, faster workers either have no papers,or ifthey have them,theyfindbetter-paying jobs doing something easier". "President Obama is responsible forputting us in thissituation", she chargesangrily. "Thisis worse thanan immigration raid.Theywantto keep us from working at all".Contreras maybe angry, but she's not wrong.The WhiteHouse website says"President Obamawillremove incentivesto enterthecountry illegally bypreventing employers fromhiringundocumented workers and enforcing the law". On June 24 he told Congressmembersthat the government was "cracking downon employers whoareusingillegal workers in orderto drivedownwages- and INTERNATIONAL union rights Page 16 Volume 16Issue 52009 oftentimes mistreat thoseworkers". Immigration raids:enforcing the 1986 Act The law Obama is enforcingis the 1986 Immigration Reformand ControlAct, which requires employers to keep recordsof workers' immigration status, andprohibits them from hiring thosewho have no legal documents, or 'work authorisation'. In effect, thelaw made ita crime forundocumented immigrants towork.Thisprovision , employer sanctions, isthelegalbasisfor all theworkplace immigration raidsandenforcement ofthelast23 years."Sanctions pretend to punish employers", saysBillOng Hing,law professor at theUniversity of California at Davis. "In reality...

Shifts in the Employment Conditions of Mexican Migrant Men and Women

Prior studies suggest that the passage of the Immigration Reform and Control Act (IRCA) in 1986 signaled deterioration in the labor market conditions faced by Mexican migrant men. In this article, the authors examine whether and how labor market conditions changed for migrant women after 1986, and the extent to which these shifts were comparable to those experienced by men. Using data about household heads and their spouses from the Mexican Migration Project, they examine sex differences in five employment conditions: hourly wages, hours worked, and the likelihoods of receiving wages in cash and paying federal and Social Security taxes. The authors find significant gender differences in the post-1986 period, especially after 1993 when most avenues to legal visas disappeared. These findings document negative policy impacts on the employment conditions of Mexican migrant men and women, and they suggest particularly precarious employment conditions for women since 1994.

Victor Zuniga and Rubén Hernandez-Leon (eds): New Destinations: Mexican Immigration in the United States

‘‘New Destinations’’ is a series of studies of Mexican immigration to the United States over the past 20 years that explores the effect of immigration on both the immigrants and the communities to which they migrated. The text is presented as an introduction and three parts of distinct case studies. The Introduction summarizes the history of immigration from Mexico to the United States, focusing on the Mexico/ US border and southwestern states where Mexicans initially settled. Part One is a series of studies regarding how and why Mexicans migrated to the new locations of Nebraska, North Carolina, and Louisiana. The authors do an excellent job of explaining the new immigrant community formation and how these new communities changed the local demography. Many of these destinations were small communities that were drastically altered by the increasing number of new migrants seeking work and a home. Traditionally, the mid-west, eastern, and southern US had not been primary immigrant settlement areas. The authors explain in each case, how economics drew immigrants to these new destinations. The authors outline the almost uniform trends as the immigrants settled in to their new communities: (1) economic need for a young working population to replace native workers in dangerous jobs such as meat packing and the poultry industry; (2) increase in Mexican businesses catering to this population; (3) varying levels of hostility to the new migrants; (4) increased economic and business activity in these destinations; and finally (5) rise of advocacy groups to support rights of the new workers. Five barriers faced by new immigrants: poor schools, language barriers, poor housing, unequal pay relative to their white co-workers and discrimination and hostility by local populations, are capably highlighted by the authors. The book makes the salient point that the Immigration Reform and Control Act (IRCA) of 1986 provided the ground work for the migration to new destinations. IRCA permitted between two and three million Mexicans to legalize their status permanently in the US. Without fear of deportation, legalized individuals were free to seek work and better economic circumstances anywhere in the US. Consequently, Mexican immigrants left the southwest and migrated to new locations in the mid-west and southern US. Finally able to settle down, they could buy homes and become part of their new communities. The new migrants were not just single young males, but the families who followed them, creating the need for schools, housing, and other necessities. The authors contrast this with the preIRCA immigrants who were mainly undocumented or in the US on an H-2B visa. These temporary work visas left the workers at the mercy of employers who could terminate them at any time. Lacking security or a permanent source of income, the pre-IRCA immigrants could not settle in the communities they worked. As a result of IRCA, this all changed in the 1980s and 1990s. Three major factors, outlined by the authors, defined where Mexicans would now be able to assimilate and grow in new destinations: (1) government policies toward immigrants; (2) societal reception by the natives in the new community; and (3) existence of co-ethnic communities already present there. Comparing two towns, the authors note Morgan City, Louisiana where assimilation of the immigrant community was more effective than Houma, Louisiana due to community support and better living conditions. J. A. Vail (&) Immigration Clinic, University of Houston Law Center, 100 Law Center Room 56 TVII, Houston, TX 77204-6060, USA e-mail: jvail@uh.edu

Workplace Rights and Illegal Immigration: How Implied Repeal Analysis Cuts through the Haze of Hoffman Plastic, Its Predecessors and Its Progeny

This piece focuses on the Supreme Court's decision in Hoffman Plastic Compounds, Inc. v. National Labor Relations Board. In Hoffman, the Court held that undocumented workers discharged in violation of the National Labor Relations Act could not recover back pay because the Immigration Reform and Control Act of 1986 (the IRCA) trumped the National Labor Relations Act (the NLRA). This holding threatened the rights of undocumented workers in other contexts, for if the IRCA could trump the NLRA, then potentially it could be cited as the basis for a broader scale-back of immigrant rights. We argue that the Supreme Court reached the wrong result in Hoffman because it did not analyze the interaction of immigration and labor law at issue in the case through an implied repeal paradigm. Moreover, we contend that application of this framework in the case, and in those cases that preceded it, would have lent clarity to this body of law and laid a solid groundwork for lower court judges, who have so far been unsuccessful in grappling with Hoffman's dubious reasoning.