From Classmates to Inmates: the Harmful Presence of School Resource Officers

By: Samantha Powers

Edited by: Micah Sandy and Chloe Shah

For many students, schools are sites of enlightenment and promise. But for some, the public education system represents something much more sinister. Lack of resources, punitive instruction models, and disciplinary alternative schools all contribute to what scholars call the “school-to-prison pipeline.” [1] This is the phenomenon in which schools become points of entry into the criminal justice system. Students who often only need additional support are criminalized and surveilled from an early age. Evidence shows that the pipeline disproportionately affects disabled students and students of color. [Ibid]. Whereas the most privileged students enjoy instruction, support and mentorship that catapults them into their college careers, many others are stuck on a track leading to a never-ending cycle of incarceration and recidivism. When compulsory education returns such vastly disparate results among students, it becomes important to look into what the root of the problem could be. The rise of police presence in schools has blurred the lines between the walls of a school and the walls of a prison.

School resource officers are sworn law enforcement officials assigned to patrol public schools and carry out disciplinary procedures. As their presence grows across campuses, Congress has proposed new federal funding through the School Resource Officer Act of 2022. Legislators cite staff resources, mentorship, and localized safety plans as benefits of SRO programs in schools, [3] though the reality is that some SROs have never been trained to deal with youth. [4] This lack of training can lead to devastating consequences.

In May 2011, a 13-year-old boy was introduced to the criminal justice system after he was ousted from his classroom for feigned burping. After his teacher’s failed attempts to stop his disruptions, she called the school resource officer (SRO) for assistance. The SRO escorted the boy out of class and arrested him for disrupting the educational process under N.M. Stat. Ann. § 30-20-13(D). The officer then took the boy to the police car, handcuffed him, and drove him to the juvenile detention center. The 10th Circuit Court ruled that the officer was qualified, able, and legally protected to make this decision. [2] As Judge Neil Gorsuch expresses in his dissenting opinion, the legal system’s backing of this decision at every level shows that the severity of discipline in schools has gone too far. If a student can be arrested, handcuffed, and jailed for burping in class, it becomes evident that schools have become sites of punishment as opposed to learning and growth.

Many believe SROs help foster a positive relationship between students and police in which officers can act as counselors and mentors in addition to disciplinarians. But given the intimate nature of the school setting, this can be a double-edged sword: in such close quarters, SROs are free to conduct a level of surveillance that is otherwise unheard of for free citizens. At school, students are constantly being supervised by teachers and administrators, and security cameras ensure that any errant behavior will be recorded and dealt with. While some of these provisions are necessary to ensure safety and order in schools, SROs must be careful not to exploit their immense power of surveillance and punishment over students. Research shows SROs only serve to “intensify the use of suspension, expulsion, police referral, and arrest of students” — particularly Black students. [5] In addition, SROs are seen as providing “peace of mind” to parents concerned about school-related crime. In reality, while SROs may be able to deter students from smoking in bathrooms and skipping class, they are often powerless to stop the most dangerous school-related crimes: school shootings. When a gunman opened fire at Marjory Stoneman Douglas High School in Parkland, Florida in 2018 — killing 14 students and 3 teachers — SRO Scot Peterson stayed outside of the building. [6] Despite his training and his mission to serve and protect the vulnerable students in the school, he failed to save 17 lives. This case, and countless others like it, demonstrate that SROs are serving the wrong purposes in schools.

To solve the growing problem of schools becoming entryways into a life of punishment and recidivism, we need to implement measures of support for students. Empathetic counselors, passionate teachers, and engaged parents will always do more to ensure the safety and success of public school students while ensuring that each child receives an equitable educational experience.

Notes:

1. “What Is the School-to-Prison Pipeline?,” American Civil Liberties Union, accessed January 29, 2024, https://www.aclu.org/documents/what-school-prison-pipeline.

2. A.M. ex rel. F.M. v. Holmes, 830 F.3d 1123 (10th Cir. 2016)

3. School Resource Officer Act of 2022, H.R. 6712, 117th Congress. (2022).

4. “What Is the School-to-Prison Pipeline?,” American Civil Liberties Union, accessed January 29, 2024, https://www.aclu.org/documents/what-school-prison-pipeline.

5. Lucy C. Sorensen, Montserrat Avila Acosta, John Engberg, and Shawn D. Bushway. (2023). The Thin Blue Line in Schools: New Evidence on School-Based Policing Across the U.S.. (EdWorkingPaper: 21-476). Retrieved from Annenberg Institute at Brown University: https://doi.org/10.26300/heqx-rc69

6. Dakin Andone, Denise Royal, and Carlos Suarez, “Then-Parkland School Resource Officer Who Stayed Outside during Mass Shooting Found Not Guilty,” CNN, June 30, 2023, https://www.cnn.com/2023/06/29/us/scot-peterson-parkland-shooting-trial-thursday/index.html.

Bibliography:

Andone, Dakin, Denise Royal, and Carlos Suarez. “Then-Parkland School Resource Officer Who Stayed Outside during Mass Shooting Found Not Guilty.” CNN, June 30, 2023. https://www.cnn.com/2023/06/29/us/scot-peterson-parkland-shooting-trial-thursday/index.html. 

Sorensen, Acosta, Engberg, and Bushway. (2023). The Thin Blue Line in Schools: New Evidence on School-Based Policing Across the U.S.. (EdWorkingPaper: 21-476). Retrieved from Annenberg Institute at Brown University: https://doi.org/10.26300/heqx-rc69

“What Is the School-to-Prison Pipeline?” American Civil Liberties Union. Accessed January 29, 2024. https://www.aclu.org/documents/what-school-prison-pipeline. 

Lost Between the Lines: Addressing the Gaps in America’s Family and Medical Leave Policies

By: Alexandra Henriquez

Edited by: madison bruno and alex brunet

For over three decades, the Family and Medical Leave Act (FMLA) has played a key role in the American labor landscape, guaranteeing American families security in times of significant life changes and challenges. The FMLA was passed in 1993 “to promote the stability and economic security of families” and balance the needs of families’ needs with employers’ needs. [1] The FMLA guarantees any “eligible employee” 12 workweeks of unpaid leave for every 12 months in response to the following events: birth of a child, placement of an adopted child, serious familial or personal health conditions, or any qualifying exigency arising from their family members’s active duty in the Armed Forces. FMLA has a leave limit of 26 work weeks per 12 months. [2] While the act has made significant progress in the fight for labor rights, Americans have noticed its significant constraints over the past few years. 

First, the FMLA does not recognize part-time or temporary employees, employees of small businesses, or self-contracted individuals. The FMLA defines an “eligible employee” as “an employee who has been employed for at least 12 months by the employer and at least 1,250 hours of service with such employer during the previous 12-month period.” [3] The act also excludes any employee at a company with less than 50 employees within 75 miles of the worksite. These eligibility requirements particularly affect those in the newly popularized gig economy, including short-term employment like freelancers, self-contractors, ride-share drivers, delivery personnel, online platform workers, and temporary or part-time workers. As a result, a growing segment of the workforce finds itself without the protections offered by FMLA.

Additionally, although the FMLA ensures job security for employees, a major challenge for many Americans is the loss of income during this period. The FMLA mandates unpaid leave, meaning individuals do not receive their regular income during this period. For many American workers, especially those in lower income brackets or those dealing with costly health procedures, the loss of income during family or medical leave can be a significant financial burden. This gap in the FMLA means that, despite having the right to take leave, some employees may not be able to afford to do so, negating the intended benefits of the act.

Moving into 2024, many states have realized the importance and social benefits of supporting workers and their families’ physical and mental health regardless of employment type, implementing mandated paid family leave that extends to all. According to the Center for American Progress, 11 states enforce family and medical leave laws: California, Colorado, Connecticut, Delaware, Massachusetts, Maryland, New Jersey, New York, Oregon, Rhode Island, and Washington State, along with Washington, D.C. [4] These state laws protect private sector employees, and many cover state and local government employees as well. State-paid family and medical leave laws, for the most part, cover all workers, even those who are self-employed; participants can pay into a fund to make them eligible for paid leave benefits.

In early December of 2023, the Wisconsin Supreme Court held oral arguments to determine whether employers such as Amazon, which are instrumental in the gig economy, should be required to contribute to a fund for unemployed workers. [5] Central to this case is the question of whether gig economy participants qualify as employees. The outcome of this case could set a precedent regarding the contributions of major companies to paid leave funds for gig economy workers.

The federal government is also slowly progressing towards aligning with evolving state policies providing paid leave. In 2021, the House of Representatives passed the Build Back Better Act (H.R. 5376), part of which aimed to establish a permanent national paid leave program. However, the bill died in the Senate and was replaced with the Inflation Reduction Act, which was passed in August of 2022 without any provision for a paid leave program. [6] While the Build Better Act’s passage through the House acknowledges the growing need for a larger-scale approach to family and medical leave, the halted journey of the bill and its paid leave provision underscores the complexities and challenges in enacting such legislation at a federal level. These complexities encompass arguments surrounding the financial burden on small businesses and economic growth, requirements of substantial government funding, and the role of the federal government. The absence of a federal paid leave program in the Inflation Reduction Act leaves the responsibility of implementing paid leave policies largely to individual states, which has led to a patchwork of policies across the country, with some states offering comprehensive paid leave programs while others offer none. Despite this setback, the conversation around federal paid leave has gained considerable attention and support from Americans, state governments, and neighboring countries. 

Extending paid leave and including gig workers is to acknowledge the value of providing a social safety net and to acknowledge that our labor landscape is changing. The discussion on paid leave extends to the broader question of how we should adapt labor laws to the changing nature of work in the 21st century. As the workforce continues to evolve, with an increasing number of gig economy workers and changing family dynamics, the demand for a national paid leave policy will definitively remain a significant topic in labor policy discussions.

Notes:

1. Family and Medical Leave Act of 1993, 29 U.S.C. § 2601, (1993).

2. Family and Medical Leave Act of 1993, 29 U.S.C. §  2611, (1993).

3. Family and Medical Leave Act of 1993, 29 U.S.C. §  2611, (1993).

4. Molly W. Williamson,  “The State of Paid Family and Medical Leave in the U.S. in 2023,” Center for American Progress, 5 Jan. 2023, https://www.americanprogress.org/article/the-state-of-paid-family-and-medical-leave-in-the-u-s-in-2023/.   

5. Shawn Johnson, “Wisconsin Supreme Court Hears Arguments in Case Involving ‘gig Workers,’ State Unemployment Fund,” Wisconsin Public Radio, 19 Dec. 2023, www.wpr.org/economy/wisconsin-supreme-court-hears-arguments-gig-workers-state-unemployment-fund.

6. H.R. 5376 (117th): Inflation Reduction Act of 2022. GovTrack, 19 Aug. 2022, https://www.govtrack.us/congress/bills/117/hr5376/summary. 

Bibliography:

Family and Medical Leave Act of 1993, 29 U.S.C. § 2601, (1993).

Family and Medical Leave Act of 1993, 29 U.S.C. §  2611, (1993).

Family and Medical Leave Act of 1993, 29 U.S.C. §  2611, (1993).

H.R. 5376 (117th): Inflation Reduction Act of 2022, GovTrack, 19 Aug. 2022, https://www.govtrack.us/congress/bills/117/hr5376/summary. 

Johnson, Shawn. “Wisconsin Supreme Court Hears Arguments in Case Involving 'gig Workers,' State Unemployment Fund.” Wisconsin Public Radio, 19 Dec. 2023, www.wpr.org/economy/wisconsin-supreme-court-hears-arguments-gig-workers-state-unemployment-fund

Williamson, Molly W.  “The State of Paid Family and Medical Leave in the U.S. in 2023,” Center for American Progress, 5 January 2023,https://www.americanprogress.org/article/the-state-of-paid-family-and-medical-leave-in-the-u-s-in-2023/.   

Supreme Court Hears Trump’s Plea on Colorado Ballot

By: Jaenney Lee

Edited by: Grace Wu and Ananya Chag

The Supreme Court of the United States (SCOTUS) has agreed to review the decision of the Colorado Supreme Court to remove Donald Trump from Colorado’s primary election, due to his role in encouraging an attack on the U.S. Capitol on Jan. 6, 2021, after losing the 2020 general election. Legal scholars and state election officials are urging for a fast process of states following the same policy before the 2024 primary voting.  Colorado and Maine have therefore temporarily paused their decisions to bar Trump as a candidate as they need to make a legal decision. This means that former President Trump will be written on the primary ballots until there are clear legal decisions from the Supreme Court. The ballots will be mailed to the majority of voters in Colorado starting Feb. 12 — four days after the justices hear arguments. This trial is particularly important as Colorado is considered a “swing” state. [1]

Lawyers for the former President must submit written arguments by Thursday, Jan. 18,  must reply by Monday, Feb. 5, and the State of Colorado must reply by Wednesday, March 31. Oral arguments will take place on Thursday, Feb. 8 at the Supreme Court in Washington, D.C.[2]

According to the recent brief written on Jan. 26 by the lawyers of the Colorado voters, Colorado voters are actively arguing that former President Trump should be barred from holding federal office as he has a history of engaging in violent acts in the Capitol. The lawyers of these voters argue that Trump “intentionally organized and incited a violent mob to attack the United States Capitol in a desperate attempt to prevent the counting of electoral votes cast against him.” Furthermore, the lawyers stated that “by spearheading this attack, Trump engaged in insurrection against the Constitution."[3]

The brief questions whether Section 3 of the 14th Amendment, which bars those who have “engaged in insurrection,” applies to President Trump and if that impacts his position as a candidate. The case overall raises legal questions: such as whether the constitutional language applies to those running for the presidential election and how and who would decide whether someone engaged in the “insurrection.”[4]

On the other hand, in Trump’s own brief on Jan. 18, his lawyers outlined the reasons as to why they believe the Colorado court ruling was wrong. They cite language in the constitutional provision arguing that the law is only applicable to individuals who hold an officer position in the United States. Particularly, they argue that Section 3 applies only to a person who would “hold” office, not “run” the office. They follow up by stating that being the president is not part of being an officer of the United States. Trump’s lawyers wrote, “The court should put a swift and decisive end to these ballot-disqualification efforts, which threaten to disenfranchise tens of millions of Americans.” [5]

Lastly, whether Trump can assert immunity from criminal prosecution for election subversion connected to the 2020 presidential election is one of the other debated issues that will likely come up soon.

Long before Trump’s trial was set for March, special counsel Jack Smith attempted to convince the Supreme Court to hear arguments regarding the immunity claim. The December request was rejected by the Supreme Court justices, and, as a result, on Jan. 9, the U.S. appellate court heard arguments over Trump’s eligibility for immunity for alleged crimes committed while in office.[5]

The decision is coming around soon, and, when the time comes, the Supreme Court’s final resolution will aim to represent justice.

Notes:

1. Marimow, Ann E, and Patrick Marley. 2024. “Supreme Court Says It Will Decide If Trump Qualifies for Colorado Ballot.”

2. Anderson. 2024. “Trump v. Anderson - SCOTUSblog.” 2024

3.  In the Supreme Court of the United States.“BRIEF ON THE MERITS FOR ANDERSON RESPONDENTS,” January 26 2024.

4. Hurley, Lawrence. 2024. “Colorado Voters Insist to Supreme Court That Trump Should Be Ineligible in 2024.” January 26th. 

5. In the Supreme Court of the United States “BRIEF FOR THE PETITION,” January 18, 2024.

6. Joan Biskupic. 2024. “The Conservative Legal World Lines up Behind Donald Trump at the Supreme Court.”

Bibliography:

Anderson. 2024. “Trump v. Anderson - SCOTUSblog.” SCOTUSblog. 2024.

Hurley, Lawrence. 2024. “Colorado Voters Insist to Supreme Court That Trump Should Be Ineligible in 2024.” NBC News. NBC News. January 26, 2024.

In the Supreme Court of the United States DONALD J. TRUMP, Petitioner, v. NORMA ANDERSON, ET AL., Respondents, “BRIEF ON THE MERITS FOR ANDERSON RESPONDENTS,” January 26 2024.

In the Supreme Court of the United States DONALD J. TRUMP, PETITIONER v. NORMA ANDERSON, ET AL., RESPONDENTS “BRIEF FOR THE PETITION,” January 18, 2024.

Joan Biskupic. 2024. “The Conservative Legal World Lines up behind Donald Trump at the Supreme Court.” CNN. CNN. January 26, 2024.

Marimow, Ann E, and Patrick Marley. 2024. “Supreme Court Says It Will Decide If Trump Qualifies for Colorado Ballot.” Washington Post. The Washington Post. January 5, 2024.

Immigrant Rights and the Resurgence of Noncitizen Voting in the United States

By: Morgan Dreher

Edited by: Samantha yip and Claire Quan

What are the requirements to vote in the United States? Citizenship is likely one of the first qualifications you consider, but for the majority of U.S. history, this has not been the case. Noncitizen voting was permitted in 40 states up until the early twentieth century, even in federal elections in some cases. [1] This served many purposes, such as encouraging immigrants to move to the South for labor or incentivizing them to join the military. [2] However, an influx of Southern and Eastern European immigrants between 1880 and 1910 increased anti-immigration sentiment and the overturning of policies permitting noncitizen voting. [3] The exclusion of noncitizens from the voting process was formalized with the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA), which criminalized noncitizens’ voting in federal elections. [4] However, since 2018, a resurgence of noncitizen voting has emerged in certain municipalities within California, Vermont, Maryland, and the District of Columbia. [5] This divergence from the country’s recent norm has resulted in much political and legal discourse and raises broader philosophical questions amidst a period of immigration crises and impending elections. 

So what exactly does noncitizen voting constitute? In its current form, it refers to municipalities in the United States that allow people without citizenship to vote in school boards and/or local elections. [6] Noncitizen voting in federal elections remains illegal due to IIRIRA, but decisions regarding local elections are reserved for the states. With the possibility of noncitizens voting back in the picture, the subject is contentious as we reconsider immigrant rights.

Rather than being divided along partisan lines, the issue of noncitizen voting elicits widespread public concern and intrigue of its radical nature. [7] Nonetheless, proponents and opponents of noncitizen voting each possess complex arguments regarding its legality and political implications. For example, many arguments regarding noncitizen voting are rooted in different interpretations of state constitutions, which can be the basis for creating and overturning noncitizen voting policies. Essentially, many constitutions declare citizens can vote but do not explicitly specify that only citizens can vote. This was the case for New York City, where a law was passed affirming noncitizens’ rights to vote for mayor and City Council. New York City would have been the largest US city to incorporate noncitizen voting, but Justice Ralph J. Porzio ruled that this law contradicted the state constitution, interpreting citizenship to be a requirement for all voters. [8] Because similar arguments can be made in many states and government officials recognize their convoluted nature, legislators in states such as Alabama, Colorado, and Florida are making efforts to amend their state constitutions so that a citizenship requirement for voting is more explicitly stated. [9] 

Another legal argument is the applicability of the Equal Protection Clause of the Fourteenth Amendment to immigrant rights. In 1982, the Supreme Court ruled in Plyler v. Doe that illegal immigrant classifications should be held to a rational-basis standard of review, rather than the strict scrutiny standard applied to legal immigrants. [10] While some argue everyone within US jurisdiction deserves the protection of the Constitution, the majority opinion in Plyler v. Doe believed those entering the US without permission should be prepared to deal with the consequences of their actions. Plyler v. Doe allotted more power to the states to determine the rights of undocumented immigrants and has since been used as the basis for other court cases that have decreased the rights of the undocumented population. [11]

While interpretation of the law grounds many debates, other arguments are heavily based on ideological standpoints. To understand these perspectives, it is beneficial to start with supporters of noncitizen voting rights, who used their arguments to bring back policies that have been obsolete since the early twentieth century. First, one of the most popularized justifications refers to the American principle of “no taxation without representation.” This argument highlights a logical disconnect between the 25 million people living in the US who are paying taxes and contributing to society but lack representation in elections. [12] Along these same lines is the idea that permitting noncitizens to vote allows for a more holistic representation of the population in city elections, which is increasingly relevant for cities with growing immigrant populations. [13] 

Furthermore, Ron Hayduk of San Francisco State University states another argument on historical precedent, referencing how “the idea that noncitizens should have the vote is older and has been practiced longer than the idea that they should not.” [14] Additionally, proponents reason that voting increases the stakes and sense of belonging for noncitizen voters, meaning they will be more interested in seeking citizenship. [15]

Another set of supporting arguments exists in the realm of social justice, given that the disenfranchisement of noncitizens is a loss of rights. Some argue that not only is preventing noncitizens from voting discriminatory, but it also opens the door for other discriminatory public policies in the future as noncitizen voices go unheard. [16]  Hayduk also makes this claim based on the idea that politicians will not fear retribution from noncitizens via the polls, enabling them to enact discriminatory policies. [17] Lastly, another equity concern is that the process of naturalization is lengthy and difficult, meaning it is an unjust requirement for representation in elections. [18] In summary, proponents of noncitizen voting, as stated by scholar Cristina M. Rodríguez, believe that “the core substantive principle of democracy is that those subject to the law should have a voice in its formulation.” [19]

On the other side, opponents to noncitizen voting are aptly ready to dispute supporting arguments. The New York Post writes that acquiring citizenship “is a vital acceptance of duties as well as privileges,” meaning that to receive the benefits of citizenship, one must also take on the accompanying responsibilities. [20] It quickly becomes evident that this concept of citizenship is an important value for opponents and grounds most of their arguments. One of the most prevalent beliefs on this side is that noncitizen voting will take away the incentive for people to seek citizenship, in turn resulting in less national unity and “diminish[ing] the voting power of citizens.” [21] Overall, opponents see citizenship as a core American value, which incurs much of its meaning from voting privileges. Rodríguez acknowledges this accordingly, discussing how while there are many mechanisms for the integration and incorporation of immigrants, voting is central to defining citizenship. [22] 

Other, less common perspectives include the idea that noncitizen voting could lead to confusion, where noncitizens surpass voting barriers and accidentally vote in federal elections. [23] Furthermore, some opponents feel that once noncitizens receiving social welfare benefits are enfranchised, they will have the main advantage of citizenship and no desire to leave welfare behind. [24] In general, contrary to supporting arguments that promote the universal benefits of noncitizen voting, critics see these same policies as a threat to integral American ideals. Connecticut Representative Vincent Candelora even went as far as to say that “opening up elections to non-citizens completely erodes our sovereignty in this country and in our state.” [25] 

Given that the restoration of noncitizen voting policies is a recent phenomenon, it is possible that public opinion will shift after analysis is released regarding upcoming elections. Only time will tell the real impact that noncitizen voting has on its permitted localities, but its impact could be significant enough to change the course of elections. [26] For example, a study of the 2008 election revealed that noncitizen voting likely affected the electoral college results, contributing to Obama’s North Carolina victory. [27] While this is an example of a federal election and noncitizens who surpassed existing voting barriers, it showcases the potential power noncitizens have to alter election results. 

Ultimately, the topic of noncitizen voting is controversial and evolving as new policies are passed and state constitution amendments are approved. Legal changes, along with upcoming elections and US demographic shifts, will likely bring further public attention to the topic of noncitizen voting. While the issue itself is relevant and debatable, it also evokes fundamental questions about the United States. What does it mean to be a citizen? To what extent do immigrants have rights in the US? Do newer or older principles take precedence in political debates? As what once was considered a country of immigrants, we must now face these questions about where we stand on the rights of all immigrants, not just those who are US citizens.

Notes:

1. Matt Vasilogambros, “Noncitizens Are Slowly Gaining Voting Rights,”  Stateline.org, 2021. https://stateline.org/2021/07/01/noncitizens-are-slowly-gaining-voting-rights/.

2. Ron Hayduk, “Chapter 2,” In Democracy for all : restoring immigrant voting rights in the United States, 15-40, N.p.: Routledge, 2006. https://www.nypl.org/sites/default/files/hayduk_-_chapter_2.pdf.

3. Hayduk, “Chapter 2,” In Democracy for all : restoring immigrant voting rights in the United States.

4. “*Public Law 104–208 104th Congress An Act,” GovInfo, 1996. https://www.govinfo.gov/content/pkg/PLAW-104publ208/pdf/PLAW-104publ208.pdf.

5. “Arguments for and against laws permitting noncitizens to vote in the United States,” n.d. Ballotpedia, Accessed January 26, 2024. https://ballotpedia.org/Arguments_for_and_against_laws_permitting_noncitizens_to_vote_in_the_United_States.

6. Alison Cross, “Republicans Voice Outrage Over Non-Citizen Voting Bill,” Governing, 2023. https://www.governing.com/now/republicans-voice-outrage-over-non-citizen-voting-bill.

7. Nicholas Goldberg, “Is It Time to Let Noncitizens Vote in Local Elections? Some Americans Think that’s Just Nutty,” Governing, 2023. https://www.governing.com/politics/is-it-time-to-let-noncitizens-vote-in-local-elections-some-americans-think-thats-just-nutty.

8. Jeffery C. Mays, “New York City's Noncitizen Voting Law Is Struck Down,” The New York Times, 2022. https://www.nytimes.com/2022/06/27/nyregion/noncitizen-voting-ruling-nyc.html.

9. Vasilogambros, “Noncitizens Are Slowly Gaining Voting Rights.”

10. Jason H. Lee, “Unlawful Status as a Constitutional Irrelevancy: The Equal Protection Rights of Illegal Immigrants,” Golden Gate University Law Review 39, no. 1 (Fall): 1-40, 2008. https://heinonline.org/HOL/P?h=hein.journals/ggulr39&i=3.

11. Lee, “Unlawful Status as a Constitutional Irrelevancy: The Equal Protection Rights of Illegal Immigrants.”

12. Goldberg, “Is It Time to Let Noncitizens Vote in Local Elections? Some Americans Think that’s Just Nutty.”

13. Hayduk, “Chapter 2,” In Democracy for all : restoring immigrant voting rights in the United States.

14. Hayduk, “Chapter 2,” In Democracy for all : restoring immigrant voting rights in the United States.

15. “Arguments for and against laws permitting noncitizens to vote in the United States.”

16. “Arguments for and against laws permitting noncitizens to vote in the United States.”

17. “Arguments for and against laws permitting noncitizens to vote in the United States.”

18. Goldberg, “Is It Time to Let Noncitizens Vote in Local Elections? Some Americans Think that’s Just Nutty.”

19. Cristina M. Rodríguez, “Noncitizen voting and the extraconstitutional construction of the polity,” International Journal of Constitutional Law 8, no. 1 (January): 30-49, 2010. https://doi.org/10.1093/icon/mop032.

20. “Arguments for and against laws permitting noncitizens to vote in the United States.”

21. Mays, “New York City's Noncitizen Voting Law Is Struck Down.”

22. Rodríguez, “Noncitizen voting and the extraconstitutional construction of the polity.”

23. Vasilogambros, “Noncitizens Are Slowly Gaining Voting Rights.”

24. Arguments for and against laws permitting noncitizens to vote in the United States.”

25. Cross, “Republicans Voice Outrage Over Non-Citizen Voting Bill.” 

26. Jesse T. Richman, Guishan A. Chattha, and David C. Earnest, “Do Non-Citizens Vote in U.S. Elections?” ODU Digital Commons, 2014. https://digitalcommons.odu.edu/cgi/viewcontent.cgi?article=1011&context=politicalscience_geography_pubs.

27. Richman, Chattha, and Earnest, “Do Non-Citizens Vote in U.S. Elections?

Bibliography:

“Arguments for and against laws permitting noncitizens to vote in the United States.” n.d. Ballotpedia. Accessed January 26, 2024. https://ballotpedia.org/Arguments_for_and_against_laws_permitting_noncitizens_to_vote_in_the_United_States.

Cross, Alison. 2023. “Republicans Voice Outrage Over Non-Citizen Voting Bill.” Governing. https://www.governing.com/now/republicans-voice-outrage-over-non-citizen-voting-bill.

Goldberg, Nicholas. 2023. “Is It Time to Let Noncitizens Vote in Local Elections? Some Americans Think that’s Just Nutty.” Governing. https://www.governing.com/politics/is-it-time-to-let-noncitizens-vote-in-local-elections-some-americans-think-thats-just-nutty.

Hayduk, Ron. 2006. “Chapter 2.” In Democracy for all : restoring immigrant voting rights in the United States, 15-40. N.p.: Routledge. https://www.nypl.org/sites/default/files/hayduk_-_chapter_2.pdf.

“Laws permitting noncitizens to vote in the United States.” n.d. Ballotpedia. Accessed January 26, 2024. https://ballotpedia.org/Laws_permitting_noncitizens_to_vote_in_the_United_States.

Lee, Jason H. 2008. “Unlawful Status as a Constitutional Irrelevancy: The Equal Protection Rights of Illegal Immigrants.” Golden Gate University Law Review 39, no. 1 (Fall): 1-40. https://heinonline.org/HOL/P?h=hein.journals/ggulr39&i=3.

Mays, Jeffery C. 2022. “New York City's Noncitizen Voting Law Is Struck Down.” The New York Times. https://www.nytimes.com/2022/06/27/nyregion/noncitizen-voting-ruling-nyc.html.

“*Public Law 104–208 104th Congress An Act.” 1996. GovInfo. https://www.govinfo.gov/content/pkg/PLAW-104publ208/pdf/PLAW-104publ208.pdf.

Richman, Jesse T., Guishan A. Chattha, and David C. Earnest. 2014. “Do Non-Citizens Vote in U.S. Elections?” ODU Digital Commons. https://digitalcommons.odu.edu/cgi/viewcontent.cgi?article=1011&context=politicalscience_geography_pubs.

Rodríguez, Cristina M. 2010. “Noncitizen voting and the extraconstitutional construction of the polity.” International Journal of Constitutional Law 8, no. 1 (January): 30-49. https://doi.org/10.1093/icon/mop032.

Vasilogambros, Matt. 2021. “Noncitizens Are Slowly Gaining Voting Rights.” Stateline.org. https://stateline.org/2021/07/01/noncitizens-are-slowly-gaining-voting-rights/.