USC Data - LA TIMES ERRORS

Deportation Research Clinic
Buffett Institute for Global Studies
Northwestern University
Deportation Research Clinic Source Materials
Founding Director, Professor Jacqueline Stevens

UNITED STATES CITIZENS IN DEPORTATION PROCEEDINGS
Problems with Los Angeles Times Reporting and Ethics

On April 27, 2018, the Los Angeles Times published an article on U.S. citizens facing deportation as so-called aliens, a situation that occurs thousands of times each year, and, paradoxically, is legally impossible. Co-authors Paige St. John and Joel Rubin misstated and vastly oversold the government data they presented, failed to link to original sources, "uncovered" immigration courts terminating deportation orders for U.S. citizenship cases despite this fact being released months earlier by another journalist, and relied on other research and analysis without attribution.

One problem in the recent rush to report on U.S. citizens detained or deported -- a topic I have been reporting on since 2008 -- is that non-specialists assume that citizenship is a discernible fact and that the U.S. government has accurate data on cases when questions arise in the context of deportation proceedings. Based on these incorrect assumptions, and a lack of information and expertise, the authors wrote an apparently authoritative article that contains several fundamental errors.

The article is a case study in how "data-driven" journalism can turn into junk science and how fancy graphics become junk illustrations.

The authors' characterization of U.S. Citizenship and Immigration Service (USCIS) errors in their databases -- "garbage in, garbage out" -- not only was copied from a screenshot I selected and pointed out to them from a document I obtained from a FOIA release, but it describes portions of their own work as well.

GRAPHIC ON ICE REVIEWS OF U.S. CITIZENSHIP CLAIMS

LA Times Americans in ICE Custody

Table Mislabeled

First, an unknown number of the 8,043 people whom the Times says had cases ICE reviewed for claims of U.S. citizenship were not in ICE custody.

Second, for an unknown number of cases ICE assessed as having evidence or indications of U.S. citizenship ICE went ahead and sought final orders of removal in immigration courts, and in an unknown number of these cases succeeded, meaning that these respondents were not U.S. Americans, at least according to the U.S. government whose statistics St. John and Rubin leave unexplained and unquestioned.

Third, the cases of those who are arrested seldom are reviewed within 48 hours of ICE learning of a claim of U.S. citizenship.

Correspondence from ICE to a journalist from Slate.com reveals the misnomers in the label text and analysis. The ICE official writes: "Some of these 1000-claims were likely raised on the nondetained docket. So their custody status would not have changed. Also, in some cases we may terminate proceedings, but in others we may let the case proceed before the IJ [Immigration Judge] because the claim isn't fully established, though it is probative."

Either no similar correspondence was shared with the Los Angeles Times reporters, or it was and they decided to ignore it.

datameaning

US citizenship case reviewed, Non-detained

The L.A. Times claims those in the column on the right are "Americans in custody," but this is false.

Policy not followed. The chart's label text states the "agency requires a legal review within 48 hours." This implies that the reviews for the cases in the chart are conducted within 48 hours. Why else reference a policy if it's not followed? However, ICE internal email shows that this is the exception, not the norm.

Quoting official policy to characterize the actual time-frame of these reviews is like paraphrasing jay-walking laws to describe how people cross streets in Manhattan. Indeed the policy referenced is not a law or regulation, but an informal protocol for avoiding criminal and civil liability and thus provides less reason than jay-walking laws for inferring adherence to it.

St. John and Rubin note in their article that ICE only released a statement and did not agree to an interview. The reporters received summary data on the number of cases reviewed and their outcomes, but apparently were unable to elicit specific operational information about ICE reviews of U.S. citizenship claims. The authors never actually claim the reviews occur within 48 hours. Bereft of factual knowledge about the details of these cases, their disposition, and how they are reviewed, the authors posted a policy and left readers to make false inferences.

It's not just the label text that has these problems.

The authors write:

"Since 2012, ICE has released from its custody more than 1,480 people after investigating their citizenship claims, according to agency figures. And a Times review of Department of Justice records and interviews with immigration attorneys uncovered hundreds of additional cases in the country’s immigration courts in which people were forced to prove they are Americans and sometimes spent months or even years in detention."

Internal correspondence shows that even among the cases ICE investigates and finds evidence of U.S. citizenship, that is, the cases in the right column, people are spending months and even years in detention prior to the reviews.

Often these reviews are prompted not by claims of U.S. citizenship but media inquiries or losing in immigration court and deciding about an appeal.

That's right, there's been hundreds of stories about the detention and deportation of U.S. citizens before the one authored by St. John and Rubin; this media coverage is part of the story. In their zeal to appear original they necessarily obscured an important part of the narrative: the numerous stories that have poked ICE into initiating these more systematic reviews during the Bush and Obama administrations, especially following the publication of a law review article documenting these and posts on these cases between 2008 and 2016 at http://stateswithoutnations.blogspot.com, as well as the coverage of this by William Finnegan, "The Deportation Machine," in The New Yorker.

(I know these publications had an impact because ICE officials addressing the problem of ICE detaining and deporting U.S. citizens are discussing them in email and memoranda released to me under the Freedom of Information Act. Government and non-profit studies going back decades show the U.S. government was well aware it was detaining and deporting U.S. citizens. Only after extensive reporting and a Congressional hearing organized by Rep. Zoe Lofgren in 2008 did Immigration and Customs Enforcement pursue policy reforms, lame as these turned out to be.)

Double-counting: Many of the cases in the right bar of the graphic also are among the so-called "additional cases in the country's immigration courts" the authors reference, meaning they are the same cases reviewed first by ICE and then by immigration judges, and are not "additional."

Here are two typical examples.

Claim Investigated Weeks, not Hours, after U.S. Citizenship Asserted

Attorneys from the Immigraton Law Practice Division (ILPD) are the ones charged with reviewing US citizenship claims. Note that this review occurred one day after the reporter inquiry, but 3 weeks and two days longer than the policy allows, even though the respondent had an attorney who was making these claims.

This tracks what happened with Mark Lyttle in 2009, who was released from ICE custody in Atlanta only after I posted about his arrest on my blog and contacted ICE public affairs. Mark's pro bono attorney Neil Rambana followed the rules, as did the attorney for the woman hed in Irwin County, but it was only after media attention that ICE released Mark.

Claims Investigated Only after Media Inquiry

On March 7, 2017, after one month in detention, ILPD indicates the woman will be released from custody. Here is an article describing what happened in what appears to be this case, though the author is not the reporter in the correspondence below.

Woman Released over One Month after Arrest

Authors Overstate the US cases reviewed as a fraction of deportation cases

The authors write:

"The wrongful arrests account for a small fraction of the more than 100,000 arrests ICE makes each year."

A reader eyeballing this would assume that the U.S. Americans ensnared are among the 114,000 to 143,000 ICE arrested each year in this time frame, though 143,000 is quite a bit above 100,000.

However, the cases include those referred as well from Border Patrol or even US Citizenship and Immigration Services. Thus, the denominator should include these case loads and would be far higher.

A better benchmark is probably new deportation cases filed, about 211,000 to 257,000 annually between 2012 to 2017. Arguably the number should also include all the applications for Certificates of Citizenship and also Expedited Removals, since the ILPD is reviewing these U.S. citizenship claims as well, bringing the number closer to 300,000 to 700,000 cases each year for the denominator. The low numbers only reflect the cases ICE or immigration courts flag and count, have no discernible relationship with the actual number of U.S. citizen claims.

The email correspondence and reports I've reviewed are from about 2,000 pages produced in response to two requests under the Freedom of Information Act, one of which is in litigation. (Many of these are duplicates and hundreds of pages are fully redacted.) I have not counted all of the cases in the e-mail released because it is not complete. That said, I have paid some attention to the time frames of the case filings and correspondence. With the caveat that this is an estimate with zero statistical significance, my best guess is that about 90% of cases reviewed for claims of U.S. citizenship are for those who are in the physical custody of ICE, and that fewer than 25% had reviews within 48 hours of an arrest.

Caveat: Once I receive all the cases and redactions are removed there is an unknown likelihood this estimate will change to an unknown figure. The estimates are worth mentioning only to the extent that I can report I have seen enough cases to know the representation of this data by St. John and Rubin are wrong.

In sum, the cases on the left include an unknown number of people who are not in custody, perhaps 10% (perhaps not), and among the 1,480 cases on the right an unknown number of people are not U.S. Americans.

Presumably the Los Angeles Times would not publish a chart under a caption that says, "ICE made some mistakes and detained and deported some U.S. citizens among those listed here. The government has no clue about the exact numbers and we don't, either." However, these are the only truthful claims one can make about the data. Knowing this, other journalists did not publish these data with these claims; the Los Angeles Times made a different decision.

Also, the authors' own analysis is at odds with the data. The chart reveals an increase between 2015 and 2016, and then a sharp decline between 2016 and 2017, in the number of cases ICE is reviewing for claims of U.S. citizenship.

Weirdly, the chart is not interactive, so readers lack exact figures for most of the years. The data I have from internal reports for years the Times does not specify are: 2012 1,314 reviewed, 275 probative evidence; 2013 1325 reviewed, 282 probative evidence; 2014 991 reviwed, 191 probative evidence; 2015 876 reviewed, 168 with probative evidence; 2016 1101 reviews, 169 with probative evidence. Trump took office in January, 2017. This means that during his first year, the number of U.S. citizenship claims reviewed actually dropped about one-fifth.

The authors write:

"...it’s unclear whether the Trump administration’s aggressive push to increase deportations will lead to more mistakes. "

Breaking news: Maybe more mistakes... But what about the decrease under Trump?

It turns out ICE's attorneys also were perplexed by this. There seem to be two possible explanations. First, claims are being received but there is a back-up in their reviews and recommendations. An internal report from ILPD notes for the first quarter of 2017 a decrease in the number of claims reviewed and an increase in the total minutes it took to review each claim, from 30 to 51 minutes. It could be cases remain in the database unresolved.

A more likely possiblity is that the band-width overload is interfering with cases entering the system in the first place. In the spring, 2017, one ILPD attorney writes: "Candidly, given the attitudinal shift I've seen in some of our OCC's [Office of Chief Counsel] in recent months, I wonder if we may be missing some of these that could come back to bite us down the road. It may also be a question of increased workload at the local level given the change of enforcement priorities and various high-profile operations such that collateral duties like USC claim memos are falling by the wayside."

A colleague replies, "Agreed--I can [sic] USC memos being pushed to the wayside in light of the other high profile issues the OCCs are currently being tasked with."

The guesswork of journalists -- 'maybe these mistakes will increase if ICE handles more cases' -- is banal conjecture, but the perplexity and hunches of ICE attorneys themselves confronting a falling trendline of reports is news.

IMMIGRATION COURT TERMINATIONS AND CLOSINGS

LA TIMES GRAPHIC

immigration court adjournments

Turning to their reporting on the immigration court cases adjudicating U.S. citizenship claims, the most obvious point is that the reporters were remiss in their failure to properly credit the breaking of this story.

Investigative journalist Lise Olsen in July, 2017 published an article in the Houston Chronicle titled, "Hundreds of American Citizens End up in Deportation Proceedings Each Year, Immigration Data Show."

Blithely ignoring the fact they were beat, eight months later St. John and Rubin write:

"And a Times review of Department of Justice records and interviews with immigration attorneys uncovered hundreds of additional cases in the country’s immigration courts in which people were forced to prove they are Americans and sometimes spent months or even years in detention."

Stay tuned for when St. John and Rubin review the Hebrew Bible and uncover hundreds of cases of God killing the first-born sons of Egyptians.

The absence of links to the underlying data they used compounds the problem in how they characterize the results of their analyses. (Paige St. John stated in an email that they from the raw data the government released to TRAC; typically these agreements prevent subscribers from releasing the original data, though St. John did not indicate this as the reason for their failure to make their data public.)

Here are a few of the problems. First, the source of the data and of the graphic below is not the Department of Homeland Security. Rather it is the Executive Office of Immigration Review, a component of the Department of Justice. Ditto for the one on the location hearings. This appears to be an editing problem -- elsewhere the authors state the data are from the Department of Justice -- no idea whether the authors failed to request a correction or if the editors refused.

LA TIMES GRAPHIC

Immigration Courts

Here are some further problems with the representation of the data.

The authors write:

"From 2008 to the start of 2018, judges terminated or suspended removal proceedings against 880 people whose citizenship claims warranted investigation."

First, the cases they are describing are in immigration courts and the adjudicators are "immigration judges," distinct from federal court judges, who also may review these claims. (This is a bit in the weeds, but the article elsewhere describes hearings in courts that are part of the judicial branch, unlike immigration courts, which are part of the Department of Justice. The terminology thus is confusing.)

Second, and most importantly, the authors fail to note how many of these cases are people in ICE custody and how many are respondents bringing paperwork to immigration court after picking up their groceries. Some of the cases involving challenges to birth certificates can go on for years, even over a decade, but the respondents are not in custody. These cases are an outrage but have an entirely different impact on people than similar inquiries for those in ICE jails.

Since the first chart label is "Americans" (sorry, Canada and Mexico) in ICE custody, it's likely most readers will infer everyone in these other cases also is locked up, but the authors don't say this and the data I have suggest they are characterizing detained and non-detained cases. (There are far more cases immigration judges terminate or close for those who are not in ICE custody than for those who are.)

EOIR releases immigration court proceeding data in such a way that the reporters should have been able to break these numbers out, but there is no clue in the Times reporting as to the portion of those who at the time of the termination orders were in custody, had been in custody but were released prior to their cases being terminated, or were never in custody at any point.

Also, there are no "suspended" cases. (If you want to see the original data and the legal outcomes EOIR uses from an original government release, please go to the bottom of this web page.) Immigration judges may "administratively close" cases, or ICE may use prosecutorial discretion and defer seeking a final order of removal in immigration court. A case may or may not be later reopened. "Suspended" means "to cause to stop for a period," but since many of these cases never are reopened this is a poor description.

If the respondent remains in the United States and acquires a U.S. passport or Certificate of Citizenship, for instance, and the case is not re-opened, then the case has not "stopped for a period," but is forever closed. How many are later reopenened? St. John and Rubin don't tell us.

Finally, the sentence and overall analyses are mixing apples and oranges. When an immigration judge terminates a deportation order for a case that at some point had an adjournment code indicating a claim of U.S. citizenship claim, it does not mean a citizenship case "warranted investigation." It means that someone asserted U.S. citizenship and ICE lost the case.

In short -- okay, the opposite of that -- the scant immigration court cases with U.S. citizen adjournment codes are the equivalent of a few pine needles on a Christmas tree ... in Rockefeller Plaza. Without a link to the original data, or more specific information about custody status, time, the nature of the claims, and outcomes, as well as legal context for questioning the government's vast understatement of these cases, there is not that much to look at. The graphic representing these cases with an eye-catching map with numbers and some city names misleadingly suggest otherwise.

For a detailed analysis of these cases, please go here. Again, Lise Olsen broke this part of the story, and more accurately, eight months before the L.A Times article.

L.A. Times Understates Real Problem of Citizenship and Deportation

This is the real problem with the reporting by the government numbers approach to deportation. Because my own reporting has used these numbers, I've felt a special commitment to include caveats about these data. My purpose, as I have explained previously, was to procure government data to falsify ICE's repeated assertions that they do not detain or deport U.S. citizens. Using government reports to falsify statements by the government is very different than using crappy, unexplained data to make authoritative claims about what ICE is in fact doing to people with U.S. citizenship claims.

As I've published, the data on these adjournment cases are demonstrably partial and woefully understate the magnitude of inaccurate evaluations. After hearing someone assert U.S. citizenship, the immigration judge could use a code for "seeks more time for an attorney," and this case will not be among those EOIR tracks as U.S. citizenship claims. There are many other reasons that people whose biographies fit the legal definition of U.S. citizenship and their cases will never show up in tabulations such as these, a common one is that they do not know they are U.S. citizens, a point St. John and Rubin acknowledge.

When people say that citizenship law and immigration law is complex, what they really mean is that governments have come up with status rules that fail to serve the realities of our lives and histories. The cruelty of these outcomes elicits legal challenges and their idiocy produces inexplicable outcomes. It is not a coincidence that the word "Kafkaesque" appears frequently in decisions by federal judges reviewing immigration court orders.

Trying to accurately count the number of "U.S. citizens" detained or deported over a denominator of "aliens" is like trying to count the number of people in the 1890s who were "White" but told to sit in the "Colored" train car, or the number of "Germans" in the 1930s who were misidentified as "Jews."

That said, I've published an estimate that about one per cent of all deportation cases are for those with U.S. citizenship and one half of one per cent of everyone deported is a U.S. citizen. These estimates are much higher than the government data in the Times article would suggest and are based on my actual observations and interviews, not those of the government.

This type of research among scholars is not so common, though it seems to be increasing. Alas, political scientists today have published gobs of research on what people think about immmigrants and deportation policies, but have very little to say about the deportation operations themeselves. The government and elites have paid great amounts of money to acquire information about our attitudes and behaviors, and are not so interested in funding research to help us learn about what the government and elites are doing to us.

To read more about the real meaning of the quandaries of citizenship in the United States, as well as India, Ivory Coast, Thailand, and other countries, please feel free to download courtesy of the nonprofit "Knowledge Unlatched" the well-received collection Citizenship In Question: Evidentiary Birthright and Statelessness, published in 2017 by Duke University Press.

If Paige St. John and Joel Rubin saw "Twelve Years a Slave," a film about a free Black man kidnapped by slave catchers in 1853, I assume their takeaway would not be outrage about the overenforcement of the Fugitive Slave Act and a free pass for slavery.

And yet this is the approach the authors take when representing the violence of deportation:

"...the detentions of U.S. citizens amount to an unsettling type of collateral damage in the government’s effort to remove undocumented or unwanted immigrants."

If U.S. citizens detained or deported are "collatoral damage," then that makes "undocumented or unwanted immigrants" legitimate targets of U.S. attacks. The language capitulates to the us-them mind-set of national sovereignty. The target of all deportation policies is civilians. All damage is collateral to other pointless damage. Indeed the "collateral damage" language applied to citizens versus immigrants itself reveals a most insidious collateral damage: the nation-state's militarized mindset is destroying our intelligence.

PROFESSIONAL AND ETHICS PROBLEMS

The reporters' failure to accurately characterize their data would be far less serious if they had provided links so that readers as well as other journalists, students, and scholars could evaluate the evidence behind their claims.

If St. John and Rubin do not produce the original sources, then people must rely on the Los Angeles Times statements about the U.S. government data, even though there are no accurate government data about these events. The government itself is not even claiming to produce these.

St. John and Rubin acquired the ad hoc, poorly described data about U.S. citizenship claims in the immigration courts because they copied an analysis previously reported in the Houston Chronicle. In short, the data on cases reviewed by ICE is inacccurately described and the data from immigration court adjournments for U.S. citizenship claims was a do-over with unclear results. For both, the absence of links to the original sources deprives readers the opportunity to evaluate the accuracy and import of their claims. No doubt this enhances the clicks and prestige of the authors and the newspaper, but it selfishly detracts from the public sphere rather than enrich it. The authors made extensive use of publications and analysis of others, most uncredited. The New York Times regularly links to its FOIA releases, court documents, and other original sources, while the article by St. John and Rubin is largely devoid of these. (The Poynter Institute and the Society for Professional Journalists endorse this practice as well.)

A few days ago, I shared this concern with St. John. She replied that sophisticated readers would know how to obtain these data. I then stated that one of her own colleagues revealed that he had not filed a FOIA request in four years. She asked me to refer the colleague to her and accused him of professional miscondcut. (I did not intend to publish our exchange so am not quoting directly, though I do think it fair to paraphrase.)

Here are some facts about the Freeedom of Information Act and journalists, including the Los Angeles Times.

First, St. John and Rubin appear to have obtained their data on investigations on claims to citizenship from a public relations officer of DHS or ICE; the data on the immigration court cases are from TRAC, which obtained this through TRAC's FOIA requests. Other data are from federal court cases, some of which are public but most of which St. John and Rubin fail to link.

It is useful to state the source because not all government data are the same. TRAC's co-director Sue Long and I have compared data sets for these U.S. citizenship adjournment cases. TRAC had cases I did not have and they had cases I did not have. (More evidence for the garbage in/out problem with these data and their inherent unreliability.)

Second, in reviewing ICE's FOIA logs, I noticed I was not the only one who had to recreate the wheel to figure out data in an Los Angeles Times article. Someone at the Annenberg School of Journalism had requested copies of "all records released to the Los Angeles Times in the past two years regarding immigration detention facilities in California..." (ICE FOIA Log, 11-2017).

Who thinks it's a good use of investigative time and resources, not to mention taxpayer money, to make people file FOIA requests and the government resend it? Maybe if the Los Angeles Times had released their FOIA responses in the article the journalist could spend more time documenting government misconduct or improving the quality of the story and maybe the new reporting would have assisted reporters at the Los Angeles Times.

Also, the FOIA logs disprove St. John's self-serving statement suggesting it is the norm for journalists to file FOIA requests. In the last year only a handful of reporters from the Los Angeles Times submitted requests. Moreover, according to the FOIA Project, the Los Angeles Times has filed just one FOIA lawsuit since the Bush administration. The reporter who said he stopped filing requests is well-aware that ICE usually will not release responsive documents without litigation.

(I filed my first FOIA lawsuit, pro se, in 2012, and have filed five additional ones since then, including a recent one with 29 FOIA cases. Documents from these, which I make available for no charge, have been used in scholarship by myself and others, reported on by journalists, and used in litigation.)

Third, it is impossible to reference all the articles, scholars, and attorneys on whom St. John and Rubin relied for their analysis. When I published articles on misconduct in deportation proceedings in The Nation I regularly quoted analyses from experts and did not paraphrase without attribution. Good reporting requires revealing their insights, not me parroting what they told me. Referencing these experts leaves a trail others may pick up later, as indeed has been the case.

I'm not saying that St. John and Rubin copied statements word for word. But if you update an article with different data and do not credit the person who came up the analysis and broke the story, then that infringes on ownership of an idea. The article copies analysis I've published on the cases adjourned based on claims of U.S. citizenship, the success rate based on presence of an attorney, and the characterization of the nature of these cases, as well as the history of ICE statements on this that St. John and Rubin tracked, including my reporting on on the origination of a hotline for reporting claims of U.S. citizenship.

Here's the paragraph tracking the information I reported here:

For a decade, ICE administrators have sought to end such mistakes. In 2009, after repeated warnings to agents from top ICE officials and a series of embarrassing deportations of U.S. citizens, then-ICE Director John Morton mandated that citizenship claims be investigated and reviewed by agency lawyers within 48 hours. A hotline was later set up to receive the claims.

The link includes links to other reporters covering these events as well, none of whom St. John and Rubin credit.

Another example of work they used without credit is my analysis of a webpage from a USCIS FOIA Manual I obtained through a FOIA request in 2016. It is from a document that had never been previously released and is 4,100 pages.

The screenshot on the blog post is from an especially hilarious page.

Garbage In

Here's what St. John and Rubin write:

A training document for users of the Central Index System, which is maintained by the U.S. Citizenship and Immigration Services, warns of incorrect or multiple identification numbers, scrambled names, inconsistent procedures for recording multi-part names common in Latin and Chinese cultures, aliases, misspellings and typographical errors, incorrect birth dates and lost records.

“Garbage in, garbage out,” the document cautions, a reminder that what computer systems deliver is only as good as what goes in.

They also reiterate analysis from a 2017 article from the Los Angeles Weekly, on an ACLU lawsuit over databases, linking neither to the article or the lawsuit. (Here is the most recent order on the ACLU website.)

Those familiar with my work remarked on the resemblance, including one reporter who called the uncredited use of my reporting and analysis "shameless."

Copyright law does not give one a right to own the facts one cites, but it does give one a property right in an original analysis of these facts, and that includes bringing them together in a unique way. It would be one thing if they quote from the USCIS manual as part of an article on hilarity in government manuals, and had examples from other government manuals with quirky observations. But when they use the exact page I publish and make the same points I make in the context of reporting on detaining U.S. citizens, that's another matter.

St. John and Rubin did original research but, understandably, they relied on other experts for ideas how to do this and the analysis of their findings.

Indeed, they contacted me after reading my widely cited law review article, "U.S. Citizens Detained and Deported as Aliens," which St. John called a "great resource."

I spent a long time giving them advice on how to do the research. Much of the reporting they did tracks what I suggested to them, and it tracks what I had done previously in the law review article.

The Ethics Code for the Society of Professional Journalists instructs reporters to indicate when news first is published by other journalists. St. John and Rubin did not do this. Several of the cases they report were covered by other journalists before St. John and Rubin wrote about them.

When I first contacted them in May, 2018, requesting that they attribute my work, they did not respond. I let the matter drop because I did not have the time to document the information above. I'd also forgotten that I'd assisted them the previous spring. I respond to a large number of media requests and this one slipped my mind.

When a colleague of theirs contacting me after seeing my work used by another journalist in an article recently published in the Texas Observer, I was reminded of the problems with their reporting and decided to follow up.

I requested that they add to the article an clarification stating, "Research from Jacqueline Stevens contributed to our analysis" and that they link to the the Deportation Research Clinic sources website on U.S. citizenship (http://deportationresearchclinic.org/USCData.html).

St. John wrote responses I found rude and dismissive. Rubin did not reply.

As of Tuesday, September 18, 2018 their editor is reviewing my request.