I need someone to make a PowerPoint presentation for me (sociology class)
We Are Not Dreamers Abrego, Leisy J., Negrón-Gonzales, Genevieve Published by Duke University Press Abrego, Leisy J. and Genevieve Negrón-Gonzales. We Are Not Dreamers: Undocumented Scholars Theorize Undocumented Life in the United States. Duke University Press, 2020. Project MUSE. muse.jhu.edu/book/77585. https://muse.jhu.edu/. For additional information about this book [ Access provided at 21 Apr 2021 03:50 GMT from Middle Tennessee State University ] https://muse.jhu.edu/book/77585 The American debate on whether to grant undocumented immigrants legal status raises, at its heart, questions about the procedural fairness of the American immigration apparatus and how public perceptions of that apparatus manifest themselves in discourse. Procedural fairness, according to Tom Tyler, queries the “manner in which authorities [exercise] their authority—on the fairness of processes rather than the fairness of outcomes” (Tyler 2004, 440). In creating an immigration apparatus that aims to be procedurally fair, there are numerous interests that must be accounted for: administrative efficiency bound up in the state’s need to control its borders, residents and citizens’ sense of a national identity, and the humanitarian interests of immigrants, among others. Emily Ryo describes immigration law as occupying “a unique position in our legal system as the only domestic law that is largely directed at regulating the behavior of noncitizens” (Ryo 2013, 575). The way we marshal those competing interests, both as a political and, more centrally for the purposes of this chapter, as a linguistic maneuver, reveals how prima facie procedurally just immigration policy makes exclusion invisible to the bodies it excludes. This chapter investigates metaphor as it relates to the law, the theory, and the politics of immigration, with a focus on the deliberative space in which immigrant and anti-immigrant rights groups negotiate immigration reform. I take “immigration reform” to mean any significant piece of legislation passed at the federal level that directly responds to the presence of over eleven million undocumented persons in the United States. Though immigration reform joel sati 1
“Other” Borders The Illegal as Normative Metaphor 24 Joel Sati has been synonymous with granting residency and citizenship to undocumented immigrants—a term I call “regularization,” this chapter does not directly contend with this view; rather, my primary interest here is the political and epistemic climate in which such a debate takes place, and the role that metaphor plays in constructing the debate. That said, I argue that when it comes to discussions of procedural fairness, undocumented persons are at a disadvantage when perceptions of procedural fairness are applied to deliberations on immigration policy. Said differently, the metaphors used against undocumented immigrants are an important dimension in making certain anti-immigrant measures salient in political discourse.1 An example would be the metaphor of “illegals” as an indiscernible mass (are they asylum seekers or isis fighters?) undergirding policies such as building a wall and other draconian measures. In addition to imbalances related to the availability of resources and lack of legal status, undocumented immigrant groups suffer from a more dangerous disadvantage: the metaphors that carry weight in policy discussions have the ability to warp the very narratives necessary for immigration relief. In other words, it is not only the issue of the presence of metaphor and narrative, but it is also the perspective of the people and entities creating them; this constitutes much of the disadvantage undocumented immigrants and other marginalized groups must contend with. In making this argument, I remark on the political climate that makes it difficult for undocumented immigrants to advocate for their interests. I am interested in how metaphor affects conceptions of procedural fairness, which I define as the extent to which American legal procedures of including and excluding immigrants are seen as legitimate. The central questions I contend with are: how do legal institutions—in particular, the courts—and the public political discussion figure into how undocumented immigrants make their claims for immigration reform? More centrally, how do the metaphors we live by in discussing immigration reform shape and constitute the responses that we devise for dealing with concerns of immigration reform? I respond by maintaining that procedural fairness plays a role in immigration discourse because either undocumented immigrants are accused of having seemingly flouted it (in, say, entering without authorization or overstaying their visa) or immigration reform that benefits undocumented immigrants is assumed to negatively impact considerations of procedural fairness vis-à-vis other groups (say, undocumented immigrants seemingly cutting in line for benefits legal residents have waited years for). Metaphor not only frames the issue; it does so in ways that maximize rhetorical value based on a group’s desired ends. “Other” Borders 25 In her paper, “Deciding to Cross: The Norms and Economics of Unauthorized Migration,” Emily Ryo concludes that “insofar as deterrence is an important goal in U.S. immigration policy, fostering greater perceptions of legitimacy (e.g., through promotion of greater procedural fairness) ought to be an urgent priority for U.S. policymakers” (Ryo 2013, 592). I am particularly interested in what she means by the phrase “fostering greater perceptions of legitimacy.” To whom is this procedural fairness accountable? Ryo appears to suggest that it is the appearance, not the existence of legitimacy that would make immigration policy more procedurally just. There exists a loose metaphorical relationship between appearance and reliability; in other words, if we see things as legitimate, then they are in fact legitimate—seeing is believing, the relationship would proceed.2 Recognizing how we can move from the appearance of legitimacy to actual legitimacy is critically important for those in immigrant rights. Examining immigrant rights campaigns and their appeals to legitimacy (for example, Clean Development, Relief and Education for Alien Minors [dream] Act legislation as aligning with core American values),3 without a substantive analysis of whether the legislation that results will actually help immigrants, will put an already-compromised community into further, unconscionable harm (United We Dream 2017). That is not to say that appearance of legitimacy is bad per se; however, it is dangerous to take the state’s self-assessment as legitimate as the only word on the matter. Language is important, metaphors matter, and both can efface the distinction between mere appearance of legitimacy, stifling critique from at-risk groups before it has a chance to begin. This chapter proceeds in three parts. In the first section, I explain that metaphors are much more than linguistic flourishes; they structure our thinking at a fundamental level (Lakoff and Johnson 1980). Indeed, we do not think about metaphor; rather, we think in metaphor. In addition, metaphors also shape how we think about policy. Thus, through highlighting some aspects and eliding others, metaphors make certain policies palatable in political discourse. Given this power, I focus on the pragmatics of metaphors rather than their truth-value. In the second section, I explore some of the most influential metaphors in the American immigration context, with particular focus on the “Illegal Immigrant as Alien” conceptual metaphor. Further, I use the metaphor of the “Immigrant as Dreamer” to argue that immigration reform politics is not an example of an egalitarian meaning-making contest. In making appeals for relief, immigrant rights activists are constricted in the kinds of appeals they can make due to more powerful anti-immigrant interests having their cognitive structures legitimated by the state. In addition, the narratives deployed by 26 Joel Sati immigrant rights activists serve to undermine undocumented immigrants’ push toward immigration reform. Let us take “Illegal Immigrant as Alien” as an example of the above. Since the late eighteenth century, the legal term “alien” refers to a foreign individual. However, in the mid-twentieth century, science fiction writers appropriated the term to discuss extraterrestrial, nonhuman beings (think green monsters with tentacles). Given the interchange of law and culture in this example, the term “alien” not only carries the legitimacy reinforced by case law, but also the valences attached to it by the prevailing culture.4 Thus, it makes it easier to conceive of immigrants as foreign and nonhuman, contributing to their place outside the polity. Then-Justice Rehnquist, in his dissent in Sugarman v. Dougal (1973), writes that aliens are unlike naturalized citizens who have assimilated “to our patterns of living and attitudes, and have demonstrated a basic understanding of our institutions, system of government, history, and traditions.”5 Undocumented immigrants become alien not only as a matter of phenotype, but also as a matter of understanding—citizenship is impossible for illegal aliens because they do not operate in the same cognitive, moral, or political space as citizens do. 6 The urgency that derives from this characterization and its implications is that because common understanding is incommensurable, the American way of life is under existential threat. Law professor Kenneth Cunningham-Parmeter examines the normative policy consequences of the “Illegal Immigrant as Alien” conceptual metaphor and resulting cognitive structure: “if immigrants are viewed as illegal alien criminals, then they should be captured and deported. If immigration is an invasion from the south, then the government should construct a virtual fence across the border to resist the Mexican offensive. These ‘common sense’ responses are made possible by selective metaphoric framing” (Cunningham-Parmeter 2011, 1550). The interchange of the unfamiliar and familiar within the two valences of the term “alien” is particularly interesting for this reason: the unfamiliar alien as nonhuman, foreign being is placed in terms of the legalized familiar, the alien as foreigner. Those who advocate for the expulsion of immigrants can draw on the legal import of the term alien while also drawing on its cultural import as green-monster-with-tentacles bent on destroying those considered humans—in this case, those who are citizens. Alienage and the term “alien” have proven a unique ability to conceptualize foreignness in both the legal and cultural consciousness. In utilizing metaphor to convey an existential threat, the state can manipulate the cultural valence and legal import of alienage to push a protectionist policy agenda vis-à-vis immigration. “Other” Borders 27 In the third section, I gesture toward an account of oppositional meaningmaking through conceptual metaphor. My goal is to expose and dismiss the pernicious metaphors used to frame the immigration debate. I argue that the metaphors and frames used in the dreamer narrative pacified the immigrant rights movement and made it much more difficult to push for more comprehensive immigration reform. In other words, undocumented immigrants were made to grovel for a humanity that ought to be presupposed (Sati 2017). This is important because, if we assume that procedural fairness is valuable in itself and only needs to be reworked, immigrant rights activism’s push for more humanizing metaphors is likely to contribute to positive changes to immigration law, as well as changes in attitudes toward immigrants that also take into account other displaced and marginalized peoples. This chapter’s implications, I argue, are as follows: how we think about immigrants shapes how immigrants are viewed, how immigrants view the world, and ultimately, what policies become all too real in the lives of undocumented immigrants. Metaphor, Cognitive Structures, and Policy Deliberation In Metaphors We Live By, linguist George Lakoff and philosopher Mark Johnson argue that metaphor is not just a flourish of language; it is human cognition, and the interpretations and actions derived from it are structured through metaphors. Lakoff and Johnson develop what they call the “experiential” account of metaphor; because the mind “operates in conjunction with a physical body that dwells in the physical world. Physical and spatial perceptions largely determine our metaphoric understandings” (Lakoff and Johnson 1980). Thus, when Lakoff and Johnson speak of metaphor, they move past the general definition of metaphor as a linguistic term and instead speak of “conceptual metaphor,” which emphasizes the cognitive potentialities of the concept (Lakoff and Johnson 1980, 6). As Lakoff and Johnson note, we humans “typically conceptualize the nonphysical in terms of the physical—that is, we conceptualize the less clearly delineated in terms of the more clearly delineated” (Lakoff and Johnson 1980, 59). A conceptual metaphor’s power lies in its ability to emphasize aspects of the unfamiliar and intangible in terms of the familiar in such a way as to shape the target of the metaphor (i.e., the unfamiliar). In that process, the very systematic nature that allows humans to understand one aspect of a concept in terms of another necessarily emphasizes one aspect while eliding others (Lakoff and Johnson 1980, 10). Metaphors, therefore, exert influence by instantiating frame-consistent cognitive structures—that means that a particular metaphor can manifest 28 Joel Sati itself in a variety of contexts, a phenomenon that becomes all too clear in our speech. As an example of what I mean by “cognitive structure,” consider the conceptual metaphor “Time is a Valuable Commodity.” From this metaphor, we can speak of wasting time, spending time, budgeting time, making things worth one’s time, living on borrowed time, investing time, and so forth (Lakoff and Johnson 1980, 10). The cognitive structure molds our conception of time to that of a limited, zero-sum commodity that must be invested well; this happens in various contexts, each one consistent with the larger frame the metaphor instantiates. Thus, the ways in which we speak of time comprise the cognitive structure that the conceptual metaphor underpins. The best way to appreciate the importance of these cognitive structures is that they do not structure our thoughts about time; rather they structure our conception of what time actually is. As I apply the time example to matters of law and politics, I want to note Lakoff and Johnson’s point that metaphors possess a self-fulfilling quality. That is, because metaphors serve as a guide for future actions that fit the metaphor, this will, in turn, reinforce the metaphor’s ability to give coherence to one’s experience. In this sense, “metaphors can [have] self-fulfilling properties” (Lakoff and Johnson 1980, 156). The suggestion that the powerful and privileged can easily create and impose metaphors underlies the integral role of metaphors in creating the public discursive space. Metaphors, as conceptual schema, thus structure how we view certain issues as salient; that is, metaphors not only define an issue for us, but they also inform us how much we should care about it and how we should approach it through policy. Legal scholars have explored how metaphors and their resulting cognitive structures are employed in policing and crime control. In their paper, “Metaphors We Think With: The Role of Metaphor in Reasoning,” cognitive scientists Thibodeau and Boroditsky (2011) reveal that linguistic framing shapes reasoning and that systems of power (i.e., the legal system and the political process) consolidate meaning instantiated by metaphor. These authors argue that the cognitive structure inherent in a metaphorical system may undergo what they call analogical transfer. Analogical transfer “can license the transfer of inferences from one domain to the other, and the most striking or stable structural similarities can be highlighted and stored in memory” (Lakoff and Johnson 1980, 9). Repeated analogical transfer from the source domain to the target domain reifies structural similarity between them. In other words, the transfer from the familiar to the unfamiliar becomes seamless such that we cease to think of one thing in terms of another and think of one thing as another. “Other” Borders 29 Thus, I argue that metaphors not only determine how we make sense of issues, but how we seek out information in constructing possible policy responses. Before delving into that further, I should note the following: metaphors about immigration rarely stand up to scrutiny. As a test case, consider the metaphorical frame “The Immigration System is a Line One Waits In.” Part of why that metaphor sticks is its simplicity; think of how angry you would be if you were cut in line for something. However, on the other hand, the metaphor is pernicious in its simplicity. The processes of immigration and naturalization cannot be conceptualized in terms of a line, and even if it could be, it would be a slow-moving one that leaves those waiting for naturalization for up to two decades. Lastly, the line metaphor gives too much credence to the procedure and the institution that operationalizes it. The immigration regime, which many activists rightly rail against, is given a prima facie legitimacy that forestalls critiques of detention, family separation, and restrictionist policy and rhetoric. Another aspect that affects the salience of metaphor is whether the public will use a certain cognitive structure if experts reinforce its meaning. “Experts” here refers to legal officials: judges, lawyers, politicians, bureaucrats, and so on.7 Experts are in a unique position to manipulate metaphors and cognitive structures in one of two, non-mutually exclusive ways: (1) experts do not know all the metaphors they use, but they can still deliberately pick which ones to use at times, or (2) experts may not be aware of the metaphors they use, but they still unconsciously select and use metaphors that are advantageous to themselves due to their position as experts (for more information, see Putnam 1973). And, as I will argue later, the products of such manipulation—cognitive structures finding their way into judicial decisions, legislation, or the administrative state’s modus operandi—provide the underwriting necessary for the polity at large to structure their normative policy goals according to the promulgations of the state. That said, what is most important about these metaphors is not about whether they are accurate, but why they exist. In this sense, the metaphor’s importance moves from the meanings metaphors instantiate to their pragmatic value. Finn Makela, epistemologist of law, characterizes this as “refocus[ing] the analysis of law from what metaphors mean to what metaphors do” (Makela 2011, 407).8 The importance of understanding metaphors and the cognitive structures they instantiate only ratchets up in a society such as ours, where the myth of objectivity has such controlling power. In a culture where the myth of objectivism is a constitutive part of Western culture “and truth is always absolute truth, the people who get to impose their metaphors on the 30 Joel Sati culture get to define what we consider to be true—absolutely and objectively true” (Lakoff and Johnson 1980, 160). All of this suggests that the importance of metaphors for policy discussions hinges on their ability to galvanize public and institutional support for certain policy positions. The resulting influence of cognitive structures in politics not only shapes how we view policy, but how we think we should view policy. A critically important consequence of metaphors and the cognitive structures they instantiate is that they influence our conception of what truth is. According to Lakoff and Johnson, what matters is not “[the] truth or falsity of a metaphor but the perceptions and inferences that follow from it and the actions that are sanctioned by it” (Lakoff and Johnson 1980, 158). Cunningham-Parmeter also comes to the conclusion that “the more we repeat, circulate, and repackage certain metaphors, the more our conceptual domains become tied to a limited set of associations” (Cunningham-Parmeter 2011, 1548). And the more that the law sanctions these limited sets of associations, metaphors and their resulting cognitive structures cease to be ways we view law and instead become the law. I use this example to contend that given metaphor’s unique ability to corrupt notions of procedural fairness, we can assess the utility of procedural fairness in two ways: either procedural fairness is problematic insofar as it serves as an ideological frame that legitimates the unfair implementation of state authority (so notions of procedural fairness are a kind of dominance framework), or procedural fairness is corrupted in a particular political context because it does not account for the input of noncitizens. The former possibility suggests that procedural fairness is itself a suspect idea, while the latter case suggests that oppositional movements can potentially reconstitute procedural fairness and popular understandings of it to make good on the promise that public discussion on political issues claims it holds. Therefore, for this chapter I will work on the latter possibility and analyze its use in the immigration reform context. Immigration Metaphors and Cognitive Structures In the face of competing ideas of the ideal society, and the differing opinions among people as to how immigrants figure into conceptions of the ideal society, immigration policy debates become meaning-making competitions among interest groups. “Metaphors play a critical role in making meanings for the groups that use them; those who oppose immigration have an interest in propagating metaphors that emphasize the undesirable aspects of immigrants and hide other aspects. The metaphor ‘immigration as a wave’ will “Other” Borders 31 emphasize the destructive force of migration while hiding the fact that migrants are human beings” (Santa Ana, 2002). It also makes a certain policy proposal—that of a physical bulwark (i.e., a wall)—appear to be a reasonable goal. Just like it would be absurd to deal with a wave at the molecular level, the metaphor of “Immigration as a Wave” makes it absurd to look at immigration at the level of the immigrant (see Santa Ana 2002 for more on the “immigration as a wave” metaphor). The metaphor characterizes the problem in a way that implies, or makes necessary, a certain solution. Voters and policymakers who strongly support immigration restrictions might view procedural fairness as summary deportation and use the metaphor to achieve their policy aim. If we take political and legal disputes to be meaning-making competitions, those competing in the political process seek the state’s legitimacy for their policy proposals in line with a group’s interests. Metaphor plays a critical role in this process; a particular metaphor’s endorsement through its use in establishing precedent and grounding legislative discussion gives the metaphor a kind of “legitimacy-at-first-glance” and, through its constant framing of a certain issue, actually becomes socially desirable. It is safe to assume that in conversations about immigration reform, the political interests of residents and citizens will outweigh those of undocumented immigrants.9 From this assumption, I argue that undocumented immigrants do not have as much access to the political process as is necessary to ensure an outcome they would view as procedurally fair. This is because the metaphors that the courts and politicians use to refer to undocumented immigrants normalize a particular way of speaking to and about those without status, and the inability of undocumented migrants to contend with this discourse politically exists in large part because of such metaphors. Metaphors become a tool of exclusion that, by the time deliberation occurs on undocumented immigration, renders their exclusion as given. In answering how political institutions consolidate the instantiation of meaning in the political context, my contention is that legal and political institutions (i.e., the courts and the legislature) not only imbue the meanings of political metaphors but, due to their position, play a unique role in accelerating the salience of certain metaphors—I focus on immigration metaphors—as tools of political exclusion.10 Cunningham-Parmeter provides a convincing account of the staying power of metaphors and their ability to warp, irreversibly, lay views on immigrants. He finds that “the more we repeat, circulate, and repackage certain metaphors, the more our conceptual domains become tied to a limited set of associations”(Cunningham-Parmeter 2011, 1548). Placed in the immigration context, the constant propagations of the “Nation as Body” or the “Illegal Alien 32 Joel Sati as Pathogen” metaphors by the courts, the legislature, and interest groups (i.e., those with the power to determine and influence law and policy) become the best way to characterize the political situation that unauthorized immigration presents, thus fueling their continued use. Assuming that deliberations about procedural fairness between proponents and opponents of regularizing undocumented immigrants require that they have equal access to the tools of political participation, there exists an unfairness in deliberation whereby undocumented immigrants and the groups that work in their interest have fewer opportunities to deliberate about immigration reform than legal residents and citizens. And, say, if a candidate for political office who supports immigration restrictions thinks it procedurally fair to build a wall, that might carry more weight in discourse relative to the policy ideas of undocumented immigrants and their interest groups. Conversely, undocumented immigrant interest groups, who have to first fight to be recognized as human, have a difficult time erasing their association with aliens and alienage. For example, suppose undocumented immigrant groups wage a campaign against the term “alien” because it is dehumanizing; immigrants are not extraterrestrial monsters with green skin and tentacles (drawing on the cultural valence of the term). However, the legal tradition the term “alien” carries makes that difficult. This is a prime example of the reifying power inherent in political metaphors. Thus, in its interaction with systems of power, metaphor plays a critical role in establishing the normativity of cognitive structures, which in turn influence the salience and the perceived normativity of certain policy positions. Here, “perceived normativity” is equivalent to what Ryo and the procedural justice literature label as “perceptions of greater procedural fairness.” Grounding this view is the assumption that the appearance of fairness in an immigration system is sufficient for the policy to be desired. Lakoff and Johnson (1980) note as much; they argue, “Metaphors may thus be a guide for future action. Such actions will, of course, fit the metaphor. This will, in turn, reinforce the power of the metaphor to make experience coherent,” harkening back to the invidious cycle that Lakoff and Johnson note (156). Metaphor is integral in constructing what law promulgates as procedurally fair, which, in turn, shapes the polity’s conception of procedural fairness. Take, for example, the metaphor of the “Nation as Body.” In the cognitive structure this metaphor creates, undocumented immigrants are a foreign invasion that pose an existential threat to the health of the nation qua body (Chavez 2013). When a pathogen is detected, the body unleashes a swift, fatal response to what it perceives as a threat. Further, given how much weight this “Other” Borders 33 metaphor carries in political discourse, swift responses to remove the invasive force that is undocumented immigration appear to be a fair response. People with significant political clout can employ this metaphor in rhetoric aimed at residents as well as in the written law, such that metaphor is indistinguishable from legal terms. If immigrants are metaphorically characterized as a pathogen, the policy idea of swift action—that is, summary deportation—fits the conceptual structure the metaphor creates. The metaphor characterizes the unfamiliar (undocumented immigrants) in terms of the familiar (a pathogen), and the prefigured response to immigrants as pathogens is tantamount to a swift, targeted, and decisive bodily reaction to an existential threat— think of penicillin responding to bacterial agents. Such a conception of dealing with the expulsion of noncitizens thus justifies and makes normative the characterization of undocumented immigrants as pathogens, and the invidious cycle continues. Thus, there is one more powerful party imposing its metaphors at play here; it is those who have the status and goods of citizenship who control the terms of the debate on procedural fairness surrounding immigration. The deliberative unfairness manifesting itself in the politics of immigration reform will lead to either no reform, piecemeal policies that fracture and pacify immigrant subgroups, or, worse yet, predatory policies against undocumented immigrants. As I have argued, it is not merely enough to expose these metaphors as inaccurate or unjust; the metaphors, given the power held by who is imposing them, receive the state’s legitimacy, making them a normal part of immigration discussions. The discussion of metaphors in the American political space is, therefore, of critical contemporary importance. Those with access to the political and legal arms of the state can more easily impose their cognitive structures, influencing how members of the polity metaphorically reason through, and thus normatively conceive of, policy. A prime example of this is “Naturalization as a Line/Queue.” Through this metaphor, American policymakers and laypeople conceive of the naturalization process (and, as a corollary, the entire immigration apparatus) as procedurally fair. One of the most common retorts in opposition to undocumented immigrants’ residency claims is to demand that they “go to the back of the line.” Policymakers deploy the “line” metaphor to describe the order in which noncitizens should arrange themselves according to their anticipated enjoyment of state benefits. Some people come to consider unauthorized immigration as not only illegal but unjust because migrants are portrayed as looking for easy access to benefits and jumping the queue. According to Bergeron (2013), lawmakers’ admonition that undocu- 34 Joel Sati mented immigrants “go to the back of the line” is one they adopt ostensibly “to convey the intent to grant legal status to unauthorized immigrants only after existing backlogs have been cleared.” Absent in this metaphor and its presentation is the fact that there are statutory limits to the number of visas that the United States Citizenship and Immigration Services (uscis) can grant in any given year. In addition, it takes years—even decades in some instances—to receive permanent residency. Thus, the conceptual metaphor “Naturalization as a Line/Queue” emphasizes the normativity of order—that is, those who are first in line have a stronger claim—and hides other aspects such as the excessive demand for visas relative to the actual number uscis allocates annually. Immigrants who migrated to the United States and were able to be regularized can take the high ground and proclaim that they did things the right way. In political discourse, the line becomes a device that citizens use to enable a hierarchy, in which we order those noncitizens more deserving of benefits ahead of those noncitizens who are less deserving. For the most part, citizens would not imagine themselves to even need to be in the line. They circumvent that line altogether. The line doesn’t apply to citizens. Even more consequential is that undocumented immigrants themselves are unable to gain residency and citizenship due to bars that prevent those who have accrued unlawful presence from adjusting their status. These bars, and the fact that the line metaphor conceals them, are important to note. Even if adjustment of status were an option for many undocumented immigrants, they must leave the country to obtain their visas from consular outposts abroad. Depending on the amount of unlawful status an immigrant has accrued, there exists an immigration provision11 that bars them from entering the United States for either three or ten years. Employing the line metaphor in that way adds a normativity to the metaphor that further adds to the marginalization of undocumented immigrants in that they are now taken to not have an understanding of law or morality, which are (rhetorically) considered lynchpins of the American nation-state. Oppositional Cognitive Structures and Undocumented Immigrant Movements Perhaps the most pernicious effect of the power imbalance indicated in the acceptance of certain cognitive structures at the expense of undocumented immigrants is that, in contending against an anti-immigrant political environment, anti-immigrant metaphors and cognitive structures restrict undocumented immigrants’ ability to construct humanizing narratives as well as concrete policy proposals. Such proposals become so restricted that the most “Other” Borders 35 successful ones almost always must receive the approval of the very political establishment they aim to critique. Thus, these “oppositional cognitive structures,” as I label them, are either made in response to, or in light of, the cognitive structures of those with power. Regarding metaphor and the cognitive structures they instantiate, I contend that in making claims in the political sphere, undocumented immigrant groups are all but forced to operate under the establishments’ framings—in this case, anti-immigrant interests as well as the national myth that places them outside the polity. In this section of the chapter, I develop an account of the importance of building an oppositional cognitive structure and making it the new norm in contemporary American immigration discourse. By this I mean that, given metaphor’s role in highlighting certain aspects of a target domain and eliding others, an important part of narrative-building strategy must include an analysis of metaphors that anti-immigrant interests use and courts legitimate. The oppositional cognitive structures immigrants’ rights movements must expose should engage, but not align with, politically dominant cognitive structures. The goal should be to expose these cognitive structures’ specious claims to normativity, which with sustained activism will hopefully lead to their disuse by legal institutions. In developing this basic account, I do not argue for the normative value of legal institutions as currently constructed. Rather, I recognize that policy must go through legislative deliberation and judicial review and strategizing in light of them will have a real effect on the daily lives of undocumented immigrants and their capacity for political action. Political engagement for undocumented immigrants and other marginalized groups is critical to surviving in an environment that presupposes their lack of humanity and puts into practice their dehumanization through deportation, stigma, and denial of necessary services. I take as given the assumption that the aims of oppositional cognitive structures are better policy. If oppositional cognitive structures are not sufficiently differentiated from powerful cognitive structures, this serves to undermine not only the oppositional cognitive structure’s policy aims, but the normative value of good policy. As a cautionary example, consider the “dreamer.” The dreamer, in discourse on immigration, denotes someone who entered this country at a young age, achieves impeccable grades or is otherwise high-achieving professionally, has unaccented speech or otherwise accepts various aspects of American culture, and wholeheartedly believes in the American Dream and its attendant myth of meritocracy. Despite their undocumented status, dreamers consider themselves part of the American community in every relevant way, save 36 Joel Sati papers. In making a claim for immigration reform or for a more piecemeal policy, dreamers mark themselves as deserving of residency and citizenship. For example, consider when high-profile dreamers endorsed candidates in the 2016 democratic presidential primaries. dreamers garnered influence within their communities, and used the resulting clout to back a candidate who would be a fierce advocate for immigrant interests. Here are how the major endorsements shook out: Erika Andiola and Cesar Vargas endorsed Bernie Sanders, Astrid Silva endorsed Hillary Clinton, and Jonathan Jayes-Green endorsed Martin O’Malley (Carrascillo 2015; Silva 2016; Hernández 2015). For the purposes of my argument, I will introduce what I call “metaendorsement.” Meta-endorsement as a concept is cognizant of the ways in which power shapes resistance and those who carry it out. What is especially pernicious about meta-endorsement is that, though undocumented immigrants may have access to the political system and have some political power, they are still subject to the political system and are nevertheless answerable to it. How does meta-endorsement operate in this example? The candidate can gain the support of the community that the dreamer represents. However, the candidate—many orders of magnitude more influential than the dreamers—retains the ability to determine who can endorse them. In partnering with high-achieving undocumented immigrants with spotless records, strong community ties, and a robust belief in the American political system, the candidates reify the caricature of the dreamer as the subgroup within the larger cohort of undocumented immigrants that most deserves to benefit from immigration reform. This example shows how meta-endorsement, in exposing the inner workings of the political system, relegates—or exposes—endorsement as a mere tool of politics. This caricature of the dreamer as the most deserving immigrant allows for only some undocumented immigrants to benefit from rightsprotecting policies, such as Deferred Action for Childhood Arrivals (daca). There exists the argument that young immigrants have the time and can present themselves as more sympathetic, placing themselves at the forefront of immigration activism. In other words, dreamers have a comparatively extensive ability, relative to their influence, to shape the narrative in contrast to their parents, unmarried undocumented adults (mostly men), and undocumented immigrants with criminal records. To the extent that the trope of the young, high-achieving immigrant who believes in the American Dream holds sway, they are able to shape the narrative for all undocumented immigrants, placing themselves at the forefront. Within this particular metaphor there are numerous controlling assumptions: that there is a clearly delineable process “Other” Borders 37 for prospective migrants to follow, that those who do not take part in this process choose not to do so, and further, that the choice not to do so is a violation that demands criminal sanction; offenders should be punished with deportation (Murdock 2018). At this juncture, it is critical to note two things. The first is that it is easy for me to conduct the foregoing analysis after the fact. Though the dreamer narrative is one that is accepted by significant constituencies within the immigrant rights movement as being dangerous, there is much to be said for the argument that such a narrative represented the most pragmatic argument possible at the time in which it became salient. The second is that there is an ongoing dialectic between the piecemeal and the comprehensive. This dialectic compels those within the immigrant rights movement to be conscious of framing claims-making in such a way as to secure the proximate avenues of relief while not sacrificing the movement’s more comprehensive political objectives. In her paper “Legal Consciousness of Undocumented Latinos,” sociologist Leisy Abrego (2011) contests the idea that undocumented immigrants’ integration processes are monolithic. She argues that examining differences in claims-making behaviors among undocumented immigrants “reveal[s] an interplay between legal status . . . as well as experiences with migration and social institutions that differentially affect their sense of belonging and incorporation experiences” (Abrego 2011, 339). She begins by introducing Adela, a mother whose child plays a prominent role in dream Act activism. Though her child can play a prominent role due to possessing the prototypical “dreamer” narrative, Adela herself is much more removed; her status as the stereotypical undocumented immigrant makes her not only less sympathetic a figure, but also a target. Though Abrego seeks to examine how positionality determines the types of claims undocumented immigrant subgroups make and does so in a way seldom done in the literature, she does not consider the effects of race in her analysis. Granted, work on undocumented Black immigrants, though ongoing at the margins for years, faced significant barriers to inclusion in the larger immigrant rights movement until the Black Lives Matter movement became the touchstone of social justice activism. To wit, there was little to no treatment of the plight of Black undocumented folks until the Black Alliance for Just Immigration published their “State of Black Immigrants” Report in 2016, in conjunction with New York University School of Law. Still, the lack of a deep race analysis within the immigration movement at the time of the dreamer’s creation facilitated the adoption of a model-minority narrative that marginalized both non-dreamers as well as Black people, immigrants or otherwise. 38 Joel Sati Though I cannot conduct a deeper dive into how race plays a part in political analysis, I want to note its general relevance especially given recent, grave developments in American politics. On November 5, 2016 Donald Trump— who holds unabashedly anti-immigrant views—was elected President of the United States. In a 60 Minutes interview, he promised to prioritize the deportation of three million so-called criminal immigrants (Davis and Preston 2016). The three million figure is a red herring (Abrego et al. 2017). Of note is the “criminal” label: by leaving the term undefined yet still allowing it to fester in the public consciousness, I contend that there will be an expanded notion of criminality such that all immigrants will be regarded as criminals without necessarily having a criminal record. There is an interplay between the two cognitive structures that is metaphorical in nature—the unfamiliar immigrant is referred to in terms of the familiar criminal/illegal cognitive structure (Stumpf 2006). In not separating the criminal from the immigrant, and in not delineating what a noncriminal immigrant would look like, such rhetoric seeks to conflate the two. Further, policies such as mass deportation and the increase in incarceration of criminal others—Black and Brown bodies—will continue to reify the conceptual metaphor as the normative framework for dealing with the immigrant as well as the criminal. The Trump administration is, in ways both public and private, attempting to fracture the immigrant rights movement by separating the wheat from the chaff, metaphorically speaking. President-elect Trump indicated amenability toward helping dreamers; nevertheless, he made good on his promise to rescind daca by instructing Acting Department of Homeland Security Secretary Elaine Duke to wind down the program (Foley 2016; Department of Homeland Security 2017). However, at the time of writing, Judge William Haskell Alsup of the U.S. Court of Appeals for the Ninth Circuit ruled that, while cases against the Trump administration are ongoing, uscis will accept daca renewal applications (McCallister 2018). Concurrently, Democrats in Congress are attempting to strike a compromise with the Trump administration on a permanent fix for daca, which would go above and beyond its predecessor in providing a path to citizenship for undocumented immigrants who arrived as children (Manchester 2018). The critical impasse is whether protections for these immigrants will be at the cost of increased immigration enforcement, the absence of which immigrant rights advocates maintain is a necessary condition of a “Clean dream Act” (National Immigration Law Center 2017). I have made the point that daca, as a political tool, served to pacify dreamers. Relative to other undocumented immigrant subgroups, they have the time, the zeal, and the support to make claims against the state. But as “Other” Borders 39 I showed, their strategies further marginalized undocumented immigrants who do not fit the mold, such as adults and those with criminal records. Moving back to the undefined Trumpian notion of the “criminal,” there is little indication that dreamers will be shielded from the presumption of criminality that now receives state approval. Further, the “Immigrant as dreamer” conceptual metaphor and resulting cognitive structures elide the intersections of race and criminality. Just as Abrego argues that various undocumented immigrant subgroups occupy diferent positionalities as a function of their age at entry and socialization, others differ based on race. The construction of oppositional cognitive structures is important for undocumented immigrants as people who deserve recognition. In discussing the rights consciousness of undocumented immigrants, Abrego (2011) reports on a 2008 immigration raid in Postville, Iowa, in which although the employers provided the workers with false documents, it was the workers who were detained and punished (355). As an explanation for why the undocumented workers did not defend themselves, an interpreter describes what one worker told them: “No matter how many times his attorney explained it, he kept saying ‘I’m illegal, I have no rights. I’m nobody in this country. Just do whatever you want with me’” (Preston 2008). The cognitive structures “Illegal Immigrant as Alien” and “Illegal Immigrant as Criminal” work together such that the undocumented immigrant does the work of dehumanization for the state, which propagates these cognitive structures. Regarding the former cognitive structure, the undocumented worker does not deserve rights because only humans have rights, whereas the latter cognitive structure decrees that he does not have rights because criminals by definition give up their rights. The legitimation of these cognitive structures through legislation and judicial decisions means that undocumented immigrants develop conceptions of self that are deeply imbricated within these cognitive structures. Moving further along this line of thought, Tamara Nopper has done helpful and important work in exposing the cognitive structures that mold existing conceptions of the undocumented immigrant worker. Indeed, discourses centering on undocumented workers draw upon “managerial and capitalist perspectives of labor as well as antiblack rhetoric regarding African Americans as lacking a work ethic, being militant, xenophobic, and costly to society” (Nopper 2011, 2). Conceptions of undocumented immigrant productivity—in this case, Nopper focuses on Latinos—is amplified at the expense of African Americans; the immigrant cares about and needs work whereas African Americans are lazy due to benefiting from welfare. In further contrast to undocumented workers, who are actively positioning themselves as valuable human capital 40 Joel Sati despite hardship, African Americans are considered physically imposing and threatening, indicating that they do not “know their place” in the American racial hierarchy (Nopper 2011, 8). Perhaps the most important aspect of Nopper’s work is her conclusion that despite the existing discourse situating itself in a discussion of neoliberal globalization, it does not—in fact, it cannot—be antagonistic to capital because its central thrusts are firmly within the cognitive structures that place capitalism as both instrumental to citizenship and normatively desirable (Nopper 2011, 17). With this conclusion in mind, I turn to Cunningham-Parmeter’s proposition of the conceptual metaphor economic sanctuary (his italics) as foundational to an immigrant counternarrative. He writes that the economic sanctuary metaphor “emphasizes the connections shared by migrants and displaced American workers; just as Americans become unemployed when their jobs are shipped overseas, migrants feel the consequences of international trade from the other side of the border” (Cunningham-Parmeter 2011, 1596). I am intrigued by the possibilities of the metaphor, though I would add that given where I think Cunningham-Parmeter wants to go with the metaphor, the word “economic” is subject to an anticapitalist critique. Despite the foundational flaws of the dreamer metaphorical framework, it has nevertheless secured important victories at the federal and state levels, thus providing a safer academic and political environment for undocumented scholars like myself to begin developing the kinds of cognitive structures that will replace the moribund dreamer framework. In an op-ed published by the Washington Post, I argue that daca, despite all its benefits, did significant harm due to its roots in the dreamer framework (Sati 2017). Using myself as an example, though I have the opportunity to secure advanced degrees at two elite universities because of daca, my achievements do not make me any more deserving than those without them. Still, I can use my position to argue for undocumented immigrants in a more precarious position. Thus, in protecting and, more importantly, building on daca, I implore the immigrant rights movement to begin adopting alternative frameworks. Despite the necessity of creating oppositional frameworks, I do acknowledge Cunningham-Parmeter’s effort and agree that conceptual metaphors will fail to capture everything. It might be the case that the immigrant rights movement will develop cognitive structures that rely on some notion of respectability, especially when it comes to converting those in the immigration debate who are unconvinced by our position. Nevertheless, it is important that undocumented immigrants understand the role of metaphor in creating cognitive structures that exist outside notions of capital and criminality, as “Other” Borders 41 well as the notions of deservingness inherent in both. Thus, undocumented immigrants are better able to utilize new frameworks and fight back against what Cunningham-Parmeter labels the “jurisprudence of otherness” present in metaphorical frameworks such as “Illegal Immigrant as Alien,” “Immigration is a Flood,” and “Immigration is an Invasion.” Therefore, it is critical that undocumented scholars take the forefront in developing oppositional analysis that contends with the problem of noncitizenship in our time. Conclusion In this essay, I argue that examining conceptual metaphors and the cognitive structures they instantiate sheds important light on the political discourse in which undocumented immigrant activism takes place. Analyzing the entities that normalize metaphors and the cognitive structures that spring from them reveals not only something about the power of such entities, but also illumines how these metaphors can become significant such that we not only think about them, but think on their terms. Regarding undocumented immigrant activism, I argue that the creation of oppositional cognitive structures that are completely cleaved from dominant ones will help create policy that is more inclusive of the various identities that intersect with undocumented status—such as race, gender, and criminal record, among others. Furthermore, such oppositional structures are more attentive to undocumented immigrants’ policy aims. In addition, differentiated oppositional cognitive structures result in normatively better policy debates and, in turn, normatively better policy for everyone. In all, a push for greater procedural fairness rings hollow without a thorough discussion of the role that noncitizens play in the deliberative framework. notes I would like to thank K. T. Albiston in the Jurisprudence and Social Policy PhD program, Sunmin Kim and the Immigration Working Group in UC Berkeley’s Sociology Department, and the editors of this volume for their constructive feedback. Lastly, I would like to thank my partner Bianca Waked and my pet cats Langshaw and Marlo, all of whom keep me sane. 1. This essay focuses on metaphors about immigrants. Though immigrants do use metaphors about citizens, this dimension of the debate is not the focus of this chapter if only for the reason that I want to make clear the link between metaphor and policy. Focusing on metaphors about immigrants presents the link in stark relief, though I want to emphasize that metaphors about immigrants are not the totality of metaphors in the immigrant rights debate. 2. This sentence reminds me of the cliché phrase “seeing is believing.” The cognitive framework that the phrase instantiates had a significant influence in my reading of Ryo’s paper. As a further avenue of research, I am interested in how empiricism or 42 Joel Sati empirical-like considerations structure our conception of truth and the many ways such a conception manifests itself in the law. 3. “Passing a Clean dream Act is the Top Political Priority of This Year.” In this article, billionaire and Democratic donor Tom Steyer is quoted as saying “When we stand up for Dreamers and the whole immigrant community, what we are really standing up for is justice in America and the rights of Americans everywhere. The triumph of America is when we move our laws to line up with our values—and that’s what we’re asking for today. So let’s live up to our true American values and pass a Clean dream Act” (emphasis added). For more information on the Clean dream Act, see this guide by the National Immigration Law Center: https://www.nilc.org/wp-content/uploads /2017/10/Clean-Dream-Act-1pg-2017.pdf. 4. Given the importance of immigration as an issue, much more work needs to be done on how narratives are constructed vis-à-vis the conceptual structure of Immigrant as Alien. 5. Sugarman v. Dougall, 413 U.S. 634, 662 (1973) (Rehnquist, J., dissenting). 6. Another thing that occurs to me about the term “alien” is the movement back and forth between cultural and legal contexts. What is the law to do? At first glance, the law’s almost-apotheosis of precedent means that the law should not be counted on to disuse the term “illegal alien.” Further yet, I conjecture that any attempt by the law to disuse the term is, to use an idiom, locking the barn door well after the horse has bolted. Though an investigation of the Illegal as Alien metaphor is a fruitful endeavor and pushing for its use in legal contexts a worthwhile exercise, the cultural valence attached to the terms makes any effort an extremely difficult one. 7. It is important to define what an expert is. For the purposes of this discussion, experts (1) have esoteric knowledge about a certain discipline, and (2) engage in foundational debates about things that they have esoteric knowledge of. I will call (1) the esoteric condition and (2) the positionality condition. For example, a professor in the philosophy of language is an expert because (1) she has esoteric knowledge of a philosophical subdiscipline, and (2) she holds a professorship and engages in academic discourse about esoteric subjects within said subdiscipline. Consider another example: it is neither necessary nor efficient that every person who wears a gold ring engage in buying and selling gold or in determining the authenticity of gold, since there are experts to fill both niches. 8. Emphasis in original. 9. Admittedly, this is a very U.S.-specific assumption. That is, though true in the American context, it is not a given in other countries. For example, in the late 1800s and early 1900s, several Latin American countries aimed to attract Europeans to become citizens. They viewed this as a whitening process that would dilute African and Indigenous races through miscegenation. In that racist process, they prioritized the rights and the humanity of white immigrants above those of other populations. Many thanks to Leisy Abrego for this insight. 10. I am not trying to conflate equality of opportunity with equality of influence. I argue that metaphors and accompanying cognitive structures manipulate the very notion of opportunity operant in political discourse. If undocumented immigrants are “Other” Borders 43 metaphorically constructed as the nonhuman alien and undeserving of rights, arguing for equal influence seems pointless. What is more important is that undocumented immigrants do not have the opportunity to influence, and it is this knowledge that undocumented immigrant groups must be aware of when constructing opposition. 11. INA § 212(a)(9)(B). references Abrego, Leisy J. 2011. “Legal Consciousness of Undocumented Latinos: Fear and Stigma as Barriers to Claims-Making for First- and 1.5-Generation Immigrants.” Law and Society Review 45: 337–370. https://www.jstor.org/stable/23012045. Abrego, Leisy, Mat Coleman, Daniel E. Martínez, Cecilia Menjívar, and Jeremy Slack. 2017. “Making Immigrants into Criminals: Legal Processes of Criminalization in the Post-iirira Era.” Journal on Migration and Human Security 5(3) :694–715. https://doi .org/10.14240/jmhs.v5i3.105. Bergeron, Claire. 2013. “Going to the Back of the Line: A Primer on Lines, Visa Categories, and Wait Times.” Migration Policy Institute, March 2013. https://www.migrationpolicy .org/research/going-back-line-primer-lines-visa-categories-and-wait-times. Black Alliance for Just Immigration. 2016. “State of Black Immigrants.” Black Alliance for Just Immigration. http://www.stateofblackimmigrants.com/. Carrascillo, Adrian. 2015. “Bernie Sanders Just Hired the Best Known Immigration Activist in the Country.” BuzzFeed News, October 30, 2015. https://www .buzzfeednews.com/article/adriancarrasquillo/bernie-sanders-just-hired-the-best -known-immigration-activis. Chavez, Leo. 2013. The Latino Threat: Constructing Immigrants, Citizens, and the Nation. Palo Alto, CA: Stanford University Press. Cunningham-Parmeter, Keith. 2011. “Alien Language: Immigration Metaphors and the Jurisprudence of Otherness.” Fordham Law Review 79: 1545–98. https://heinonline .org/HOL/P?h=hein.journals/inlr32&i=627. Davis, Julie Hirschfeld, and Julia Preston. 2016. “What Donald Trump’s Vow to Deport up to 3 Million Immigrants Would Mean.” New York Times, November 14, 2016. http:// www.nytimes.com/2016/11/15/us/politics/donald-trump-deport-immigrants.html?_r=0. Department of Homeland Security. 2017. “Rescission of Deferred Action for Childhood Arrivals (daca).” Department of Homeland Security, September 5, 2017. https:// www.dhs.gov/news/2017/09/05/rescission-deferred-action-childhood-arrivals-daca. Foley, Elise. 2016. “Trump Says, without Specifics, He’ll ‘Work Something Out’ for Dreamers.” Huffington Post Politics, December 7, 2016. http://www.huffingtonpost .com/entry/donald-trump-daca-dreamers_us_58481963e4b0d0df18372021. Hernández, Arelis R. 2015. “Martin O’Malley Is Targeting Latino Voters.” Washington Post, June 1, 2015. https://www.washingtonpost.com/news/post-politics/wp/2015/06 /01/martin-omalley-is-targeting-latino-voters/. Lakoff, George, and Mark Johnson. 1980. Metaphors We Live By. Chicago: University of Chicago Press. Makela, Finn. 2011. “Metaphors and Models in Legal Theory.” Les Cahiers de Droit 52(3–4): 397–415. https://doi.org/10.7202/1006668ar. 44 Joel Sati Manchester, Julia. 2018. “Warren: ‘Glad We Are Moving Forward on Getting a Clean dream Act.’” The Hill, January 10, 2018. http://thehill.com/homenews/senate /368261-warren-glad-we-are-moving-forward-on-getting-a-clean-dream-act. McCallister, Doreen. 2018. “Federal Judge Temporarily Blocks Trump’s Decision to End daca.” NPR, January 10, 2018. https://www.npr.org/sections/thetwo-way/2018 /01/10/576963434/federal-judge-temporarily-blocks-trumps-decision-to-end-daca. Murdock, Deroy. 2018. “Fence-Climbing Illegal Aliens Cut in Line as Legal Immigrants Wait in Obscurity.” National Review, May 4, 2018. https://www.nationalreview .com/2018/05/legal-immigrants-vs-illegal-immigrants-cutting-line/. National Immigration Law Center. 2017. “What is the dream Act.” National Immigration Law Center. https://www.nilc.org/wp-content/uploads/2017/10/Clean-Dream -Act-1pg-2017.pdf. Nopper, Tamara K. 2011. “The Wages of Non-Blackness: Contemporary Immigrant Rights and Discourses of Character, Productivity, and Value.” InTensions Journal 5: 1–25. http://www.yorku.ca/intent/issue5/articles/pdfs/tamaraknopperarticle.pdf. Preston, Julia. 2008. “An Interpreter Speaking Up for Migrants.” New York Times, July 11, 2008. http://www.nytimes.com/2008/07/ll/us/llimmig.html. Putnam, Hilary. 1973. “Meaning and Reference.” Journal of Philosophy 70(19): 699–711. Ryo, Emily. 2013. “Deciding to Cross: Norms and Economics of Unauthorized Migration.” American Sociological Review 78(4): 574–603. https://doi.org/10.1177 /0003122413487904. Santa Ana, Otto. 2002. Brown Tide Rising: Metaphors of Latinos in Contemporary American Public Discourse. Austin: University of Texas Press. Sati, Joel. 2017. “How daca Pits ‘Good Immigrants’ against Millions of Others.” Washington Post, September 7, 2017. https://www.washingtonpost.com/news /posteverything/wp/2017/09/07/how-daca-pits-good-immigrants-against-millions-of -others/?noredirect=on&utm_term=.785fbd34950e. Silva, Astrid. 2016. “Astrid Silva: I Stand with Hillary Because She Stands with Immigrant Families.” Univision Noticias, February 3, 2016. http://www.univision.com/noticias /opinion/astrid-silva-i-stand-with-hillary-because-she-stands-with-immigrant-families. Stumpf, Juliet. 2006. “The Crimmigration Crisis: Immigrants, Crime, and Sovereign Power.” American University Law Review 56(2): 367–420. https://heinonline.org /HOL/P?h=hein.journals/aulr56&i=379. Thibodeau, Paul H., and Lera Boroditsky. 2011. “Metaphors We Think With: The Role of Metaphor in Reasoning.” PLoS ONE 6(2): 1–11. https://doi.org/10.1371/journal .pone.0016782. Tyler, Tom. 2004. “Procedural Justice.” In The Blackwell Companion to Law and Society, edited by Austin Sarat, 435–52. London: Blackwell Publishing. United We Dream. 2017. “Passing a Clean dream Act Is the Top Political Priority of This Year.” United We Dream, October 5, 2017. https://unitedwedream.org/2017/10 /passing-a-clean-dream-act-is-the-top-political-priority-of-this-year/.