State of Washington et al v. United States of America et al

Filing 31

EXHIBIT Exhibits_34-66 re #15 MOTION to Expedite Discovery and Regular Staus Conferences by Plaintiff State of Washington (Clinton, Laura)

Exhibit 34

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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Case No. 2:18-cv-00939
STATE OF WASHINGTON, et al.,

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Plaintiffs,

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V.

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THE UNITED STATES OF AMERICA, et al.,

DECLARATION OF JENNIFER
PODKUL IN SUPPORT OF
COMPLAINT FOR
DECLARATORY AND
INJUNCTIVE RELIEF

Defendants.

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I, Jennifer Podkul, Esq., make the following declaration based on my personal knowledge, and
declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that the following is true and

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correct:
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1.

I am the director of policy at Kids in Need of Defense (KIND). KIND is a national non-

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profit organization with ten field offices providing free legal services to unaccompanied

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immigrant children who face removal proceedings in Immigration Court. Since 2009,

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KIND has received referrals for over 15,800 children from 70 countries, and has partnered

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with pro bono counsel at over 500 law firms, corporations, law schools, and bar
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associations. KIND also advocates for changes in law, policy,
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PODKUL DECLARATION
2: 18-CV-00939

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Kids in Need of Defense (KIND)
1300 L St, NW, Washington, D.C. 20005
[phone]

and practice to enhance protections for unaccompanied children. Since 2010, KIND has also run a
return and reintegration program for children who return to their country of origin.

2.

KIND has served children who arrived in the United States with parents from whom they
were separated by federal officials.

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3.

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During interviews with children, KIND staff seek to determine whether children entered
the country with parents from whom they were separated, and will inquire into the

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circumstances.
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4.

Several children have reported experiencing distress and confusion at being separated

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from parents. For example, a seven-year-old girl reported crying throughout two days

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spent in a Border Patrol holding facility, and asking to be reunited with her mother. Other

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children have reported worrying about their parents, because they did not know what

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happened to them after the separation.

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5.

Through our work representing the children in legal proceedings, as well as supporting

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those who return to the country of origin, it is evident to KIND that there is no consistent

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policy for ensuring communication among separated children and parents. Some

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children served by KIND were allowed to communicate with parents by telephone after

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separation. In other cases, children reported that the government did not allow any

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communication with a parent while the child was in detention, or that children did not

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know the whereabouts of their parents.

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6.

In order to provide adequate legal representation to children in removal proceedings, it is
important for the attorney to have a thorough understanding of the child's situation in the

PODKULDECLARATION
2: 18-CV-00939

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Kids in Need of Defense (KIND)
1300 L St, NW, Washington, D.C. 20005
[phone]

J....__ ___ ,

country of origin. Attorneys must ask difficult questions about abuse, abandonment,
neglect, violence, persecution, or other harms suffered by children and their families in
the country of origin. Children may qualify for humanitarian protection on several
grounds, and past harm to the child or to family members may support eligibility for legal
relief. A child may have limited memory and understanding of complex or violent
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situations, making it important for the attorney to speak with members of a child's family

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who may corroborate information, fill in gaps, and provide additional facts the child

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might not know or comprehend.
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7.

Children who were separated from their parents following DHS apprehension may not

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know where the parent is or how to contact them. Parents of KIND clients may be held

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in the custody oflmmigration and Customs Enforcement or the U.S. Marshall, or may

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even be back in the country of origin before the child begins working with an attorney.

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8.

Separation from parents makes it harder for the child to provide the evidence necessary to

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prove their defense from removal. Many times, the parent has important paperwork, such

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as notarized affidavits, birth certificates, or police records. Obtaining these documents

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from a parent who is detained or deported is difficult and resource-intensive.

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9.

KIND's Return and Reintegration Project has worked with several children who were
separated from their parents following apprehension, and sought voluntary departure

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from the Immigration Judge in order to reunite with a parent and return together to their
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country of origin. In several such cases, the government was unable to coordinate the
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return of the parent and child, and the children had to face the return journey alone.

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Several of these cases involved very young children.

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PODKUL DECLARATION
2:18-CV-00939

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Kids in Need of Defense (KIND)
1300 L St, NW, Washington, D.C. 20005
[phone]

10.

When a child is separated from a parent and rendered unaccompanied, the child's legal
case is generally severed from the parent's. Under the Trafficking Victims Protection
Reauthorization Act of 2008, unaccompanied alien children are entitled to be heard in
removal proceedings before an Immigration Judge. A separated child has his or her own
removal case, separate from the parent's matter, which may be expedited and may not be

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referred to the Immigration Court. Thus, the child's and parent's cases may proceed as
two separate matters, often in different tribunals and on very different schedules,

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although the family members may share in common underlying facts, claims for relief,
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and evidence.
I declare under penalty of perjury under the laws of the United States of America that the

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foregoing is true and correct to the best of my knowledge and belief.

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Executed in Washington, D.C., on June 30, 2018.

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10
Director of Policy

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Kids in Need of Defense
1300 L St, NW
Washington, D.C. 20005
Tel: [phone]
Fax: [phone]
[e-mail]

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PODKUL DECLARATION
2: 18-CV-00939

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Kids in Need of Defense (KIND)
1300 L St, NW, Washington, D.C. 20005
[phone]

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PODKUL DECLARATION
2:18-CV-00939

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Kids in Need of Defense (K_
IND) DC 20005
1300 L St, NW, Washmgt&62) .824-8692

Exhibit 35

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHING TON

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STATE OF WASHINGTON, et al. ,

NO. 2:18-cv-00939

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Plaintiffs,
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v.

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DECLARATION OF CHARLES
ALBERT DUTCH
RUPPERSBERGER III IN SUPPORT
OF PLAINTIFF STATES

THE UNITED STATES OF
AMERICA, et al.,
Defendants.

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I, Charles Albert Dutch Ruppersberger III , declare as follows:
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1. I am over the age of 18 and have personal knowledge of all the facts stated herein.
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2. On June 19, 2018, I visited the Ordinance Road Detention Center in Glen Burnie,
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Maryland, which contracts with U.S. Immigratio~ and Customs Enforcement to hold detained
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immigrants, most of whom are awaiting court proceedings or deportation. I made the visit with
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Rep. Donald Beyer, a colleague of mine in the House of Representatives . Our visit was reported
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by the Washington Post and other news outlets.

See , e.g., Patricia Sullivan, Md., Va.

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congressmen hear stories of family separation, Wash. Post, June 21, 2018, at B4, available at

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https://www.washingtonpost.com/local/immigration/md-va-congressmen-hear-stories-of23
family-separation/2018/06/20/af3fe0ae-74aa-11e8-b4b7-308400242c2e_story.html?noredirect
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=on&utm term=.fa6d5bb19919.
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DECLARATION OF CHARLES ALBERT
DUTCH RUPPERSBERGER III IN
SUPPORT OF PLAINTIFF STATES

ATTORNEY GENERAL OF MARYLAND
200 Saint Paul Place
Bal ti more, Mary land 21202
410-576-6300

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3. During our visit, I met two men who had had their children taken from them by federal

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immigration officials under the Trump Administration's family separation policy. Both had to

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wait for weeks to hear from their children again.

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4. One man-whom the Washington Post referred to as Carlos-fled Honduras after gang

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violence in that country threatened his life and that of his 7-year-old son. Carlos fled with his

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son by train and was arrested by federal officers on March 10, 2018, when they crossed the U.S.

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border into El Paso, Texas. Carlos told me that he sought asylum and yet was held in leg irons

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for several days, with his son by his side. Then his son was removed. Three months passed

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before Carlos was able to speak to his son again. At that time, his son was being housed in a

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care facility located in Michigan.

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5. Carlos had the foresight to make his son memorize a relative's phone number before they

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left Honduras. As a result, his son was able to contact the relative, who connected him to another

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family member in the United States. Carlos still did not know when he would be able to see his

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son agam.

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6. The second man-whom the Washington Post referred to as Mario-also fled Honduras,

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by bus, accompanied by his sister and his 5-year-old daughter. Mario told me that his sister was

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a victim of domestic violence committed by a police officer in Honduras. When the family

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attempted to press charges, a gang beat Mario up.

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7. Mario, his daughter, and his sister surrendered to U.S. Customs and Border Patrol on

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April 20. Mario told me that he and his sister had both sought asylum. According to Mario, his

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sister was ultimately granted asylum, but he and his daughter were placed in an ICE holding

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facility. Conditions in the facility were difficult; the room in which they were kept was frigid

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and little more than a prison cell. After three days, Mario told us, an officer approached him and

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told him to give up his daughter or she would be taken away. Mario told us that his 5-year-old

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girl was dragged away from him crying and screaming, which was the last he saw her. Mario

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DECLARATION OF CHARLES ALBERT
DUTCH RUPPERSBERGER III IN
SUPPORT OF PLAINTIFF ST ATES

2

ATTORNEY GENERAL OF MARYLAND
200 Saint Paul Place
Baltimore, Maryland 21202
410-576-6300

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told us that he finally heard from his daughter in mid-June but he still did not know where she

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was being held.

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8. Mario and Carlos both told us that they were seeking asylum in the United States and

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that they had entered the country through legitimate points of entry. Neither knew where in the

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asylum process their cases stood.

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9. Both men visibly struggled to maintain their composure while recounting the trauma that

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they experienced since coming to the United States and ultimately broke down into tears. Our

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interpreter too broke down into tears, finding their stories too painful to bear.

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l 0. Carlos and Mario told us that a third man who had been separated from his children under

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the Trump Administration's policy was also being held in the facility but we were not able to

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speak with him during my visit. In response to our questions, ICE officials indicated that they

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did not know how many parents they were holding who had been separated from their children

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under the Administration's policy.

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11. I have asked ICE officials whether detainees or children were being held in Maryland.

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ICE officials have confirmed that parents and children separated from one another pursuant to

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the Trump Administration's family separation policy are being kept in child care and detention

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centers in Maryland.

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I declare under penally of perjury that the foregoing is true and correct.

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Executed on this ~

day of June 2018 at Washington, D.C.

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upper
rger III
U.S. Representative for Maryland's 2nd
Congressional District

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DECLARATION OF CHARLES ALBERT
DUTCH RUPPERSBERGER Ill IN
SUPPORT OF PLAINTIFF STATES

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ATTORNEY GENERAL OF MARYLAND
200 Saint Paul Place
Baltimore, Maryland 21202
410-576-6300

Exhibit 36

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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NO. 2:18-CV-00939

STATE OF WASHINGTON, et al.
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DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

Plaintiff,
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V.

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THE UNITED STATES OF AMERICA,
et al.,

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Defendants.

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I, Francisco Serrano, declare as follows:
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1.

I am over the age of 18 and have personal knowledge of the facts herein. If called

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as a witness, I could and would testify competently to the matters set forth below.
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2.

1 reside in the District of Columbia. I live with my wife, my mother, and my two

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children who are fifteen- and seventeen-years-old.
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3.

In May 2018, my niece Maria called me to tell me that she had traveled from El

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Salvador with a caravan, that she was at the Mexico-United States border and that she was going
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to cross the border by San Ysidro. She also told me that she was traveling with her two children,
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M. who is 7 years old and N. who is 2 years old.
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4.

Approximately a week later I received a call from a shelter indicating that the

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children were going to be separated from Maria, that they were on their way to New York, that
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Maria had designated me as a sponsor and asking me whether I was willing to be the sponsor. I
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DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

I

OFFICE. OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
13001 Street
Sacramento, CA 9581.1
916-445-955.5

I

told the person that I would be the sponsor and then the person told me that I would be able to

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talk to the children twice a week. Attached hereto as Exhibits 1 and 2 are the forms I was told

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to complete in early May 2018 so that I could receive Maria's two sons.

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5.

I have spoken with the seven-year-old on several occasions since the family

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arrived. He told me that officials told him that he and his baby brother were being taken to a

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detention center in Washington, D.C. to be closer to me, their uncle. I received a phone call from

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the seven-year-old who thought he was in Washington, D.C., but he was not. He was in New

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York. I was told by a social worker that the two young boys are in Lutheran Youth Hostel of

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New York.

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6.

To become the sponsor the social worker told me that I had to provide: 1) Maria's

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mother's birth certificate, 2) Maria's birth certificate, 3) the kids' birth certificates, and 4) my

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birth certificate, driver's license, passport and proof of citizenship. In addition to completing the

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paperwork, I had to provide copies of my identification and police record. I did not have copies

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of Maria's mother's, Maria's or the kids' birth certificates so I had to ask persons in El Salvador

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to send them to me. This process took 5 days because a friend was in El Salvador and was able

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to help me, otherwise the process would have taken 15 to 20 days.

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7.

The social worker who was working with the kids told me that once I submitted

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the documents she would get approval within 36 hours and the children would be released within

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24 hours after that. I did not hear from them within 36 hours, but I assumed that everything was

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valid because I had completed all of the forms and followed all of the instructions.

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8.

Approximately one week after I provided the paperwork I was told that I had to

be fingerprinted. The next day I took time off work and got fingerprinted.
9.

After I submitted all the requested documents the social worker told me that she

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was very sorry but that she had only been able to get one of the approvals she needed to approve

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the paperwork. She said that she did everything she could but it was out of her hands.

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DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

2

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFOIZNIA
13001 Street
Sacramento, CA 95814
916-445-9555

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10.

In late May 2018, I received a power of attorney from my niece Maria giving me

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the authorization to care for her two minor sons. A copy of the notarized power of attorney is

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attached hereto as Exhibit 3. I provided a copy of this power of attorney to the social worker in

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early June 2018.

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11.

About a week later I was asked to complete a certified form for a further

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background check. On June 1, 2018, I completed the additional form that Lutheran Social

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Services had provided to me to get authorization to receive Maria's two sons. I had to have the

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form notarized. A copy of that form is attached hereto as Exhibit 4.

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12.

Then I was informed that I passed the background check but they needed one

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more week to release the kids to me. The seven-year-old boy called me and told me that

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officials had told him that he and his brother would be released to me in a week.

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13.

But then, I was told that they needed to perform a DNA test to confirm that

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Maria is the children's mom. Recently, the social worker told me that a few days ago a

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government employee went to Otay Mesa where Maria was detained to conduct the DNA test

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but that Maria was not there. Later, when I spoke to Maria she said that she had been at Otay

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Mesa the entire time.

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14.

Several weeks after I submitted all of the paperwork, on June 22, 2018, I was

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told that the paperwork I submitted was wrong, the power of attorney was not valid, and the

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boys would not be released to me. The social worker said that we will have to start the

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sponsorship process again because the rules changed. She said that there were new forms we

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had to complete, but she did not send me the forms until Friday, June 29, 2018. Those forms

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are attached hereto as Exhibits 5 and 6.

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15.

On June 27 after borrowing money from family members, I was able to gather

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$10,000 to post Maria's bond. An immigration agent told me that Maria would come out on

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June 28, 2018 and that she would be taken to the bus station so she could take the bus to

26 1 Washington, D.C. So Maria's bus ticket was for June 28. But immigration released her on
DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

3

OFFICE OF THE ATTORNEY GENER.AI.
STATE, OF CALIFORNIA
1300I Street
Sacramento, CA 95814
916-445-9555

I

June 27 and Maria called me because the agents left her in a McDonald's and she did not have

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any place to go or to sleep. She had to look for someone to take her in for one night and now

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she in on the way to Washington, D.C.

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16.

On June 28, 2018, I talked to the social worker who told me that we will have to

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start the sponsorship process again and that Maria will have to fill the application and request

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the children because she already was released from immigration detention.

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17.

I am concerned that now the process for Maria's children to be reunited with my

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family will have to start all over again. Everyone in my home, including my 78-year-old

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mother, will have to submit fingerprints, police records, and identification, and we will have to

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complete a new application form. Because of my mother's age, it is difficult to get her

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fingerprints, and immigration officials previously told her that she would not have to submit

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fingerprints again. I was told that my niece Maria will also have to be fingerprinted and will

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have to submit all the documentation, as well. I am concerned that Maria will not be able to

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produce the right paperwork to be reunited with her sons. Maria does not have a passport, and

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all she has is an ID card from El Salvador.

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18.

All this process has been very difficult for my family:
a.

At first when I would talk to M., the 7-year-old, he was very talkative and

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excited because the social worker told him he would be out within a week. When the time came

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that M. expected to be released and nothing happened he sounded depressed, he would not say

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much and wanted to cry. M. asked me why I had not picked him up yet. The social worker told

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me that M. is depressed and asked me for words of encouragement to cheer him up. Yesterday,

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June 28, 1 spoke with him and he is glad because he thinks that soon he is going to be reunited

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with his mother. I am worried about M.'s mental health when he learns that we have to start the

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process again and that he is not going to be released soon.

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b.

Because I am only able to speak on the phone and N. is too young, I have

26 1 not been able to speak with him at all. M. told me that N. cries all the time, and that the only
DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

4

OFFICE OF THE XFTORNEV GENERAL
STATE of CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

1

time that the kids see each other is at night. M. told me that they let N. stay with him at night

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because he is the only one with whom N. won't cry.

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C.

When I speak with Maria she asks for an update about the children and is

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speechless when I tell her that I am still waiting for approval. She cries. She has only been able

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to speak with the kids a few times.

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d.

The most affected person by all this is my mother. She raised Maria after

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her mother died when Maria was 8 months old. At first, I did not want to tell my mom what was

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happening because she is 78 years old and I was concerned that the news would adversely impact

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her health. I only told her that Maria and the kids had crossed the border but were detained.

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After watching news, my mom demanded I tell her what was happening. My mom became ill

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when I told her that the kids had been separated from Maria. Ever since my morn found out

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about the family separation, she has had an intense headache and I had to take her to see a doctor.

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I am really concerned about my mom's health. For Maria, the separation from her kids repeats

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the story as when she lost her mother.

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e.

On my part, this process has been very depressive and frustrating. When

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I finally thought that they were going to give me the children they tell me no. I have also had to

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take time off work to do all that has been asked of me.

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19.

1 am hopeful that Maria, M. and N. will be reunited soon.

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I declare under penalty of perjury under the laws of the State of California and the laws
of the United States that the foregoing is true and correct.
Dated this 30th day of June 2018 in Washington D.C.

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[Signature]
FRANCISCO SERRANO

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DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

5

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
13001 Street
Sacramento, CA 95814
916-445-9555

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DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

6

OFFICE OF THE ATTORNEY GENERAI.
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON, et al.,

NO. 2:18-CV-00939

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Plaintiff,

DECLARACI6N DE FRANCISCO
SERRANO EN APOYO A PETICI6N
DE LOS DEMANDANTES PARA
EXHIBICI6N DE PRUEBAS
ACELERADA

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V.

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THE UNITED STATES OF AMERICA, et
al.,

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Defendants.

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Yo, Francisco Serrano, declaro to siguiente:
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1.

Tengo mas de 18 anos de edad y tengo conocimiento personal de los hechos en

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este documento. Si se me llamara como testigo, podria y testificaria de manera competente a las
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cuestiones que se exponen a continuacion.
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2.

Yo resido en el Distrito de Columbia. Vivo con mi esposa, mi mama, y mis dos

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hijos que tienen quince y diecisiete anos de edad.
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3.

En mayo de 2018, mi sobrina Maria me llam6 para decirme que habia viajado

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desde El Salvador con una caravana, que estaba en la frontera de Mexico y los Estados Unidos,
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y que iba a cruzar la frontera por San Ysidro. Tambi6n me dijo que estaba viajando con sus dos
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ninos, M. de 7 anos de edad y N. de 2 anos de edad.
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4.

Aproximadamente una semana despues recibi una llamada de un albergue

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diciendome que los ninos iban a ser separados de Maria, que iban rumbo a Nueva York, que
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DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

1

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
I Street
Sacrammen to, CA 95814
en
916-445-9555

I

Maria me habia designado como patrocinador y preguntandome que si yo estaba dispuesto a

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ser el patrocinador. Yo le dije a la persona que serfa el patrocinador y la persona me dijo que

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yo podria hablar con los ninos dos veces por semana. Adjunto los Documentos 1 y 2 son los

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formularios que me dijeron que completara a principios de mayo para que pudiera recibir a los

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ninos de Maria.

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5.

Yo he hablado con el nino de 7 anos en varias ocasiones desde que la familia

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1leg6. El me dijo que oficiales le dijeron que a el y a su hermanito los iban a llevar a un centro

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de detenci6n en Washington, D.C. para estar mas cerca de mf, sus tfo. Recibf una llamada del

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nino de siete anos quien pensaba que estaba en Washington, D.C., pero no era asf. El estaba en

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Nueva York. Una trabajadora social me dijo que los dos ninos estan Lutheran Youth Hostel en

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Nueva York.

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6.

Para ser el patrocinador la trabajadora social me dijo que tenfa que proveer: 1) el

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acta de nacimiento de la mama de Maria, 2) el acta de nacimiento de Maria, 3) las actas de

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nacimiento de los ninos, y 4) mi acta de nacimiento, licencia de conducir, pasaporte y pruebas

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de ciudadanfa. Ademas de completar el papeleo, tuve que proporcionar copias de mi

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identificaci6n y registro policial. Yo no tenfa copias de las actas de nacimiento de la mama de

17

Maria, de Maria o de los ninos asi es que tuve que contactar a personas en El Salvador para que

18

me las enviaran. Este proceso tomo 5 dfas porque un amigo estaba en El Salvador y me pudo

19

ayudar, si no, el proceso hubiera durado de 15 a 20 dias.

20

7.

La trabajadora social que estaba trabajando con los ninos me dijo que cuando yo

21

entregara los documentos ella obtendrfa aprobaci6n en 36 horas y los ninos saldrfan 24 horas

22

despues de eso. No escuche de ellos en las pr6ximas 36 horas, pero asumf que todo era valido

23

porque ya habia completado todos los formularios y seguido todas las instrucciones.

24

8.

Aproximadamente una semana despues que proporcione el papeleo me dijeron

25

que me tenfan que tomar la huellas. El dfa siguiente pedf tiempo en mi trabajo y me tomaron las

26

huellas.
DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

2

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95314
916-445-9555

1

9.

Despues de que entregu6 los documentos que me pidieron la trabajadora social

2

me dijo que to sentia mucho pero que solo habia obtenido una de las aprobaciones que necesitaba

3

para aprobar el papeleo. Ella dijo que hizo todo to posible pero que estaba fuera de sus manos.

4

10.

A finales de mayo, recibi un poder legal de mi sobrina Maria ddndome la

5

autorizaci6n para cuidar de sus dos ninos menores. Una copia del poder legal notariado esta

6

adjunta como Documento 3. Yo proporcion6 el poder legal a la trabajadora social a principios

7

de junio.

8

11.

Aproximadamente una semana despues me pidieron que completara una forma

9

certificada para una verificaci6n de antecedentes adicional. El primero de junio de 2018, yo

10

complete el formulario que me proporciono Lutheran Social Services para obtener la

11

autorizaci6n de recibir a los dos hijos de Maria. Tuve que certificar el formulario por notario.

12

Una copia del formulario esta adjunto como Documento 4.

13

12.

Luego me informaron que pas6 la verificaci6n de antecedentes, pero necesitaban

14

una semana Inds para entregarme a los ninos. Hable con el nino de siete anos y me dijo que los

15

oficiales le dijeron que a el y su hermano me los iban a entregar en una semana.

16

13.

Pero luego me dijeron que necesitaban hacer una prueba de ADN para confirmar

17

que Maria es la mamd de los ninos. Recientemente, la trabajadora social me dijo que hace unos

18

dias un empleado del gobierno fue a Otay Mesa donde Maria estaba detenida para tomarle la

19

prueba de ADN pero Maria no estaba ahi. Despues, cuando habl6 con Maria ella dijo que habia

20

estado en Otay Mesa todo el tiempo.

21

14.

El 22 de junio, varias semanas despues que entregue todo el papeleo me dijeron

22

que el papeleo que entregue estaba equivocado, que el poder legal no era vdlido, y que no me

23

iban a entregar a los ninos. Ella dijo que hay formularios nuevos que tenemos que completar,

24

pero no me envi6 los formularios hasta el viernes, 29 de junio de 2018. Esos formularios estdn

25

adjuntos como Documentos 5 y6.

26
DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

3

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
I Street
Sacramento, CA 95814
men
916-445-9555

1

15.

El 27 de junio despuds de pedir dinero prestado a miembros de mi familia, pude

2

recolectar $10,000 y pagud la fianza de Maria Un agente de inmigraci6n me dijo que Maria

3

saldria el 28 de junio de 2018 y que la llevarian a estaci6n de autobus para que ella pudiera tomar

4

el autobus a Washington D.C. Asf es que el boleto de autobus de Maria estaba para la fecha del

5

28 de junio. Pero inmigraci6n liber6 a Maria el 27 de junio y Maria me llam6 porque los agentes

6

la dejaron en un McDonald's y ella no tenia a donde it ni dormir. Ella tuvo que buscar a alguien

7

que la alojara una noche y ahora esta en camino hacia Washington D.C.

8
9
10
11

16.

El 28 de junio de 2018, habld con la trabajadora social quien me dijo que

tendremos que empezar el proceso de y que Maria tendra que llenar la aplicaci6n y pedir a los
ninos porque ya sali6 de detenci6n de inmigraci6n.
17.

Estoy preocupado que ahora tendremos que empezar de nuevo el proceso para

12

reunir a los ninos de Maria con mi familia. Todos en mi casa, incluyendo mi mama de 78 anos

13

de edad, tendran que someter huellas, registro policial, e identificaci6n, y tendremos que

14

completar un nuevo formulario. Debido a la edad de mi mama, es dificil tomarle las huellas, y

15

oficiales de inmigraci6n me dijeron anteriormente que ella no tendria que someterse a las huellas

16

de nuevo. Tambidn me informaron que Maria tendra que tomarse las huellas y tendra que

17

presentar toda la documentaci6n. Estoy preocupado de que Maria no pueda producir el papeleo

18

necesano para poder reunirse con sus dos hijos. Maria no tiene pasaporte, y todo to que tiene es

19

to tarjeta de identificaci6n de El Salvador.

20
21

18.

Todo este proceso ha sido muy dificil para mi familia:
a.

Al principio cuando hablaba con M., el nitro de 7 anos, dl estaba muy

22

platicador y estaba emocionado porque la trabajadora social le dijo que saldria en una semana

23

Cuando el tiempo cuando M. esperaba salir lleg6 y nada pas6, dl se escuchaba depresivo, nc

24

decfa mucho y querfa Horan Me pregunt6 por qud no he venido por dl todavia. La trabajadon

25

social me dijo que M. estaba depresivo y me pidi6 palabras para animarlo. El 28 de junio habl(

26 1 con dl y esta contento porque piensa que pronto va a reunirse con su mama. Estoy mas
DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

4

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

I

preocupado por la salud mental de M. cuando se entere que tendremos que empezar el proceso

2

de nuevo y que no va a salir pronto.

3

b.

Porque solo puedo hablar por tel6fono y N. es muy pequeno no he podido

4

hablar con el. M. me dijo que N. llora todo el tiempo, y el 6nico momento en que los dos ninos

5

se ven es en la noche. M. dijo que dejan que N. se quede con M. por la noche porque es to unico

6

que hard que N. deje de llorar

7

C.

Cuando hablo con Maria ella me pregunta que esta pasando con los ninos

8

y se queda sin palabras cuando le digo que todavia estoy esperando la aprobaci6n. Ella Mora.

9

Ella solamente ha podido hablar con los ninos pocas veces.

10

d.

La mds afectada por todo esto es mi mamd. Ella crio a Maria despu6s que

11

su mamd muri6 cuando Maria tenia 8 meses de edad. Al principio, yo no querfa decirle a mi

12

mamd to que estaba pasando porque ella tiene 78 anos de edad y estaba preocupado que si le

13

decfa se iba a poner mal de salud. Yo solo le dije que Maria y los ninos habian cruzado la

14

frontera, pero estaban detenidos. Despues de ver las noticias, mi mama exigi6 que le dijera que

15

estaba pasando. Mi mama se puso anal de salud cuando le dije que los ninos habian sido

16

separados de Maria. Desde que mi mama se enter6 de la separaci6n familiar ha tenido un dolor

17

de cabeza intenso y yo tuve que llevarla al doctor. Estoy muy preocupado por la salud de mi

18

mamd. Para Maria, la separaci6n de sus ninos repite la historia de cuando ella perdi6 a su mama.

19

e.

Por mi parte, este proceso ha sido muy depresivo y fiustrante. Cuando al

20

fin pensaba que me iban a dar los ninos me dicen que siempre no. Tambi6n he tenido que

21

descansar de mi trabajo para hacer todo to que me han pedido que haga.

22
23
24
25
26
DECLARATION OF FRANCISCO
SERRANO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

5

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
13001 Street
Sacramento, CA 95314
916-445-9555

1,9.

`Cengo is u-spermi/a qu(: Mmi 1" M,, y NV v wiilitifttt

De.clato ha. jo

itrio
pe""a t ic pe-d

im,"tr?

p
I)(,jt) jat. icyt`,"i dq.l I;s,1 dt de C` aliliyrma y I:t,% 11-Y"', fir 10

Flstu(lus LInicluq quc Io un(vrior u-s vertlad ; o y vorruclo .

Fechadtt e41c all (IF) (1( fimiO tic 7019 en Wa slrit,lfol, 1).c'.
.

f

Fl(UNCiSC() ` 1';1'1<./1W)

27
23
24

0

UI!('I_ARATIUNOf; FRAN('ISI:O
I

SFRRANO IN SUPPO RT of
I'LAIN'rivvs'MOTION 1'()►?
F?(P(?t1111!() hlSr:()VrR Y

r►

01, F111"ot ,rn A.,1";I,r, r• r,r .,1; ,~
1
SIA TV r,t r AI ll r,P:;iA
'tom"lit Wr"h")"!X14

EXHIBIT 1

00kit alrRditm~t
5goassr Camba wmmd, ger. OV3000

G& I3wr.mc.rnmftmda~saTm=9

Nombre dd meet:
AUms (si Im tnvicaa):

Notttbre dd wtracin

OFICINA DE REMCAC16N DE RM?UGLM)OS
Divisi6n de Servkks de Niiios
!iCUERDO DE CUMADO DEL PATROCINADOF
Duero deI menor A:
Fecha de narimienio del
Fecha: (D § h © 11.9
-

Lm solicW ala Ofidw do Reubicaid6a de Ref tgiados (Of ice of Refagee Rcsctflcmcnt, ORR) paixocinw a on rttiio
extraMem no axmVafmdo en el cuidado y In custodies del gobiemo federal conforme al acuerdo extrajndicisl
esdpolado blares v. Rena.mimero 85-4544-RJK (Px) (C.D.Cal, 17 de meta de 1997), seccidn 462 del Hot ound
Scomityr Act de 20M y la seeci6n 235 del William Wilberforce Trafficking Ytcdma Protection Rcaudw izaden Act de
2QD8.Si sc opmebaIa mAkitad de patracini% redW un fatmulario de VeWcaddn de liberacidn de ORRy se
cep un acuepdo do custodxa con el gobicnta federal en cl curl ampta cumplir con las sigguicnbts disposidones
mi=A s e1 menur esM en sa coidado:
•

Preparcionar el bicw=n ental y Him del menor, qne induyc~ entm otrcns, alinientos, refugio, vim,
educad6n, a nci6n mica y ofias servicios segdin sea necesario.

•

Si no as eI tabor IqA ni el padre o la main:dd nano[, hap Los mejom esfaam pot estabkc r tats cnstodia
Ieg d cam el nibmmd hmml demo de un tiempo razonahle.
Asistir a un programs de oriented& legal proporcionado por el Departnmento de IuWcia (DepmUnmt of
1ue, DOI), o p mgmma de or=tacidm legal pars custodios (pattmmWom) dc la Oflcm Ejocubva pma la
Rovim6n dr, la Inmwam6n
Office for Immigration Review, EOIR), st ests djWunible en el lagar

donde reside_
•

Sagtm d6nde estd pendieutc el caso de inmigrad6n del menor, notific ar al. Tribunal de Iin:ig=dn o al
-dimo
Tn-bunal de Apelamontws de Inmigraci6nlocal. en un permdo de ch= (5) dies de bxto cambio de Ii
ndamexo de UdUbno del mmm t
el forma ado tie tamWo do dkeCxidn de eatrrmjerus (fotmtolario
EOI8.33). Ades, si es necesado, pnesentar mesa petieiuu de Rio cle competenda kniturial a uvmb is del
u=nr IA p dwi6n de mnbm de c+ompacrima temtonA debe coutmer ndoamaeidn esp=Txada pot el
TrIand de 7nmigrad6u.Tenga en cuents. qua In petict6n de cambio de campeteacia tmntorial paeds tegr+e
la ayuda die un abogado. Para obw= asmaramima sabre la " gencidn de cambio de c ampetsncia berfitorisF",
consulte el bdauoal de grh:dm dd Tribumal de Inmigraci6m cu hUp:/l LuNn.-,ovle0Fl9zL. Pam obw=
imfa mci6n sabre cases do arc, o m =iqusse con el simma do infc►rmacidua de casos de bmAgraci6n
de UOM Ilamando al 1-800-89&-7184 Visitt el sitio web de EOIR pm obteuer infbnnm i6n adid octal en_

htto:litv»tiv_ jvsticc.not/coirlFormsiist.htm_
Notifimr al DepmtmnWo de SegundW del Tanneries WadmA (DcpmtrAmt of Homchnd S=unty, DHS) o
a Servimm die CSadadania a Inmigcaaida de los Estadas Unidos (U.S: CitizemhT 2md Ikon Sermes)
en un perfodo de dies (I0) dbs de Uxio camhio de dh=ddn. presentanft la Tmjeta do Cambia do Dhe cido
de Exuanicza, (AR-1l) * de wawa dechAdm an h :!!l. sa.Qov IA 5~b1P.
Asegur )a paescum del mearsen Codas Im procodimmatos futmos ants DHS o Iamigracidn y Segmialad. de
Ad=ms am mgrAuon and Cuss nzs Enforcement, ICE) y el Depart memo de lusux (Dcpaotment of Justice.,
de
DOI) o EOIRI Para obit mr mfiamadde sabre c asas de a mipv66u, connWitquese con el
infonmaci6n de casm de FOIR Hamando aL I-800-898 718[1.
Asegmu que el memt se prewWe sate ICE para la eapulai6n de Im Estados Unique at un. do
t=
iiatnigracibn cu&c mu ordw do expuW6n o utta antra do Salida vohmtaua. Se asigm aI nznm on aficW de
deparmcidn pwa Im Fromm de expdd6n_

Spumm Cam Apem mt,Rw. WA =12
^nu wulwnn a..

UA Dgmt mts;t utBmM dl H~Sssvea

Q1Ree G[BAfbww

Rmft Endmomm Appaclam, Rev. MWM6

13. mod► tie las oempauft do six boor st&+e de
fug' !(w ftvw eq*qado'

1
V0

live y ewtm*m (IL ej-, Tl , SIDA, bqpa*k)? Si

"a). ZUsted o algsao de los ocapantes de sa hoer ham sWo acnsadas o condenadus par un delito (que no sea una
iuliaod6u nmor de Uindfi ,p. ej, vdaddad exa%im,
multa par mgt
)?
E NO u St
14(b). gUsted o aggna persona en sn hogar han Wo lnveSUPdas par abuw ftsicoy, seamA descoido o abandon de un
menor?
0 N [I S!
Si osted respaud6 "A" a dwdqaiexa de In pregumtas 14 (a) o 14(b), sh vase adjuntar nun Nsix a este formulario con in
siguiente bifunnaci6n para cubs cargo/rnndena:
(1) Membre del* pM'MM mvohKrada; Cl) Iugar y foaa del incidents; (3) desaipe" dd
;
(4) Resdud6m sob m d mod= (p. ej., deseatunad6n. tie
multado, encarc&do,per£ado de, praeba); (S7 Irapba
del(de los) regtstro( jokes r+eglstro(s) poUcW(es), ylo regish*s) de la agenda de servicio social gubernamndal
s)
),
15. Si exisdese In pusONT" que usted deba sally de los F.statlos Unidns, a sex inmpaa de tnidar al m mor, ggmen
supervi umda A meaec m sa
?:
Nom6az dei pm0k cmkh dor add: ,M tk.-f
1a k Ye fay u~-zFerha de nadud+entu del posdk culdadar adntto610
Welrmaci6u de contudo (dQrocci6a y of mero de. auo)
p
posUfle
r
Relsei6n tym el umn r, si hay 2ftema: +t c( Po h-4- c q iei sol ile;. NtQ'cc A I ~ i o
Reswmac so plea de Flo en ptwo de que usted tenp que ashy de las Es#adns Uju us o incapuz de c ur al menor:

dttfc?r0

poll Cct (

`j t ii

q..~tQ:~ QC*q ~".T.c

Declaro y allm no bad ja pens de perj que In Wermacs6n curb mMa en esta solicited es verdaders y precisa, segom
mio
Doy fe de que iadas Im docamentm que preseoft a lass copies de did m decumenbos esmn
mi led saber y adender.

Illrr>es de eri y de Frauds.

Doy fe ads que me atendri a las inshucrioaes emteeMas en d Acuerda del Pabvefiwdor sabre d Cnid mdo. Velars
per el bi
ienestar Miao y mentatl del moor_ Tamb in camptit6 con las leyes de mi estado respe do dd cukbAo de este
menor, le qv ii iaicl W Im bwu#wi6n del mtwr en In escuela, la provisi6a de ate neian midka cuando =a neemaria, La
proteccMn dd menor Matra ei abos% diescWdo y abandon, y cualquier otro requisite no tonteuido en el piesente.

F= ft RumWmfimApp tfeo.~v OI/~V1e16

C
•
USA'

offlee Of RdbaeE Resemement
Fgnnly Reaml7catim Applkition, Rev. Olt3W16

Uri. ; nmtnedofHsakband71maaSa-%* s

OFICINA DE REUBICACION DE REFUGIADOS
Divisiba de searvidos pare niiios
SOLI mm DE REUNIF'ICACYON FAMILIAR
1. Nombre del '"mar:

Al

AM A

11

sombre (de usted):
lmjtc<!~co de.sysuts SO Tan o
S. Su pais de origen (de asted)
1
-0
: L 1 5Q
7. Ndmere(s) de tWreno donde nos podemos eonaunkar
can riled:
9. El domk io don& re*HrAu usted y el menor:
c / lr i~ yt r.

3.

Z.Su relad6ra eon el menor:

-ri 0

4. Cualgaier otro nombre qae usted hays udHzado:
6. Su fecha de nadmiento (de usted)i

nk

h-'k
a fag:

10. jQu6 idlomas habla?:

e5 N i ► a {

j iW

u LA oC o

les

i
11.3nfornwd6p de Ions ocupates del huger. (Si necesita mss espado, sirvam adj mtar una iista de lee ocupanUs del haygar
a este formula6o)
Fecha de
Nacimiento

Nutbre

moflQL9°

Relact6n con el menor
(p. ej., madre, padre)

Relacion con usted
(Cl pabw.*Wdor)

C?s~'Qscz

~$o

Fez

rCo

©{

hC

12. Informad6u Dnamciera: Sh-vam expl7car e6mo va a mantenez finana eramnte al menor:

- f ,a.~~-~ %'

5,qlUw

(c

r t/~ j4 Jq Co W 0

tiit- ca

E,3 Ctx Q-tq

1M Q'', L J;1,'vt

!lieu.07!.25/20115
Fmdt~, gv=Mmda ApOkaliau,
ORR 1 CNBP-39

G.dS

5

'USA'

17,9. Aepartinad at

tired M
E

~L t~

SerTim

~IG~ltlt

Fly Ramocatlea (7tec t thr OPSWUM AM OUNIMM4

OFICINA DE BMICACIUN DE REFUGIADO,S
Divimft de Servidos pare Niiias
LISTA DE VEREFAC16N FAAE LIAR PARR PATRCCWAQRES
Ferromlatias mm deberim seer ce mdltllos.firnumim v
dcvudAm a sn tUdgladig secfad

iDoder

y fi
a He combIWbrmacido is AntorexacWupara is
Divtilgacifio de

® He lefdo la Catta introdnc=a del Pagneoe paa la
Reunificacidn Fan iliar

0 He comACado y fimmdo la SoUcitud pans la mmffwacidu
familiar

M He leido el Aamdo de Cuidado del Famciva~

Formula rips gm deberin mr WEI= v mantmWas en so

IRHe lefdo La Bata de Veri$cacibn para. Patxocinadares
N He lefdo el Prragtama General. de Odenacidn Legal pars
Custodies
He Iddo el Manual Para el Pabuchmdor
He ldfdo lit Iastcucciones pare la tome de hoe3las digitales
par si Henan qur scr souiefila&
W Carts de D
esigrt d6n del Cuidado de xm Menor pam el
pattacinador que NO to uno de km padres del memw ni sa tutar

legal_

Por favorprnpoceione una eopia de los sigdcntes docnmentsWs quo f guran a contintraciGa. Po3r favor tome en cumta que tanto la
Oficma de Redncam6n the Refugiados (C)M= of Refugee ltesetilest=ORR) cuum In Dmudu tle Servicios de Tyrone no
e
Aca paaa"{lmn ofOrrl& eWs ServicM DCS) puedert xt dul w su wheitud comp pat wma A falta cusiquier elemmlo de
dur
b infonnacsbn solidtada o si esa Tui—. estd hwompleta o no es ca=ta- En cl caso de que no pueds prov= los doctmnentos
regoeddos,
una expUad6n, juito am la &hcaud & lemmficamft Faniffiar, ca la que m&que qae tipo de dommentm6n de
r+espaldo na l
ply lg rA2J6u Tenga ea manta qta su rxphcacidn sobw etAatquier docuwmt «itin hftmte goeduA snjeta a la
L

Fltaega drsmid~ddark
Una cupademmit3cr
d6a cmitide par dgobkxmp.talcomo:
a. Lima de taoadesa a bu*U de limolka d6n emitida par d satado
h. Dacmmta de i&mfi&d (cnufinm) da su pats de adgm (p• rj, Tula)
C, Pesnpntte

•

Una copia de se cmtfm*do de aaindmto

Z Preeba de bs idetrti td dd

•
3.

Um p is dd cofifica& do aim del maw"
t1e IP s Is -

F~ttrgrne eapia9 de eqC
de naciiad0.
eunre ns~t r e~ tamer
erideacia dela

dDO==tMafmdcVmur

$i eased
5.

~ a bra pcegocdas 14(s) 3`~ 14(b) m la Solia[rrd tk R,~turi6R Fmnitiar, apa¢te te$isays jutTteiabp, PoS, pto de boa
srrvici m Sari &ObCW2MCMbd= nhWiMadtis COD d/ bas hIddMLe(4
Si ns~t No m ttrm tk boa pales o ei ttda iegpl da esEe tsar, per Fivtebaogvte's®c de um da los siguietw~ doq~,~ auao eo~ de
damakMa Si ustaa M es d paft o d
iegd del mcam;tm es aeasmio the enuegne un comptabuate de dnn&Ma.
a.
h.
m
d.

Una cepk de sa to a asina)
Um copia dd estado de mega acmal da sa hipomm
Cmta dd pmgk=ior, m ]a class
Su damits}iD.
Uf iacgpi da m cmn pond,pflTctH&nWmft one

Fhmly tau Apph-tk-

STansots,lur. 0410111011
+

de mvicio puldku xHgib a usleoL oDatspoofficadu a7os tl

das Iar~

OFICINA DE REUBICAC16N DE RMGLMDOS
Did" de Selrvide s de N'mas
AUTOitI7AC16N PARA LA DIVULGAC16N DR DiFORMACI6N
.
IlWORMACi N REQVEPMA PARA LA DMEMGAC1 N DB ANTEC MENM
WOMBU UMMMOIL ctrl
ry
FECHA DE NAMUMM MM MEIVORt I

01MA

FECUADENACOMM

MM PALTROCRUAQ$:

,
ApeMd° <g>,

SEgO:

I~

(Soma)

mAw
-

ML

Eaas

"a1tJ Aoty- 1(400 Lour de ojas
ca"d

Aftm

f

DE SEGl W SM"

ape

Pd ~

LUGAR DE ri &CO&MMU: (Qw id ddlga de date kbw pace el estado)

OTROS NOl

VTUIZ&OM Y SW WSCErAs nW USO-

Nambm
RESM*NCIASMLOS
DME:
AMsa

DesiG
Mes Ain
MMOSSANM*

Mes Aim

Ewa=
Mes Ana

Mss Aho
Apartw enW

Gtodad{coudado}

Fstadn

Dooiaio
'

ApartaasmW am

Ch dad (
=Oft&)

EsUds

CfFd"
PWW

Doxicra

Apartumoft um.

Ciudad {odado)

F.stado

C"90
POSW

Drama

Apartasteabv.
nio.

Girded (oendnda)

Fstado

Codigo
POSW

03

BASTA:AfedAffo

DEPI;:

Mc slAio

ALA MA.
-

MedAiin

DESK:

M& MM

HASTA:

MedlAiio

Dl

bwAiie

HASTA
:

i&Afio

CUMAIDANIA DE LOS FSI'ADOS UN UMS Si el pattuaina dor es em dadano estadaa Wcnsr- pem no uacM en les EH. UU, brinde hdbn saci$n acme de
de dodadanfa.
una a mis de las
CerfiffCWWdtMXb02MEWCifW

j

Tdinumal

'54.Pr oe Co q ~

(
Sxpdad

GUdShr r +~

Z?stado

dada
(
-11
dG
c > aferr~e id as ie~n ra d
Faimalario 2+N del
~licalz6n
MtslpfalAso
x~iiyue la fecba en goe se ptrpanQ
el fornwGvio y brinde uaa
explicsoft si fmm novs2do,

Ciudad

tt t

G
N6mtro de cerrifx~do~

de emisi6n

1

~/13oda emisi6n

do ou dadadaeo de Im Esstsdim IN las

—
Pnede sa two an pasopmla de Ina EL UU aet"d cam antcdm
8
DONX CUMADMW Si el S 9eW Um ( lavo) Mok amW nf% de los EAados
y
UUMm de wopa(s, indhpcei nombw de dire en el espado de as dmechiL
EXTRANOMO Si el s*lo es exnanjarm, bdfiquO la ssgniarte informari5n_
Estado Feeba de entrada a Ios
Ciudad
EE. UU.
Lugar de caftl& a los
Mes Ilfa
Apo
ESUTA s iJnWas

McslDfil a de

Pais

u

log ~'s 77

Sal V, dof

Nfinero de regisnu del
c~rarijan

Pais de ciudadanfa

a
i.drearsl ubQnde5e~cee Socio& Siwems,s sa to 1"m, "dale q s Is Olt$so Patch raaMw r la lawn dsanWomUnUs
AFo es
weeesa►iss pararl pimce de ~
Adnve ai Ldatwstka~, iet.lil3l/7llll
Aa~tlw [a;
n" I)rJFQPP-7a

Fie 3 ot2

ONCINA DE REURICACION DE REFUGIADUS
Divisl" die Servki w de Nmns
AUPORMC16N PARA LA DWtILGACION

I

ctcicladowo art, don

D>f. MORMAC16N

adotimciin, hwgvft=dkyfikAe& cm AW& megr:;.

Autoriw a cmdquier invesdV dm, ageoW cgxx iA einpleado, embradsta, cesionario u oho regresentante debujan nta aatarzmdo qua
kab* cm numbm de fa 066 ma de Roubk2ci6n de Refttgiados (Office of Refugee Rescuk meatt) que esW Hcvan& a cabo la invest6pm 6n
de mis antecedevfts y la evabxxi6n de patroci nio a aMoxx i darniad6n a fin de evahmr n i rapaddad papa bnindaxie el &Mdo c:aidaclo y
lugar a un mcnory pam pmveede Im suc ack* postesiores a sa !zbetao n, segdn sea neaesum. Anoorim a cvaltpex agenda de just ma
"
d
.
pmd federal,estatal o kwmt agectcia pm el bicnesu t.inhmffi federal, estatal, local o pdvada; ogendo federal de inmigmcidu o walquier
oha f6m to de infounad6i4 cal eomo cscwlas, tnibu mles, paovecdom de bwamicow, Amckmaovs de bocr a8
ckmailbgjo palWmr ,
pmfesimtales de la saW mental u onas refezencias, a &Mgar,tanto verbalmente como par e=lf, infbrma►a6n acema de todo Mstmw
t
dchcavo, cargos o du das solve abuso y descuido infanta, situaci& migutoda pasada y pmsmxe, pmoblemas de salad mental, aboso de
sastauc~ vi &mm dowAdwao cnakpm of m znfonnmm6n pmwaocW mcovdada amm de mi persona_
Autmisa a los catm&os de los re&ms y fumfts de la h& macidu sobre mi persona. a divulger tal infotmaddn ante b sofxitud dcl
investigadr, Socate espe64 eta, cooftvista, c esionado u mu mptesentmac dcbkamente amef de la Olitdon de Reubicmd&
f
itado
de Reft4ombs_

Ebtiendo que la infDumaci6n divulgada Pot cuakfdi r c ustodio de mis w4ut ms y otras faeades de la iaf*rmaacldn accua de mi persona es
parer wo olisiat par pane del gobirmo de k a EE- UU, sus empleados, cesionauos, c:ontrafidas y Wo personal dckga& Para kss fines
expresados mds amba y gae puede set revelatla par el gobjemo de k s E - UU_ solamcntc en la fauna autorirada pnr ]a.ley_
En em% qm esm iufxmacide se oouvromA en propiedad de la Oficioa de Reuhicaci6n do Re fugisdos y que puc& set ocviwAa par Sias
los
ti. s y deiega{ 'L'anbi~u ei3ohenda qae la ofiam de Rettbicacon de Refiagmdos puc& compafir ester
empieaclos, cos, a
informacibn con Los empleadw y c omVistas do otters agendas federates.
Per el pt4 wsk temmcio a cuakpder mQrhwo o derecbo co viand de Las Icy= de lays Esbwbs Uoidos corms el gflbimw federal, sm
mVkados, ceslamaaas, canhalistas o delegados porvsar legahmaata cudgoier infommaddn recopileda d mww la bcisgaeda de nn histmial
detect m, nn£unmci6a reiativa al biumstar ice, mb-mK i6a n igtatma pasaft o ptrscnM ctr*p= idotm m6a contemda cu mi sohmd
de patrockw y en la docam ut=d n de rrspaido y mfomu=i& rccopdMa de carer otter fuertte, en forma ord o eserib, relacionada
con esta solidus de patcocbmio.Pat' el grescnne mmmcio a tnda demanda o amm-dD pnevic con coalgtner agenda fidmml es#at4 local o
privada qw pudiera impedbdc al ddgpdo oficial de la oficina do Reubicaci6n de Rr fugiados obtema la infomnatibn solichada.
"
Las copies de esm arm mmd& qne corngan nu frims sou tau vdlidas causer cl od gival Ester auDoriz mhn m valida parrot (1) ant a padir
de la keba de su E mm

Rmla (1maw cm tioa)

Nombm completo (a m figmna o en lehadc
imprenta legible)
its i` C ?

Ot=

alias)
goeumed hays usadn (

Domicrlio aortal

~ ls~tzn

P~C~S

Fecha de rw dd paUmci mWor

Trstado

CA&go

Fecha de la firma

Os'/k l is
N6u=o del Segut o

Nro, de ic0ono de Sin hogar

posla

'Noes obllgsWiM titt3w=m utlmm de Sham Soalal. Sin urge, Sian to tn4tca, es dam qae U U~[ m ptteaa tYnrttar rtipfP
A
eatrs ncoosairis Para d pnWbil tiato & cewaftaoion
ant

61a do

yettataammiamsaw ml3t mjk
A~atlsNloaf~vAbom
0"04M raiiita+0t1l4iMMU

Page I On

EXHIBIT 2

U&

dunce arRdhgm ltewttUem4nt
5panmr Care Agreewwt,Rey. 04!3011011

nrHmIth rod R==n 5ervhxs

Nombre del menor:

Alias (si los toviera):
Nombre del patzvdMilor.

OFICINA DE REUBICAC16N DE REFIJGIADOS
Divisi6n de S"cios de Ninos
ACUERDO DE CUIDADO DEL PATROCINADOF
uanem del menor A:
echa de nacimiento del menor:
Fecba: OC' 1n IJSV

Le solicit6 a la Oficina de Reubicaci8n de Refugiados (Office of Refugee Resetdement, ORR) panuciriar a un ni.no
extranjem no acompaiiado en el cuidado y la custodia del gobierno federal conforme al acuerdo cxtajudicial
estipulado Flores v. Reno, ndmero 85-45 4--RIK (Px) (C.D. Cal., 17 de enero de 1997), seccidn 462 del Homeland
Security Act de 2002 y la secci6n 235 del William Wilberforce TraiJiicEug Victims Protection Reauthorization Act de
2008. Si se apmeba la solicitud de pauminio, recibira un formulario de Verificaci6n de liberaci6n de ORR y se
celebtaraun acnerdo de custodia con el gobierno federal en el euai acepta cumplir con las siguientes dispositions
mientras el menor este en su cuidado. .
s Froporciouar el bienestar mental y fisico del menor, que incluye, entre otros, alimentos, refvgio, vestimenra,
education, atenci6n medica y otros servicios segnin sea necesario.
Si no es el tutor legal ni el padre o la madm del menor, haga los mejores esfiterzos per establecer una custodia
legal con el tribunal local dermo de un tienrpo razonable.
0

As'istir a on program de orieWmi6n legal proporcionado per el Departm=nto de Juslicia (Department of
Justice, DOI), o programa de orientaci6n Legal para custodios (patrocinadores) de la Oficina Ejecutiva pars la
T{evisidn de la Inmigrad6a (Executive Office for lutuiigration Review, EOIR), si esti disponible en el lugar
donde reside.

•

Seg6n d6nde este pendimpte el caso de inmigraci& del menor, notificar al Tribunal de lnmigrwi& o al
Tribunal de Apelaciones de Inmigraci6n local en un pedodo de cineo (5) dins de todo cambio de direction o
ndmero de teWono del menor, usando el formulario de cambio de direction de extranjeros (fa mulario
FAIR 33). Adensas, si es necesatio, presentar unn petici6n de cambio de competencia territorial a hombre del
menor. La petici6n de cambio de competencia territorial debe contener informaci6n especifcada por el
Tribunal de Inmigracion_ Tenga cu cuenta que la petici6n de cambio de competencia territorial puede requerir
la ayuda de un abogado. Para obtener asesoramiento sobre la "pedd6n de cambio de competencia territorial",
consulte el Manual de prdctica del Tribunal de Inmigracidn en liti
Lisa. au\ 1e0ll9YA-. Para obtener
informaci& sobre casos de inmigtaci6n, comuniquese con el sistema de informaci6n de casos de inmigraci6n
de EOIR llamando al 1-804-598--71811. Visite el sitio web de EOIR pare obtener informaci6n adiclonal en:
i,lira/5`:4,•p il`,tiC'~. ~„ 4~ :,l'!{i~rS=1.•1:5~.i7[::1.

+

Noti5car al Depart memo de Seguridad del Territorio National (Department of Homeland Security, DHS) o
a Servicios de Ciudadanfa a lnn igraci6n de los EsU os Unidos (U.S. Citizenship and Immigration Services)
en an pedodo de diet (10) dfas de tndo cambio de direcci6n, presentando la Tm jeta de Cambio de Diracci6n
i
de Extmjero (AR 11) o de manes electronica en I i ~U: (I 1. u.:. 1--M
I P,

•

Asegurar la presmcia del menor en todos los pnocedimientos futuros anhn DHS o Inmigraci6a y Seginidad de
A,duanas (Immigration and Cltstoms Enforcement; ICE) y el DeparWwnto de Iusticia (Department of Justice,
DOJ) o EOIR Para obtener informaci6n sobre casos de inmigracidn, comunfquese con el sistema de
informaci6n de casos de EOIR IIamando al• 1-9013-S98-7180L
Asegmar que el menor ae presence ante ICE pars la expulsi6o de los Estados Unidos si uu juez de
inmigraei+6a emite una orden de expulsi6n o una orden de salida voluntaria. Se asigna al menor un oficial de
deportaci6n pare los procedirnientos de expulsion.

5ponmr Care Agreemen4 Rev- 840GS012

r
'U5A"

ORke of Refogee Resettlement

US. Departaxat of HeRM ttad Hmttan Serricra

Family Retmifkadoo AppHudaN Rev.O11ZSM16

OFTCINA DE REUBICACI(SN DE REFUGIADOS
Division de servidos pare ninos
SOLICEMD DE REUNIFICACIQN FAMOUAR
1. Nombm del In

A~ 7Aftin
)

Z.Su rdad6n con el menor:

<

3. Su nombre (de

`(wt
O ;~Gt7 C10 .
5. Su pail de origin (de usted):

ra

4. Cualquier otro nombre clue usted haya utllizado:

` f w
~~

6. Su fecha de nacimiento (de usted):

donde nos
7. Ndmero(s
comunicar
"
con usted:
9. El domic> iu donde residu-An us" y el memr:
1
Li
C_

w4"nl~ (el

1q~

It. tfam~l a% vsArns-0

i
10. lQue Womas habla?:
c
Ct 4't r3C~J
ciit

~C

fav-

S

11.Infermad6n de Jos ocupantes del hogar. (Si rlecesita mss espada,sirvase adjuntar um lists de los ocupantes del hogar
a este formulario)
Nombre
lfltm

Irfait-0

Odw
kO

d

J

Relad6n con usted
(e) patrocinador)

Relaei6n con el meaor
(p- ej-, madre,padre)

10

VQ ic7s U—
n-

anc?

Fechn de
Nachnknto

-rtq

poly

6
-SO

<CA

~S d

6 Lf t/a

e'te.

o
12.Informad6n Unandera:Sfrum exp9car c6mo v a mantener finanderamente al menor:
t
'

J%~r
Y

of

Family Rewffla► dm Applimdoo,Rev. tllaSM16
ORR UGFRP4%

pro sr~ 3

t"r

0119ee of Refugee Resettlement
Family Reunification Application.Rev. 01 ISM16

U.S. Department of Health and Human Services

13. ZAlgimo de los ocupantes de su hogar sufre de alguna enfermedad grave y contaglosa (p. ej., TB, SIDA, hepatitis)? Si
fuera, por favor, expliquelo:
/ j }

14(a). ZUsted o eiguno de Im ocupantes de su hogar ban lido acusados o condenados por un delito (que no sea una
infrac d6n menor de transito, p. ej., velocidad excesiva, multa por mal estacionamiento)?
® NO u Sr
14(b). ZUsted o alguna persona en su hogar ban sido lnvestigados por abuso flsico, sexual, descuido o abandon de an
menor?
® NO u Si
Si usted respondi6 "Sill a cuolguiera de ]as preguntas 14 (a) o 14(b), sirvase adjuntar anti lista a este formulario con la
siguiente informaci6n pare cada eargo/condena:
(1) Nombre de la persona involucrada; (2) lugar y fecha del incidente; (3) descripei6n del incidente;
(4) Resoluclbn sohm el incidente (p. ej., desestimaclon de cargos, multado, encareelado, periodo de prueba); (5) Copia
del(de los) registro(s) judicial(es), registro(s) policial(es), y/o registro(s) de la agencia de servicio social gubernamental
reladonado(s) con el(los) incidente(s)
15. Si existiese la posibilidad que usted deba salir de los Estados Unidos, o ser incapaz de cuidar al menor, gquien
supervi%wia al menor en su ausencia?.
~r
r Cd fW t N ~ j
0
,
Q
Nombre del posible cuidador adulto: 1111 d fl
Fecha de nacimiento del posible cuidador adulto: ~ ~
Informaei6n de contacto (direcei6n y niunero de telef000) del posible cuidador adulto:
Relaci6n con d menor, si hay
Resume su plan de cuidado en caso de que usted tenga que salir de los Estados Unidos o sea incapaz de cuidar al menor:

dosai
d { 0 0-r'C1

Los bt I'LS ?a-14 cae-io 0w-A
_1

pot

O

Z'O r3uq oc

lvt~rga~~ cou,t~A 5Le F►cr,gvlI I,

Declaro y afirmo bajo pena de perjurio que la informaci6n contends en esta solicitud es verdadera y precisa, segun
i
mi leal saber y entender. Doy fe de que todos los documentes que presento o Ins copias de dichos documentos estfin
fibres de error y de fraude.
Doy fe ademfis que me atendre a [as instrucciones contenidas en el Acuerdo del Patroci'nador sabre el Curdado. Velare
por el bienestar fWco y mental del menor. Tambi6n cumplire con Ins leyes de mi estado respecto del cuidado de este
menor, to que incluye la inscripci6n del menor en la escuela, la provision de atencinn medica cuando sea Aecesaria, la
proteeci6n del menor contra el abuso, descuido y abandono, y cualquier otro requisito no contenido en el presente.
SU FIRMA:

Family Reunification Application.Rev, 01125/7016
ORR VC/ MP-3s

FECHA:

c)

J( Q//Y

T"

y

t~

O. US A'

Office -Df Rdagee RMtdUwA

U.S. Depatrhmal or Health and Hen so-vim

Farmiy ReunWcatim CbeckW for Sponsors. Rev. 0414 M14

OFICINA DE REUBICACION DE REF'UGIADOS
Divtstdn de Servtdos pare Ntftos
LISTA DE VEREFAMN FAMILIAR P.ARA PATROCINADORES
t!ormularios cue deberAn ser comvletados,_filrmiades v
devueltm aso balmiado> r social

Form ularios ave deberliin ser lefdos v mantenidos en so

R He completado y firmado la Autorizaci6n Para la
Divulgaci6n de lufarmaci6n

® He lefdo la Carta introductoria del Paquete pars la

I[ He eompletado y fmrado la Solicitud Para la reunificaci6n
familiar

er

Reunificaci6n Familiar

He lefdo el Acuenlo de Cuidado del Patrocinador
® He lefdo la l ista de Veriflcaci6n Para Panvcinadores
He lefdo el Programa General de Orientacidn legal Para
Custotlios

® He lefdo el Manual Para el Pairocinador
® He lefdo Ins Inetrtwciones parala toma de huellas digitales
per si tienen gtre ser someddas.
s Carta de Designaci6n del Cuidado de un Menor Para el
patrocinador qua NO es uno de los padres del menor ni sa tutor
legal.

Documentos urubatorios
Par favor propomione una copia de los sigutentes documentos que figuran a continuaci6n, ,For favor tome en cucuta que tanto la
Oficina do Renbicad6o de Refirgiados (Office of Refugee Rcsetticutent, ORR) come la Division de Serviclios de Nriios no
s
AcomlmWns (Division of Children' Services, DCS) pueden mobazar .su solicit ud come patroch ador A falls cualq ier elemento de

la informacidn solicitada o si csa misma ester incompleta o no es corrects. Ea el case de que no Pueda proveerlos documentos
reque idos,adjunte una explicaci6n, junto con la Solicitud de Reunifi> acift Fa iniliar, en la que indique que tipo de documentaci6n de
respaldo no puede presentar y la raz6n. Tenga en cuenta que so expliea d6n sobre cualquier documentaci6n faltaute queda►a sujeta ala
AI NL41

1.

Proeba & an bkn idad:
Una c *a de tma idrntificad6a enfidda par el gobierno, tal coma:
a

b.
c.

Licencia de c dacir o m jets de k1mWfrcaei6n emitida pore] caado
Docmmratn do ideutidaA (cm fr to) de su pats de otigen (p. ej., cedula)
Pasapotte

Y

*

Una OVM de su aRfificado de Yahmmimdo

Z. Prnda de la kkntidad dd near:
Una copra del cerdficado de nadmiento del memr
•
3. Pmeba de Pamntesco:

1a&
Irm
iftcados
Eniregue copias de cvr, de nadmimtu,de mstdwnlo, ,M,% jndiciales, =69 de la tutuda u onus documentos. a fm de "Aar
eAdmcia de la rdoci6n entre usted y el utemar_
si
4. Rtgistrus Legates ( torreVwvk)
Siumdrespmdi6 " a In pregnntw 14(a) y1n 14(b) an la Solicitud de Reunifimd6n Famillar, agorae regimes ju&ciates,policiates, ylo de ins
mrvicios smiales gub=wxacatales relacionadas con el/ las incideate(s).
S. Si acted Was um de los pa&m o el tutor iegai de este rasa, par ravor pmpovdane de uno de los siguienim documentos corm compmbante de
damicWo. Si usoed SI es el padre o el nyw legal del numar,na as n=xwio que enpegue un comptobante de domidlio.
a Una copia de sa nnta state]
b_ Una capia del made de atenta actual de sulopateca
Q Cnta dd psnpictario. err la que se con itme su domicilie,
d_ Una copia &-.-w cuncqxwdcacm pserenb1cmrnie una fact= de sern6u publice difieda a aped, contspondk xb a ins Wdm to dos mesm.

Famuty Reunification Appllistlon Checkna for Sponsors,Rw- 04MU014
ORR UAC(FRP-3A&

OMCWA DE REUBICACION DE REh'i.IGIADOS
Division de Servvicios de Nunos
AUTORUAC16N PMU LA DMLGAC16N DE INIfORMAC16N
EWORMACI N

AP

J+IOMBRE DSL I~IEl+10R:

LA INVESMANON DE ANTECED
WCRA DE NACI14fJt NW DEL NWMR:

-LWOMACION DEL PATROCTNADOR:
ApdHdo se 19 is
i=rlme<
kic

15lc~nbre del media (snf~o)
C
FE1vL
SEX(): IN MA C.
Ran j q f„w v '4q L' q'j'c Color de of
S
. F4
Peso
f
Altura
Color de pelo
INVIZVO LUGAR DS NACPAUNTO: (Use el codigo de das ietrw pare el estado)

FECHA DE NAClM1Ei+ M
Ano

-Ift

10

RA DE SEGURO SOCIAL

L

I

Pats
. L(

~l~l 11~t~~S

1

:501,1-k f e C /

OTROS NOMERES UTIIdZAIfOS Y SUS FECHAS DE USO:
beade:
I Rasta:
Nombre
Mes A&
Mes ASo
itESUWNCUS EN LOS VLTIMOS 5 ANDS:
DESDE:
Mg&fAna
HASTA:

MedAfw

HASTA:

McdA,no

HASTA:

Mes/Afio

Apartamentonra.

Desde:
Meg Ado
Cludad{condadu)

Hasts:
Mes Afia
Estado

Codigo

~ p lira

MesfAPm

DESDE:

I+Iambre

Mea/Ano

DESDE:

~Q va(/01

f

McsfAito

DESDE:

t4 `bu~

HASTA:

DomiciH D

Apartamento am

Ciudad (coodado)

Fsfsdo

C6di90
postal

Domicilio

Aparumentonno.

Ciudad(condado)

Fstade

Cddfga
pasty

Dornicilla

Apartamento nrv,

Ciudad (coadada)

Estes

c6fto
Postal

Mes/Afi a

CnMAD
DE U)S ESTADOS UNUMS Si el pauminador es eiudadano estadounidense,pero na na66 en los EE. UU., brinde infonnaci6n acerea de
una o etas de Ins siguientes pnmbas de ciudadanfa.
CerlffciBo de nsbuaffmKiin
Ciudad
Estado Ndmero de certificado
Tribunal
McsfOWAfio de emir 6n
?
Certifirado de ciudxdanfat 'Doade se enrw et nEq
Ciudad
p
W051M+0
&C
Formulario 2,40 dsl Pgartaento de Estada Worme del nadva a►tt► to d exhw&ro de un dudadane de Ins Estadas Unidos
Txplicaci6n
Mes/Dia/Ano
Indique ]a fecha en que se pmpan5
el forrnWario y brinde um
explicaci6n si fuese nccesario.
de kw EE. UU
f
Puedc ser Canto un pasaporte de Jos EE. UU Actual cDmo anterior.
o de i n
,0
M~~~
Fats _
DOSLE C[UDADAMA:Si el sigeM riew (o tuvo) doble chWadania, de los Esfadw
Unidos y de otm paL% indiq= d nomhm de dit ho pals en el espacio de la derecha.
w

5q

/.1 11

EXtRAN,IERO Si el sujeto es extranjero,%deque In siguiente infermacidn_
Estado Feeba de eutrada a los
Caadad
EE. UU.
Lugar de cutraM a Ins
A0
Mm Ila
Eslados Unidas

Minoru de regiam de]
extranjcrn

Pats de ciudadania

a No es obbgatoria iadicar A nfimero de Segura SadaL Sin embargo,sine ]o indlciiy es pobible que L ORR no pueda realb ar le ]nvesdgacibn do antemdentes
mecersaia pRm t1 procodinga to de reunifiewt6e.
Aatharhation for Rdmw of ladanwtion,Rev. IWV2"1
ORR Ucaw-25

OFICINA DE REUBICAC16N DE REFUGIADOS
Divisicin de Servidos de Ninos
AUTORIZACION PARR LA DIYULGACION DE INFORl1+l:AuON
Lett cuidadosamente ester mutorimci6n, luego j&mela y fd+chela con tbda negua.
Autorizo a cualquier investigador,agents especial,empleado, conuatista, cesionario u otzo representante debidamente autari ado quo
trahaje ennombre de la Oficina de Reubicacidn de Refugiados (Office of Refugee Resettlement) que estc llevando a cabo la investigaci6n
de mis anteoDdentes y k evaluaci6n de patroctimo a obtetrer informaci6n a fin de evaluar mi capaddad para brindarle el debido cuidado y
lugar a un menor y Para pmveede Ins servicing posteriores a su liberad6n, segdn sea necsiuio. Autorizo a cualquivr agenda de justicia
penal federal, esu al o local; ageucia pars el bienestar infantil federal, estatal, local o privada, agencia federal de inmi&=Mn a cualquier
otm fuemte de infomaci6n, tal como escoelas, tribunales, proveedores de tratamiento, funcionados de libertad condicionallbajo palabra,
pmfesionales de la sahrd mental u otras referencias, a divulgar, tanto verbalmente como por escrito, informaci6n acerca de todo Mstorial
dalictivo, cargos o Judas sobre abuso y descuido infantil, situaciim migracoria pasada y presence, problemas de salud mental, abuso de
sustancias, violencia domestics o cualquier otra informacion psicosocial reeapilada aeema de ini persona.
Autnrizo a log mstudios de los registros y fuentes de la informacl6n sobre nd persona, a divulgar tad informacidn ante la solicitud del
investigador, ageata especial, empleado, contratista, eesionario u otro representante debidamente acneditado de la Oficina de Reubicaci6n
de Refugiados.
Entiendo que La informaci6n divulga,da pox cualgnier cnstodio do mis registros y otras fuentes de la informaci6n acerca de mi persona es
pars use oficW por pane del gobierno de los EE. UU_, sus empleados, cesionarios, conaatistas y otro personal delegado para los fines
ezpresados mis ardba y que puede ser revelada per el gobierno de los BE. UU. solatuente on la forma autorizada por la ley.
Tntiendo que esta informaci6n se convertird en propiedad de la Oficina de Reubicaci6n de Refu&dos y que puede ser revisada por sus
t mpleados, cesionarios, con1vatisMs y delegados. Tambien entiendo quo la Oficina de Reubicaci6n de Refugiados puede compartir esta
informaci6n can los empleados y contratistas de otras agencias federates. .
Per el presence rewmdo a cualquier reclamo o derecbo on virtud de las leyes de los Estadas Unidos contra el gobierno federal, sus
empleados, cesionarios, contratistas o delegados por usar legalmente cualquier informaci& recapilada durante la btisqueda de mi historial
de&tivo, informacibn relativa al bienestar infantil, sitoacibn ruigratoria pasada o presente, cualquierRdormacidn conterdda on mi solieitud
de patx=Wu y cm la documeataci& de respaldo y la informaci6n recopilada de cuaWcr otra fuente, on forma oral o escrita, ielacionada
con esta solicited de patr ocinio. Por el presence renuneio a toda demands o a,cuerdo previo con cualquier ageneia federal esratal, local o
privada que pudiera in4xx rlc al delegado oficial de la Oficina de Rcubicacion de Refugiados obtener la informaci6n solicitada.
Las copias de ester auto&,addn que contengan mi flans son tan validas como el original. Esta autorizacidn es vU& por un (1) ano a partir
de la fmha de su firmaNombrc completo (a miquina o on leha de
imprenta legible)

Firma (fume con tinta)

f iwicrsco
Otros no

que usted haya usado (alias)

Estado

~ ~ f4Ch~ if 0 to

~~~d

~q -SeSv-s -s4ocwt7

Fecha de nac. del patrocinador

Domicilio actual

Fccha de la firma
I

C

C6digo

Numero del Segura

Nru. de teldfono de su hogar

postal
1

-Na es ebUptorio iadkarm hero de Segarn Sacral. Sin embargo, si m ro mdbesa,as pomace que is vxK m pneoa resrnar ra mvesngaatrn ae
anteeedeaies iris perm el pmeeMmeenro de reuoMead6m

Anfrwimfiam Aw Rth%n orLforu "00, Sev 1N31@nil
OEM UUJF P--Ter
OMB0970-073,vAd lhrnagh IiM3IMS

Page l

EXHIBIT 3

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EXHIBIT 4

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EXHIBIT 5

(~

Administration para los ninos y la familia
Oficina de Reubicacion de Refu9 iados
rU U J•

y~ r

Solicitud de reunification familiar
Como completer esta solicitud
IMPORTANTE:Si no puede completer estos pasos an el lapso de siete (7) dias, infdrmeselo at Administrador
de su caso.

Paso 1
Si todavia no to ha hecho, debe ffrmar y devolver de inmediato al Administrador de su caso el
formulario de Autorizaci6n de divulgaci5n de Informacl6n y Una copia de su identificacion (ID) con
fnto emitida por si goblerno.
Si se le pide que presence huelias dactilares, el Administrador de su caso to ayudarA a programar
Una cite pare presenter sus huelias dactilares an el lapso de ties (3) dias. Comuniquese con el
Administrador de su caso si bone preguntas.

Paso 2
Lea el Manual del patrocinador y el Acuerdo del patrocinador sobre el cuidado que incluye otre
information importante qua debe saber aicerca de patrocinar a un menor on nuestro programa.

Paso 3
Complete y fiirmp to Solicitud de reuniCcacicn familiar (p6ginas 3 a 7 de este paquete)_

Paso 4
Retina los documentos necesarios que se enumeran en la section Documentos problatorios
(pdginas 8 a 10 de este paquete).

Paso 5
Presente la 5olicitud de reunifiicacion familiar (esta solicited) y los documentos probatorios
necesarios al Administrador de su caso.

ORR UACIFRP-3s [Rev. 05114120181
OMB 0974-0278 IvAlida hasta al =112018]

P~gfrta 1 do 10

La LEY DE SIMPLIFlCACION DE TRAMrrES DE 1995 (Pub. L. 104-13). Se estime que el pranedo de Ins dedaradmas p6blicas obNgaWas de esfa
ser
solleihid de infemtaci& as do 30 mimdw por respuesta, indurdo el 6empo pare revi las insbuccierms,recdectar y mantener ids dabs necesades y revisor
is solicitud de informod6n. Una agenda no puede dlrigir ni pabrWrnar y no es necesario que une persona responda a una recopiiaddn de informad6n, a
mends que mueslre un nOrnern de control vAiido y actual de la CNicina de Adminisd do y Presupuesln (Ofrrce of Management and Budget, OMB) Consrtfle
et aviso de pmracidad adjunkOedaradon de la Lay de Prfvaddad pera oblener un or"Isis acema de (1) is autoridad de la solicitud de hftmecidn y acerca
de si la divulgacidn es obiigatoda o vduntaria, (2) foe prop6sitos pAncipales para Joe cuales la inrt mac*n, est6 didgide, (3) otms usos nifimri" Para [as
eusles se puede user la inromladdn y (4) los erectos, ai las hay, de no bdndertoda o pale de la infermaddn solicitada.

Solicitud de reunificacion familiar
Oficina de Reubicacion de Refugiados

Preguntas frecuentes
t,Puedo

patrocinar a mil hijo sJ no tango documentos?
Si. La Oficina de Reubleaci6n de Refugiados (ORR, Office of Refugee Reset0ement)/Divis!6n de Servicios de
Ninos No-Aaompariados (Division of Unaccompanied Children's Services, DUOS) prefer@ entnagar un nino a
su madre, padre o tutor legar sin importar la situaci6n migratoria.

glone, un costo patrocinar a un Who?
No. No se exigen cargos para completer los requisitos para patrocinar a un nino. Sin embargo, usted puede
ser responsable de los costos de viaje y como acompanante del nino.
LNelceaito un abogado para patrocinar a un nifio?
No. No necesita un abogado para completer los requisitos para patrocinar a un nino. Si necesita ayuda pars
completer los requisitos, el Administrador de su caso Jo puede ayudar. Si busca atenci6n adicional, tenga an
cuenta quo no hay ningun cargo por aompletar Jos requisitos para, patrocinar a un nino.
LPor qu6 tango que prosentar mis huellas dactilares?
ORRIDUCS requiere investigaciones de antecedentes para garantizar la seguridad ddl nino_ Si se le pide
quo presente huellas dactilares, el Administrador de su caso to ayudara a programar una cita pars presentar
sus huellas dactilares en e) lapso de tres (3) Was. Comuniquese con el Administrador de su caso si tiene
preguntas.
i.Qu6 inf6ttmacil6n debo proporcionar?
Debe completer la Solicitud de reuniffcaci6n familiar y los documentos probatorios. Tambien debe responder
preguntas del Administrador de su caso sobre su hogar, la relaci6n con el nino y su capacidad de cuidar el
bienestar fisico y mental del nino. Dabs proporcionar prueba de su identidad.
,&Cudndo tango que entregarle +estos documentos al Adminlstrador do mi caso?
Debe presenter toda la informacion necesaria en el lapso de siete (7) d1as o antes, si es posible. Cuanto antes
presents todos Jos documentos necesarios, con mss rapidez ORR tomara una decision sabre la liberaci6n del
nino para su custodia. ORR le irr#ormarA de inmediato la decision sobre la liberaci45n del nino para su custodia
o le notificard si se neeesite una evaivaci+•in o infonmacitin adicional.

ORR UAC1FRP-3s [Rev. 05114/20183

Adm4iistrador do SLI C8$0.

P691tta 2 de 10

OME OMM-02M tvMda hasta el 10131M18J

La LEY DE SIMPI. ncAcON DE TRAWES DE 1995 pub_ L 104-13). Se esUrna que el promedio de las dedaraciones p6btieas obiic a as de esta
solicftud de i►dannacibn as de 30 minutos por respuesta, induldo el tiempo para reviser las Inshuodoms, recolector y mantener W datos necesarios y
mvisar la so8citud de informad6n. Una agenda no puede drigir ni patroaker y no es neaesario que una persona responds a una recopilwZn de
informad6n, a metros que muestre un nfsnero de control vdfldo y achwi de la Ofidna de Admin'ISUad6n y Presupuesto (Otte of Management and Budget,
OMB) Consufte el aviso de p&addad adjunto0edaradbn de la Ley de Privaddad pars obtener un anANsfs ace m de (1) to sutarided de la soliicitud de
informad6n y acema de si is divutgaadn es obligators o voluntarta, (2) los prop6sites prindpales Para los wales Is informacfdn esIA dirigida, (3) otros usos
A
a IAN 1n arw+% ci Ina Mav tra r h kwiAP IMo n rge{A do la inrM.nAM,..AnIh7Ia&
w., t.....s........... I- --I- ee

Solicitud de reunificacicin familiar
Ofiicina de Reubicaci6n de Refugiadoe

Acerca de usted, el patrocinador y el (Ios) menor(es)
2) Su relacibn con el (los) menor(es)
p. ej. madre, tie, amigo de la familia

1) Nombre(s) de! (de Cosy menor(es)
Enumere los nombrea do todos los ninos que solicita

3) Su nombre
4) Cualquier otro nombre que usted hays
utilizado
Enumere obw nombres que hays usado,
Coma sU hombre antes de casarse o sus
apellidos matemos (separelos con camas)
5) Su psis de odgen (de usted)
Donde nacis
6) Su fecha de nacimiento (de usted)
p, ej., 12131/1979

7) Numeros de teitafono

p. ej., 210-555-1234

Tel6fono principal
Telftno secundario

8) Su direcci6n de correo electrftico o
n6mero de fax
9) ldioma(s) que habla

ORR UACXRP-3s [Rev. 05M4120181
OM13 0070-0278 iv€flida hasta el 10MI20101

Pt;glna 3 de 10

'o
-

La LEY DE SIMPLIFICAC16N DE TRAMITES DE 1595 (Pub. L 104-13). Se asllme que el pmmedlo de fas dedaradones publicas obl4au*as de esta
sol;citud de irdbrmacidn as de 30 minutas por respuesra, inciuido el tlempo pare revisor las fnstrucclones, recalectar y mantener fos datos necesarW y
reviser In satidtud de infammaci6n. Una agenda no puede dirigir rrt patiadmary no es nemado que tines pefswa responda a una rew0faci6n de
intommacidn, a rnencs que muesire un nGmero de contrd v9Gdo y actual de la Ofidna de Admin6ftd6n y Presupuesto (office of Management and Budget,
OMB) Consutte, el aviso de privac7dad adiuniaMedarwkn de la Ley de Privacidad pare oMener un "lisis acerca de (1) is auWdad de la solic:ittud de
infonnad6n y ecema de si la dtvulgacidn es ob(kptwia o vduntaria, (2) los propdsibm principales para los cuales la informad6n est;& d.liwda, (3) ohm usos

Solicitud de reunificacion familiar
Oficina de Reubicaci6n de Refugiados

1,130"nde viviran usted y el (los) menor(es)?
1 Q) Qomicilio
Domicillo
(+ n6mero de departamento, si
corresponds)

Ciudad

I

j

11) LQuien viv+e actuaimente en este domicifio?
Fecha de

ombre del miembro del hour

rtazlrt>lleJrtttoJ

(EJEMPLO) Miguel Peru

ORR UACIFRP-3s [Rev. W14120181

1213111985

`•

-••

Relaci6n con
usted (el
patrocinador)

Hermano

-

•

Reiaci6n con el
rtrlenor

To

Pagina 4 de 10

©M8 0070-6278 jv&IdIa hasta el 10131120181
Le LEY DE SIMPUFIGAWN DE 1RAMMES DE 1995 (Pub. L 104-13). Se estima que el promedio de !as dedara#ones pabUcas obli<jatodas do esta
solicltud do informedbn es do 3Q minutos por respuesW. Induido el tlempo para reviser tas irmtruWones, necolecter y mantener tos datos necasados y
reviser is snticitud de informed6n. Una agenda no puede dlrigir ni patrocinsr y no es necesario qua una persona responda a une recopiladdn de
informaddn, a menos que muestre un Mrnero do conbd vMdo y actual de la Ofidna do Administraddn y Presupuesto (Office of Mansgemerd and Budget,
OMB) Consults el aviso de privackled adjurrto/Deciaracf6n de la Ley de Privaddad para obtener un artfilfsis acerca de (1) la auWdad de to solicitud de
inforrnecOn y acaroa do si la divuhpolbn es oWkj2doda o voluntaria, (2) los propdsltos pdrraipales para Jos cwkL-. is intnrmacMn estA dirlgida, (3) ohms usos

Solicitud de reunificacion familiar
Ofidna de Reubicacion de Refugiados

Adulto que se hard cargo del We Jos) menor(es) si usted no
puede hacerlo
En el caso de quo tenga que irse de los Estados Unidos o no pueda hacerse cargo del (de los) menor(es),
gquiian se harA cargo del (de ios) menor(es)?
12a)Nombre del posible encargado aduFto

L~

I

12b) Fecha de nacimfento del posible encargado
adulto

12c) lnfonnac!6n de contacto del posible encargado
adulto

NOrnero de
telefono

Domicilio
(+ n(imero de departarnento, si
corresponde)
Ciudad

Estado

C6digo postal
n

12d) &Cud[ es su relaci6n con el (los) menor(es)?
(abuelo, tta, henrlano mayor de 18 anos, etc.)
12e) &Cual es su relacion con usted, el patrocinador?

12f) &C6mo se cuidard al (a Jos) menor(es) on el caso de que usted se tenga que it de los Estados Unidos
o rto pueda cuidarlo(s)?

ORR UACIFRP-3s tRev. OS114120181

•

P691na 5 de 10

OMB 0$70.0278 (vMda hasta el 1013112018)
La LEY VE SIMPLIFICACION DLL TRAMFES DE 1995 (Pub. L 104-13). Se estima quo at promedio de las dedaractones publican obiigatorias do esto
so icitud do ini6imaci6n es de 30 minutos por respuest% induido el tiempo para reviser las instrucdones, recolecter y meritener ios daios wasarios y

reviser is solidtud de informaci6n. Una agenda no puede dirigir M patrociner y no es rrecesarlo que una persona responda a una recopitaabn de
informaci6n, a menos quo muestre un nftmem de cordrot vMdo y actual de la Ofdna de AdminWtraci6n y Presupuesto (Office of Management and Budget,
OMB) Consulte at aviso de privaddad adjuntofDada mMn de la Ley de Privacidad para obtener un wAlisis acerca de (1) la aubxWod de la sdkadid de
infonnaddn y acerca de si is divulgacidn es *Wlgatoria o vvluntaria. (2) los props itos pftpales pare bss cuales la irtformaci6n estd dirigida, (3) otros usos
n

Solicitud de reunificacivn familiar
Oficina de Reubicacibn de Refugiados

Informacion economica
13) ,&Mmo mantandirS own6micamente al (a los) menor(es)?
Incluya todas las fuentes y las montos de su ingreso (por ejemplo, cu6nto le pagan por semana) y
explique cualquier apoyo econdmic o qua reciba de otros que to ayudaran a mantener econ6micamente al
(a Jos) menor(es),

informacion medica
14a) &Ngunc de los ocupantes de su hogar sufre de aiguna enfemmedad grave y c:ontagiosa (tuberculosis
[TB], sindrome de inmunod+eficiencia adquirida [SIDA], hepatitis, etc.)? Si asi fuera, expliquelo;

14b) jSabe de aiguna afeccibn medica que el (Ios) menor(es) pueda(n) toner (discapacidades, alergias,
enfwn adades, etc.)? Sl asi fuera, expliquelo;

ORR UACIFRP-3s [Rev. 05114=161

"AdministradoiedeSLIC2SO.

PiAgina B de 10

OMI! 0976-4278 [valida hasty el 10131=181
La LEY BE SIMPLIFICACt6N BE TRAMn ES DE 1995 (Pub. L 144-13). Se estime qua el promedia de fas daderarion as pLIblic ass obUgatorias de esia
soliahA de Wormaci6n es de 34 minutes por respuesta, kWuldo el bwpo pars reviser [as instrucdones, recolectsr y manbaner los dabos neceserios y
reviser Is solidtud de infonnacian. Una agencia no pueds dirigir ni patrednar y no es nedasado qua una persona responda a una recopilaca6n de
informad6n, a menas que mueahe un rulmem de control vblido y acWW de la Oricina de Administracl66n y Presupuesto (OfRce of Management and Budget,
OMB) Consulte el aAso de p&iwAed adjunto(Qedaradbn de le Lay de Prtvacidad para obtener un arvalisis acerca de (1) la autorided de la solicitud de
infOrmWbn y atoms de si to divutgad6n es afte. toria o volunWa, (z) lop ptop6sitas principales pare los COW to infonmacibn ester diriglda, (3) obw usos

Solicitud de reunifcaclo'n familiar
Oficina de Reubicacion de Refugiados

Antecedentes penales
Si responds °Si" a cualquiera de estas preguntas, tendrA qua brindar m6s informaci6n. Consults la pAgina de
Documentos probatodos (pagina g do esto paquete) para obtener mAs informaci6n.

I5a) &Usted o alguno de los ocupantes de su hogar han lido acusados o condenados por un delito
alguna vez (quo no sea una lnfra+cc16n manor de trAnsito, p. ej., velocidad excesiva, multa por mal
astaclonamiento, etc.)?
QSi 0 N

15b) ZUstied o alguna persona an su hogar han lido investigados por abuso f1sico, sexual, desculdo o
ahandono de un manor alguna vez?
b S i @ No

Firma y fecha de la solicitud
Declara y aftrmo bajo Pena de pefjurio que la informaci6n contenida en esta solicitud es verdadera y
precisa, seg6n mi leal saber y entender.

Doy fe de que todos los documentos que presento o las copias de dichos documentos estAn libres de error,
y de frauds.
Doy fe ademas que me atendre a las instrucciones contenidas en el Acuerdo del Patrocinador sobre el
Cuidado.
Velar6 por el bienestar fisico y mental del (de los) menor(es). Tambidn cumplire con las ieyes de mi estado
respecto del cuidado de ante manor, to que incluye:
• la inscripci6n de (de los) menor(es) en la escuela;
. la provision do atenci6n m6dica cuando sea necesaria;
• la protecci6n del (de los) menor(es) contra el abuso, descuido y abandono;
: y cualquier otro requisite no contenido an el presents.

FECHA

SU FIRMA

ORR UACIFRP-39 [Rev. 05114110181
OM13 0970 4278 IvAlida hasta el 110131W81

-+

-

a

Pagina 7 de 10

La LEY DE SIMPUFICAC.IdN DE TRAMi7ES DE 190 (Pub. L IN-13). Se esttma que at promedio de las deda►adones pablI as obligaWrias de sets
so!Wtud do utformad6n es de 30 minutes por respuesta, Induldo at tiempo pare reviser las Instruc clones, recolectar y mantener log dates rreceserios y
reviser Is saticitud de intonnact6n. Una agenda no pueds dirigir nI patrocinar y no as necesado que una persona responda a una recoplisd6n de
infomad6n, a menos que muestre un numem de control vhlido y actual de Is Ofidna de Administraddn y Presupuesto (Office of Management and Budget,
OMB) Consulte el aviso de prtvacidad adjuntolDecfaracibn de Is Lay de Privacidad pore obtener un arrgisis acerea de (1) to autorldad de Is sbUatud de
Informaci6n y mmrca de si la di Wpcl6n as obligaWda o voluntada, (2) W prop6sftos p4m1pates para los cuales In inforrnaeft oath didglda, (3) ohm usos

Solicitud de reunification familiar
Ofidna de Reubjeaddin de Refugiados

Documentos probatorios
5irvass provesr Una copia de los siguientes documentos que fcguran a continuation. Si no puede proporcionar
los documentos que solicitamos, explique el motivo. Tonga en cuenta que podemos rechazar su Solicitud si
falta cualquier elemento do la information solicitada, si esta se encuentra incompleta o no es correcta.
1) Prueba de identidad de usted y de los mlembros del hogar
Una copia de una idengficaci6n emitida por el gobiemo. Puede presentar una opcion de la Usta A o dos o
mss opciones de la Lista B. Si presenta opciones de la Lista B, al menos una opcion debe aontar con una
fotografia. Se aceptan documentos vencidos.

Lista A
Pasaporte de Jos EE. UU o tarjeta pasaporte de los EE. UU.
Pasaporte extranjero que contenga una fotografia
Tarjeta de residente permanente o tarjeta de registm de extranjero (Formulario 1-551)
Documento de Autorizacion de Empleo que contenga una fotografia (Formulario 1-766)
Licencia de conducir o tarjeta de identificacion de los EE_ UU_
Lista B
GertWr,adu de naturalization de los EE_ UU.
Tarjeta de identific:ad6n militar de los EE. UU.
Partida de nacimiento
Cer6ficado de matrimonio
Orden judicial para el cambio de nombre
Ta"eta de identification de extranjero
Recibo de renovation del pasaporte del consulado que contenga una fotografia
Tadeta de identilicacion del consulado de Mexico
Licencia de conducir extranjera que contenga una fotografia
Tarjete del registro de votantes extranjeros que contenga una fotografia
Ta"eta de truce fronterrzo de Canadci que contenga una fotografia
Tarjeta de truce fronterizo de Mexico que contenga una fotografia con el formulado 1-94
valido
Docl.Jmento de viaje del refugiado que contenga una fotografia
Otros documentos del gobiemo similares

ORR UACIFRP-3a[Rev. CISM412018]
OMB 0970-0278 [vAilida haste el 10131Ji 0191

AdMinistrador de su caso.

P4ina 8 de 10

La LEY DE SJMPLIFICACf6N DE TRAwms DE 1995 (Pub, L 144-13)_ Se estima que el promedio de [as dedaraciones pubiicas a4GgaWas de esta
solioitud de InformseMn es de 30 minutos por respuesta, induido el tiempo pars reviser Ws instrucdones, recotectar y mentener Jos dates neceserios y
reviser Is solicitud de Jnformecl6a. Una agencia no puede dirigir ni patrvdnar y no as necesario que una persona reaponda a una rewolacidn de
informaridn, a ►rrenos que muestre un n0inero de c orrt d vMdo y achial de is Ondna de Admmcstrad6n y Pmsupuesto (Office of Management and Budget,
OMB) Consulte of aviso de priveddad adjunUV13edaracidn de to Ley de Privaddad para obtener un anblisis acwca de (1) Is autoddad de la sdirAud de
infom►ad6n y acemn de sJ la divulgacibn es oW%Iatoria o vduntaea, (2) Ice pmpositvs p incipotes pare Jos cosies la informac16n estA dirlaida. (3) otrurs usos

Solicitud de reunificacion familiar
Oficina de Reubicaci6n de Refugiados
2) Prueba de is identidad del menor
Una copia del certificado de nacimiento del menor
3) Prueba del parentesco
Copias de los documentos Para brindar pruebas de una relaci6n entre usted y el menor. Se aceptan
documentos venridos.
Su relaca6n con el
menor
PadrelMoore

Documentos aceptables
* Partidas de nacimiento
e Registros judiciales
a ldentificacion con fotograffa del padrelmadre ernitida por el gobiemo

adrastlro/madrastra
doptd legalmente al
menor

• Partidas de nacimiento
o ldentificaci6n con fotograffa del padre/madre emifida por el gobiemo
a ldentificacion con fotograffa del padrastro/madrastra emifida por el
gobiemo
a Certifcado de matrimonio
a Documentos de una orden judicial quo confirrnan quo se establecM la
adopcion o la tutoria legal

Tutor legal

* Documentos de una orden judicial que confirman que se establecio la
adopcion o la tutorfa legal
+ Partidas de nacimiento
• Identificaci6n con fotograffa del tutor legal emifida por el gobiemo
a Registros de la tutoria.
a Certificados de defunci6n
& Registrar huspitalarios

iembro de la familia

Po time parentesco

Partidas de nacimier to
o Rastro de certiticados de defunci6n ylo partidas de nacimiento de Jos
familiares que muestren que usted y el menor tienen un parentesco
i
• Certificados de matrimonio
a Registros hospitalarios
. Registros judicialeS
• Registms de la tutoria
a Certificado de bautismo
a

Comunfquese con el Administrador de su caso

con el menor

ORR UACJFRP 3s [Rev. OW14120181

CWS 0970.0278 [vallda hasty of iW3112Q'fta]

'•

ayuda? Cornuniquese con
.••.-

el
PSgina 9 de 10

La t-Ey DE siw,,uFIGA ON DE TRAmrrEs DE 5995 (Pub. L 104-43). Se eafta que el pfnmedio de las dedaradones pibiCas oMptudas de esta
solicitud de frrfonnad6n es de 30 rninutos por respuesta, induido et liempo pera revisor fes lnstarcdones, recdectar y mantener los lotus nooesstios y
revisar la solkAjd de Woffnad6n. Una eoncis no puede dirigir ni patrodnar y no es nemado que una persona responda a una recopil3d6n de
informad6n, a metros que muestre un nrimem de control vOlo y actual de is ofidna de Administrad6n y Presupuesto (office of Management and Budget,
OMB) Consufte el aviso de ptivacidad ad1unWDedarad6n de la Ley de Privaridad pare obtener un aWsts acerra de (1) la autoridad de la solicitud de
Infnm nriAf, u aroma da qi In dhnocaci6n es oWktatoda o Muntarla, (2) los propdsitos prindpales Para los cuales to inforrnad6n est'd dtrigtda, (3) ofros usos

4) Registros legales (si corresponde)
Si usted respondi6 "Sf" a cualquiera de [as preguntas 15(a) o 15(b) de este formulado, proporcione la
siguiente informacion pars cada cargolcondene:
• Nombre de la persona implicada
• Lugar y fecha del incidente
• Fxplicacion del incidente
• Pronunciamiento del incidents, (p. ej., retiro de cargos, aplicacidn de multa, detencfon, libertad
condiciona[)
• Copia del (de los) registro(s) judiciaf(es), registro(s) policial(es), y/o registro(s) do la agencia de
servicio social gubernamental relacionado(s) con el (los) incidente(s)
5) Evidencia del domicillo
Una copia de al mends un tipo de documentacion que verifique su domicilio actual. Los tipos de
documentacion aceptables incluyen los siguientes:
•
•
•
•
•
•

Su renta actual con su nombre, y con fecha en los 61timos dos meses
Su estado de cuenta actual con su nombre, y con fecha an los uttimos dos meses
Su estado de cuenta bancario, con fecha en los iritimos dos meses
Su empleador smite un recibo de sueldo official, con fecha an los Ottimos dos mesas
Su ID del estado vilida y vigente con su fotograffa y domicillo actual
Correspondencia, en to posible una factura de servicla publiico o liquidaci6n de seguros, dirigida a
Listed a su domicilio actual, con fecha en los ultimos dos meses
• Carta de su locador, certificada por notario p6blico, en la que se confirms su domicilio y que
contenga su nombre, la fecha en la cual se mudo, la cantidad de dormitorios y la fecha de
vencimiento de la renta
a Otros documentos similares que indiquen, de manera confiable, que vive en su domicilio actual,
eon fecha en los ultimos dos meses

ORR UACIFRP-3s [Rev. OSM4/20181
OMB 0970.0278 [v0da hasty el 1013112019]

'r

..

P3gina 10 de 70

Le LEY DE SIMPUFICACI0N of TRAMITES DE 1995 (Pub. L 144-13). So estima que el pmmed90 do Ins dedenadones publicas obfigntorias de esta
soliatud de infprmetilxt es de 30 mirwlns por respuesta, induido el tlempo Kara reviser Ins instrucciones, recoiecter y mantener los dates necesarios y
reviser la solicitud de info macl6m Una agenda no puede &Rjr ni palrod ur y no es necesario que una persona responda a urra tecopiiadnn de
informad6n, a menos que muestre un nftero de control v0do y actual de to Ofic:ina de Administraadn y Presupuesto (office of Management and Budget,
OMB) Consufte et eviso de prnracidad adjunta(DedaracOn de la Ley de PrWddad pare obtener un andlisis acerca de (1) la autoridad de In solfalud de
inh mtaadn y aicemat de si la dNulgaddn es 009- tone a voluntada, (2) los prop"los principales para los cuales In informooft ests didgida, (3) otros usos
ruNnerios pare los cuales se puede usar la infonnacibn y (d) los ereelos, si los hay, de no brinder toda o pane de la informaeldn solkWa.

Sponsor Care Agreement
Office of Refugee Resettlement
Le sollcft a la Oiicina de Reub1caci6n de Refugiados (Office of Refugee Resettlement, ORR)

patrocinar a un nino extranjero no acompariado en el culdado y la custodia del gobierno federal
conforme al acuerdo extrajudicial estipulado Flores v. Reno,, n6mero 85-4544-RIK (Px) (C.D.
Cal., 17 de enero de 1997), section 462 del Homeland Security Act de 2002 y la section 235 del
William Wilberforce Trafficking Victims Protection Reauthorization Act de 2008. Si se aprueba la
solicitud de pabrocinio, recibira un formulario de del ficaddn de Aberaadn de ORR y se eelebrara

un acuerdo de custodia coon el gobierno federal en el cual acepta cumplir con las siguiente_s
dispositions mientras el menor este en su culdado:

+ Propordonar el bienestar mental y fisico del menor, que induye, entre otros, alimentos,
refugio, vestimenta, education, atencift medica y otros servicios seg6n sea necesario.
Si no es el tutor legal ni el padre o la madre del menor, haga los mejores esfuerzos por

establecer una custodia legal con el tribunal local dentro de un tiempo razonable.
Asistir a un programa de orientaci6n legal proporcionado por el Departamento de Justicia
(Department of Justice, DOJ), o programs de orientaci6n legal para custadios
(patrodnadores) de la Oficina Ejecutiva pars la Revision de la Inmigracion (Executive
Office for Immigration Review, EOIR), si esta disponible en el lugar donde reside.
• Seg6n d6nde este pendiente el caso de inmigraci6n del menor, notificar al Tribunal de
Inmigracion o al Tribunal de Apelaciones de Inmigracion local en un periodo de cinco (5)
dias de todo cambio de direction o numero de telefono del menor, usando el formulae o
de

cambia

de

direction

de

extranjeros

(formulario

EOIR-33). Adem6s, si es necesario, presenter una pebd6n de cambio de cornpetencia
territorial a nombre del menor. La petition de cambia de competencia territorial debe
contener infornaci6n especificada por el Tribunal de Inmigracion. Tenga en cuenta que la

petician de cambio de competencia territorial puede requerir la ayuda de un abogado.
Para obtener asesoramiento sobre la "petic16n de cambio de competencia territorial",
consulte el Manual de practica del Tribunal de Inmigracion en
Para
obtener
information sobre casos de inmigraci6n, cornuniquese con el sistema de informaci6n de
casos de inmigraci6n de EOIR llamando al 1-800-898-7180. Visite el sitio web de EOIR
para obtener informacion adicional en:
i:.i,
tm.

• Notificar al Departamento de Segurldad del Territjorio Nacional (Department of Homeland
Security, DHS) o a Serviclos de Ciudadania a Inmigracion de los Estados Unidos (U.S.
Otizenship and Immigration Services) en un periodo de diez (10) dias de todo camblo de
direction, presentando la Tarjeta de Cambio de Direcci6n de Extranjero (AR-11) o de
manes eledmnica en c;1,'i,usa. ,),f% CSMP.
+ Asegur-ar la presencia del menor en todos los procedimientoS futuros ante DHS o
Inmigracion y Segurldad de A►duanas (Immigration and Customs Enforcement, ICE) y el
Departamento de Justicia (Department of Justice, 001) o EOIR. Para obtener information
oRR UAC/FRP-45 [Rea.65114/20181

Page 1 of 2

Office of Refugee Resettlement
sabre casos de inmigrad6n, comuniquese con el sistema de informacidn de casos de
EOIR llamando al: 1-800-898-7180.
Asegurar que el menor se presence ante ICE para la expulsion de los Estados Unidos si un
juez de inmigrad6n emite una Orden de expulsion o una Orden de Salida voluntaria. Se
asigna al menor un oficial de deportation para los procedimientos de expulsion.
» Notificar a la autoridad policial local o a los Servicios de Proteceion Infantil local o estatal
si el menor estuvo o esta en riesgo de estar sujeto a abuso, abandono, descuido a
maltrato a si se entera de que el menor ha sido amenazado, abusado o agredido sexual o
fisicamente, o ha desaparecido. Se debe notificar ni bien sea posible o antes de las 24
horas despues de ocaurrido el acont3ecimiento, o despues de tener conodmiento del riesgo
a la amenaza.
• Notificar al Centro National para Ninos Perdidos y Explotados (National Center for Missing
and Exploited Children) al 1-800-843-5678 si el menor desaparece, fue secuestrado o se
escapa. Se debe notificar ni bien sea posible o antes de las 24 horas despues de
enterarse de la desaparici6n del menor.
Notificar a ICE si algun indlvlduo que se crea que represente un sindicato de contrabando
de extranjems, crimen organizado a una organizaci6n de trafico de Beres humanos se
comunica de aiguna forma con el menor. Notificar to antes posible o antes de las 24 horas
despues de conocer esta information. Puede Ilamar a ICE al 1-866-347-2423.

berminos de este Acuerdo de culdado del pa&vdhador.
• Si no es el tutor legal ni el padre o madre del nino, en caso de que ya no pueda y no estee
dispuesto a cuidar al menor y no pueda transferir de manera temporal is custodia Mica y
el menor retina los requisites de la definition de nino extranjero no acompanado, debe
notificar a ORR ai 1-800-203-7001.
• La liberation del menor mendonado anteriormente de la tfCcina de Reubicado'n de
Refugiados para su cuidado no le otorga al menor ningun estado de inmigracian legal y el
menor debe presentarse a los pracedimientos del tribunal de lnmigraci6n.

ORR UAC/MP-4-- [Rev. 05/14,1 20183

Page 2 of 2

IT I

Deciaracion del patrocinador
-.~

Ofidna de Reubicacio'n de Refugiados

De lam y afirmo, bajo pena de perjurio, que soy el patrocinador propuesto para et menor y que
mi

Solief ud de raunftrcaddn familiar y los documentos usados Como respaldo a la solicitud

funcionan Como evident is de que tengo la plena intenct6n de proporclonarle cuidado at menor
que pretendo patrocinar. Asimismo, no me presento Como patrocinador para no tener a un
menor a mi cuidado y lueaa transferir ese menor a otra persona, en incumplimleinto de la poli4ca
de la Oficina de Reubicad6n de Refugiados (Office of Refugee Resettlement, ORR) y las leyes
federates.
Solo puedo transfedr a un menor al cuidado de otra persona en las siguientes situaciones:
(1) a los padres biol6gicos del menor, en caso de que al hacerlo no exponga al nino a un

peligro inmediato y que no haya una finalizaci6n de los derechos parentaies;
(2) en el caso de que no pueda o no desee continuar el patrocinlo debido a una difrcultad
inesperada o en el caso de que deje inminentemente los Estados Unidos, transferire
el cuidado del menor a un cuidador altemativo (y unicamente at cvidador alternativo)
identificado en mi respuesta a las Preguntas 12a-e de mi SWic#ud de reunfi adddn
ic
familiar, conforme a to aprobado por la ORR en mi Plan de culdado del paftdnador,
si al harerlo no expongo at menor a un peligro inmediato;
(3) a funcionarios encargados del cumplimiento de las leyes locales, esiatales o federates
o funcionados del Servido de Protecci6n de Menores (Child Protective Service, CPS),
o a las personas designadas del goblemo local o estatal.
Antes de intentar transferir a un menor, debo notificar at Centro de Atendo' n Telef6nica Naclonal
(National Call Center, NCC) de la ORR at 1-800-203-7001. La Ofidna de Reubicaci6n de
Refuglados puede requerir mas infcxmaci6n antes de que pueda realizar una transferenda de
cuidado o puede requerir una medida correctiva antes de aprobar una transferencta. .
Si no notifico a la Oficina de Reubicaci6n de Refugiados sobre una transferencia o si transfiero
al menor a una persona no autorizada, entiendo que el gobierno federal puede procesamte par
peijuido, fraude, trata de personas u otros detitos penales establecidos en la ley federal, segun
corresponda.
Comprendo que la conspiraci6n o la cooperacio'n en la comisio'n de cualquiera de los siguientes
actos constituye un delito:
(1) ingresar o intentar ingreesar a un extranjero a los Estados Unidos por un lugar que no
sea el puerto de entrada designado u otro lugar designado por el Departamento de
Seguridad National (Department of Homeland Security, DHS);
(2) transportar o mover, o intentar transporter y mover, a un extranjero que no tiene una
condiclo'n legal dentro de los Estados Unidos para apoyar una violacio'n de to ley;
(3) alojar u ocultar, o intentar alojar y ocultar, a un extranjero que no tiene una condict6n
legal dentro de los Estados Unidos; o
ORR UAC FRP-100 (05/1411 20181

(4) incentivar o inducir a un extranjero para que venga a los Estados Unidos si su
residenda es o sera una violacion a la ley.
Ademas, puedo estar sujeba a tener que asumir una responsabilidad civil derivada de una
transfierencia del cuidado de un menor a una persona no autorizada de forma negligence o
imprudenbe. La Qfidna de Reubicadon de Refugiados coopers plenamenbe con las autoridades
encargadas del cumpUrniento de las (eyes locales, estatales y federales, incluidas fas auGaridades
de inmigradbn federales o las autoridades de bienestar de menores, para poner en practica
fielmenbe las leyes que involucran la divulgacibn de mi infanTiado"n personal en el caso de que
un menor sea transferido de una manera no autorizada.
Ademas, entiendo que, si no soy un ciudadano estadounidense, una transferencia no autorizada
de un menor puede afectar mi capacidad de permanecer en los Estados Unidos,
independientemente de rmi eondicion legal de inmigracion.
Afirmo o certifico que entiendo la advertenda proporcionada en esta declaracion.

Nombr+e del patrocinador

ORR UAC FRr'=10s 105/14120181

Fecha

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*a ol
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1

1

1

GOVERNMENT OF THE DISTRICT OF COLUMBIA
Child and Family Services Agency
tft

r~
Request for a Child Protection Register (CPR) Check
The purpose of the Child Protection Register is to protect children and to ensure their safety by maintaining an index of
perpetrators of child abuse and neglect in the District of Columbia. This confidential index includes the names of individuals
with substantiated and/or inconclusive findings from the investigative reports of the Child Protective Services Unit of the
Child and Family Services Agency. Authorized individuals may request background checks to establish whether an individual
has a record of substantiated abuse or neglect of a child that occurred in the District of Columbia.
► To request a local police clearance for the District of Columbia, please visit https://mpdc.dc.gov/node/187552.
/ For information about the Sex Offender Registry, visit: https://mpdc.dc.gov/service/sex-offender-registry.
► If you are making a request on behalf of a state child welfare agency outside of the District of Columbia and need
the history of a family previously living in the District of Columbia, you may call 202-671-SAFE.
► For other questions, call the CPR Unit at 202-727-8885 between 8:30 am and 4:30 pm Monday through Friday.

Read all instructions — incomplete, incorrect or illegible forms will be returned and your request may be delayed
s

Do not complete an old version of the form; get the latest form at https://cfsa.dc.gov/service/bacl<ground-checl<s.

s

Mail or deliver original application (no photocopies); no faxed, emailed, or scanned applications accepted.

Part I
s Schools (other than DCPS), child care facilities, private foster care agencies, and other private, community-based
organizations should select "Non-Government Organization" as the Requestor Type.
s

CPR check results are not transferrable and cannot be shared from one agency or employer to another.

Part II
s

If you have no middle name write "no middle name" or if a middle name is an initial, indicate "initial only."

s

If the answer to any question is none, write "N/A".

Part III
s An individual must sign the form to provide consent for CFSA to release information to an authorized requestor.
s

The form must be signed in blue ink; electronic signatures are not permitted.

s

An employment request allows access to substantiated reports of child maltreatment, to chief executive officers
or directors of day care centers, schools, or any public or private organization working directly with children, for
the purpose of making employment decisions.

Part IV
s Forms shall be returned if not notarized (Note: applications for prospective and current CFSA resource parents and

kin caregivers need not be notarized, but photo ID must be provided and the form must be signed in the presence
of a CFSA employee).
Part V
s Self-check applications must be submitted in person, not by mail.
s

Individuals requesting a self-check and CFSA resource parents and kin caregivers must present one non-expired,
government-issued, photo identification: e.g., driver's license, state identification card, passport, "green card".

s

Results of CPR self-checks may not be used for employment purposes. Employers must directly request CPR
clearances for prospective or current employees.

MAIL or HAND DELIVER
completed forms to:

Attn: Child Protection Register Unit
Child and Family Services Agency
200 1 Street SE, 3rd Floor
Washington, DC 20003

Applications accepted
between 8:30 am and 4:30 pm
Monday through Friday
Rev. October 2017

Please type or print clearly. Sign the form in blue ink, and date where indicated. Thoroughly review and submit to the
CFSA CPR office. Allow up to 30 business days for results to be processed. Expedited requests will be considered on a
case-by-case basis. Forms will be returned if incomplete, incorrect, or illegible resulting in a delayed response.
PART I: Requesting Organization/Employer Information
Request Date

Corrected Application Re-submission Date

Requestor Type
u Court

u Government Agency

u Non-Government Organization

u Self (personal use only)

Purpose
u Adoption
u Visitation

7:71u Court Request
u Current Employee/Volunteer

El Foster/Adoption Licensing

I[:] New Hire/Volunteer

El Kinship Licensing

u Other:

Requesting Organization/Employer Contact Information (results cannot be mailed to a P.O. Box)
Requesting Organization

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES, PROGRAM SUPPORT CENTER, DIVISION OF CHILDREN'S SERVICES

Attention To

Cynthia Ramos

Requestor Address

5600 FISHERS LANE, ROOM 02E70, ROCKVILLE, MD 20857

Phone Number

[phone]

Fax Number

Preferred method to return CPR check results to the requesting organization

[phone]
u By Mail

u By Fax


PART II: Applicant Information
Last Name (include suffix if applicable)

Date of Birth (MM/DD/YYYY)

Full Middle Name
(write "no middle name" if there is none)

First Name

Social Security Number (or USCIS/Alien Registration #)

Gender (on birth certificate)
u Male

u Female

Other Names Used (nicknames, alias, maiden name, previous married name, legal name change, etc.)

Household Information. List all persons living at the current address with the applicant (including students away at college).
Name (first name, middle name, last name)

CPR Check Form

I

Date of Birth

obtain the latest form online at cfsa.dc.gov

I

Relationship to Applicant

Rev. October 2017 1 Page 2 of 4

Previous Residency Information. List all addresses (excluding zip code) and the start and end dates, to the best of your ability.
Indicate L, W or M in the first column (L = lived, W = worked, M = received mail).
•
•
•
•

Applicants for employment or volunteer purposes must include all addresses of residence and where mail was received for the
last five (5) years.
Applicants for adoption, foster care, and kinship care must provide addresses for residency, receipt of mail and employment
from the age of 18, per Title 29 DCMR Chapter 60 § 6009.1.
To calculate the starting date for the previous addresses, add 18 years to the date of birth (e.g., If you were born in 1970, add 18
so addresses going back to 1988 must be provided).
To help obtain previous addresses, check the credit report bureaus (Equifax, Experian, TransUnion).
Current Address (include Street #, Apt #, Quadrant if applicable) I

LWM I

Previous Address (Include Street # and Apt #)

I

City

City

I State I

I State I Start

CPR Check Form I obtain the latest form online at cfsa.dc.gov ( Rev. October 2017 1 Page 3 of 4

Zip

— End Dates

PART III: Applicant Consent
I hereby consent and authorize the D.C. Child and Family Services Agency to provide the Requestor (noted in Part 1)
information concerning me that is contained in the Child Protection Register ("CPR").
Printed Name:
Signature:

Date:

Must be signed in blue ink; electronic signatures not permitted
PART IV: Certificate of Acknowledgement of the Applicant before a Notary Public

Leave this space blank for Notary seal
Applicant Name
(Printed)

Applicant Signature
(must be signed in the presence of a Notary)

Date

Subscribed and affirmed or sworn to me, in my presence, on this

day of

Signature of Notary Public:
My commission expires on

20

in the state of,

i

PART V: Self Check, CFSA Resource Parent, and CFSA Kinship Caregiver Verification

CFSA USE ONLY: Identification has been shown to me that I have deemed satisfactorily identifies the applicant:
Type of ID

ID #

CFSA Employee Name (print)
CFSA Employee Title (print)
CFSA Employee Signature

CPR Check Form I obtain the latest form online at cfsa.dc.gov I Rev. October 2017 1 Page 4 of 4

Exhibit 37

Exhibit 38

Exhibit 39

Exhibit 40

Exhibit 41

1
2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

8
9

STATE OF WASHINGTON, et al.,
Plaintiff,

10
11
12

NO. 18-cv-00939
DECLARATION OF
EMARY C. ARONSON

v.
DONALD TRUMP in his official capacity
as President of the United States, et al.,

13

Defendants.

14
I, Emary C. Aronson, declare as follows:
15
1.

I am over the age of eighteen and have personal knowledge of all the facts stated

2.

I am Chief Program Officer for Robin Hood. I oversee Robin Hood’s grant-

16
herein.
17
18
making efforts to support nonprofit and social services in New York City. I have been employed
19
by Robin Hood since 1999.
20
3.

Robin Hood is one of New York City’s largest poverty-fighting organizations.

21
Since its founding in 1988, Robin Hood has raised more than $2.5 billion in dollars, goods and
22
services to provide for hundreds of the most effective early childhood development programs,
23
schools, legal services nonprofits, healthcare clinics, homeless shelters and other vital services
24

in our city. Robin Hood’s mission is to ensure that New York’s neediest children and families

25
have the tools they need to build better lives. Our work is based on a rigorous set of metrics that
26

DECLARATION OF
EMARY C. ARONSON

1

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

measures the relationship between the cost of an intervention and the economic and social

2

benefits it produces for the individual being served.

3

4.

Consistent with our mission is the belief that all children present in New York

4

City, regardless of nativity or immigration status, have the right to safety, to grow up in a

5

nurturing environment with their parent or guardian, to be educated, to enjoy their childhood,

6

and to receive due process in immigration proceedings.

7

5.

Robin Hood invests more than $30 million annually to support programs that

8

promote early childhood development, including initiatives focused on the crucial first 1,000

9

days of life. More than 50 years of research demonstrates that the lack of nurturing care from a

10

parent or committed caregiver, social interaction, appropriate stimulation, and psychological

11

comfort lead to a number of deleterious impacts that have lifelong consequences for children 1,2.

12

These include serious impairments to healthy development leading to cognitive delays and

13

emotional dysregulation. Moreover, adverse childhood experiences, including even the brief

14

separation of children from their parents, are directly correlated with increased risk of

15

depression, suicidality, long-term physical health problems, substance abuse disorders, and other

16

social ills3.

17

6.

Robin Hood also invests more than $5 million annually in programs that provide

18

immigration legal services. In 2013, we launched Immigrant Justice Corps, the country’s first

19

legal fellowship program focused on immigration services. That program has now served more

20

than 40,000 immigrants in four states. In 2014, we also helped establish the ICARE Coalition,

21
22
23
24
25
26

1

National Scientific Council on the Developing Child. (2012). The Science of Neglect: The Persistent
Absence of Responsive Care Disrupts the Developing Brain: Working Paper 12.
http://www.developingchild.harvard.edu
Nelson, C.A, Fox, N.A., & Zeanah, C.H. (2014). Romania’s Abandoned Children. Cambridge, MA:
Harvard University Press.
2

3

Felitti, V.J., et al. (1998). Relationship of childhood abuse and household dysfunction to many of the
leading causes of death in adults. The Adverse Childhood Experiences (ACE) Study. American Journal of
Preventative Medicine, 14(4), 245-258.

DECLARATION OF
EMARY C. ARONSON

2

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

which has provided legal counsel to nearly 1,500 Central American unaccompanied minors in

2

New York City. We make these investments because attaining legal status provides a long-term

3

pathway out of poverty for immigrants in our city. Data from the Transactional Records Access

4

Clearinghouse at Syracuse University demonstrate that legal representation in immigration

5

proceedings increases the probability of a grant of legal status by at least 400 percent. However,

6

the federal government does not appoint counsel in immigration proceedings, thereby

7

endangering immigrant children’s right to due process, diminishing the likelihood they will

8

attain legal status and permanent work authorization, and constraining their ability to contribute

9

to our society and our economy into adulthood.

10

7.

Robin Hood funds more than 200 nonprofit organizations every year. Through

11

our work, we have an intimate knowledge of the impact that shifts in federal policy can have on

12

local nonprofit operations. Without clear planning, communications, and transparent data

13

sharing in the implementation of new policies at the federal level, local social services are

14

severely disrupted. Nonprofit executives, attorneys, social workers and clinicians can be pulled

15

away from serving their regular clients to coordinate and respond to emergency needs.

16

8.

We have learned that at least 300 children who were forcibly separated from their

17

parents are currently in New York City as a result of the “zero-tolerance policy.” We have been

18

in contact with more than two dozen agencies involved in mounting a local emergency response

19

to the situation. This outreach has included federal officials, state and local government

20

agencies, foster care agencies caring for these children, nonprofit legal services providers,

21

experts on the health and mental health of young children, and national and local philanthropic

22

organizations.

23

9.

We know that organizations in New York City involved in this effort are

24

operating at the highest levels of professionalism and care for these vulnerable children.

25

However, the current situation resulting from the “zero-tolerance policy” has demanded a far

26

greater volume and type of service than historically they have been funded to provide. We have

DECLARATION OF
EMARY C. ARONSON

3

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

learned that these children, in being separated from their parents, have experienced severe

2

trauma, compounded as they have faced difficulty in contacting or being reunited with their

3

parents or caregivers. Nonprofit legal services providers do not have sufficient staffing or space

4

to provide counsel to all those in need and are having to quickly gain new expertise to be able to

5

serve children who are pre-verbal. Translation services are also lacking, particularly for those

6

who children speak indigenous Central American languages. Immigrant children are now

7

spending twice as long in foster care as they have historically, as potential sponsor families are

8

reluctant to come forward due to increased immigration enforcement activities nationwide. As

9

a result, local governments and philanthropic institutions will likely need to divert millions of

10
11

dollars to ensure an effective and humane response to the situation on the ground.
10.

We firmly believe that preserving the rights of asylum seekers, including young

12

children, as already enshrined in our laws, is vital to the fair administration of justice, to the

13

alleviation of poverty, and to our country’s economic prosperity.

14

11.

The “zero-tolerance policy” instituted at our border, which directly led to the

15

separation of children and parents, has caused irreparable social and emotional trauma to the

16

hundreds of children now in our city as well as to their families detained across the country. This

17

is not a political issue. This policy has denied them and their families their fundamental right to

18

due process, overburdened local nonprofit services providers, and increased the likelihood that

19

these vulnerable children will live their lives in poverty.

20
21
22
23
24
25
26

DECLARATION OF
EMARY C. ARONSON

4

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1
2
3
4

I declare under penalty of perjury under the laws of the State of Washington and the
United States of America that the foregoing is true and correct.
DATED this 29th day of June, 2018 at New York, New York.

5
6
7
8
9
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26

DECLARATION OF
EMARY C. ARONSON

5

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

Exhibit 42

1
2
3
4
5
6
7
8
9
10
11
12

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
STATE OF WASHINGTON, et al.
Plaintiff,

15
16
17
18
19
20
21
22
23
24
25
26

DECLARATION OF TOM K. WONG
IN SUPPORT OF PLAINTIFFS’
MOTION FOR EXPEDITED
DISCOVERY

v.
THE UNITED STATES OF AMERICA,
et al.,

13
14

NO. 2:18-CV-00939

Defendants.
I, Tom K. Wong, declare as follows:
1.

I am over the age of 18 and have personal knowledge of all the facts stated herein.

If called as a witness, I could and would testify competently to the matters set forth below.
2.

I am an Associate Professor with tenure at the University of California, San

Diego (UCSD). I work in the political science department, which is consistently ranked by U.S.
News & World Report as one of the top ten political science departments nationally. I am also
the Director of the International Migration Studies Program Minor at UCSD.
3.

I am an expert on immigration. I have written two peer-reviewed books and

several peer-reviewed journal articles, book chapters, and reports on this subject. My most recent
book analyzes 31,193 roll call votes on immigration-related legislation in Congress from 2005
to present, which makes it the most comprehensive analysis to date on contemporary
immigration policies in the United States.

DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

1

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
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4.

I received a Ph.D. in political science at the end of the 2010-2011 academic year.

I was a post-doctoral research fellow during the 2011-2012 academic year. I joined the political
science department at UCSD during the 2012-2013 academic year. I served as an advisor to the
White House Initiative on Asian Americans and Pacific Islanders (WHIAAPI), where I worked
on the immigration portfolio, during the 2015-2016 academic year. I was promoted to the rank
of Associate Professor with tenure at UCSD during the 2016-2017 academic year.
5.

I have attached a true and complete copy of my curriculum vitae as Exhibit A to

this Declaration.
6.

Data on the monthly number of U.S. Border Patrol apprehensions of family units

at the Southwest border show that recent policies intended to deter families from attempting to
enter the U.S. without authorization have not had their desired deterrent effects. The data show
that the expanded use of family detention is not statistically significantly related to decreases in
the monthly number of U.S. Border Patrol apprehensions of family units at the Southwest border.
The data also show that the use of family separation is not statistically significantly related to
decreases in the monthly number of U.S. Border Patrol apprehensions of family units at the
Southwest border; instead, U.S. Border Patrol apprehensions of family units at the Southwest
border have increased following the current administration’s “zero tolerance” pilot. Moreover,
the data show that U.S. Border Patrol apprehensions of family units at the Southwest border have
followed seasonal trends, wherein the monthly number of apprehensions increases beginning
late Winter (February and March) and continues to increase through Spring (April, May, and
June) before declining at the start Summer (July).
7.

In my first set of analyses, I evaluate changes over time in the monthly number

of U.S. Border Patrol apprehensions of family units at the Southwest border from October 2012
to May 2018.1 To the best of my knowledge, these data represent the range of publicly available
1

Data for Fiscal Year 2012 are available at (last accessed June 28, 2018):
https://www.cbp.gov/newsroom/stats/southwest-border-unaccompanied-children/fy-2016. Data for Fiscal Year
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

2

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1
2
3
4
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8
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data from U.S. Customs and Border Protection on the monthly number of U.S. Border Patrol
apprehensions of family units at the Southwest border.
8.

The method used to analyze these data is interrupted times series analysis

(ITSA).2 ITSA is a quasi-experimental research design, meaning a research design that evaluates
causal effects using observational data, that is, data that do not come from experimental research
that makes use of random assignment to control and treatment conditions. ITSA is used to
evaluate trends before, immediately following, and during the period after an intervention, such
as a policy change. ITSA estimates three main parameters: ß 1 is the slope or trajectory of the
outcome variable before the start of the policy change; ß2 is the change in the level of the outcome
variable in the period immediately following the start of the policy change; and ß3 is the effect of
the policy change over time.
9.

In response to the increase in the number of arrivals of Central American families

and unaccompanied children at the Southwest border in 2014, the Karnes County Residential
Center was converted from a civil detention facility to a family detention facility in July 2014. 3
During this time, families were also detained at a temporary facility in Artesia, New Mexico
before the South Texas Family Residential Center in Dilley, Texas opened in December 2014.
The conversion of the Karnes County Residential Center and the opening of the South Texas
Family Residential Center represented major shifts, as the use of family detention had been
largely abandoned by the Obama administration prior to 2014. 4 When delivering remarks at the
2013 to Fiscal Year 2017 are available at (last accessed June 28, 2018):
https://www.cbp.gov/sites/default/files/assets/documents/2017Dec/BP%20Total%20Monthly%20Family%20Units%20by%20Sector%2C%20FY13-FY17.pdf. Data for Fiscal
Year 2018 are available at (last accessed June 28, 2018): https://www.cbp.gov/newsroom/stats/sw-bordermigration.
2
Linden, Ariel. 2015. “Conducting interrupted time-series analysis for single- and multiple-group
comparisons.” The Stata Journal 15(2): 480-500.
3
Available at (last accessed June 28, 2018): https://www.geogroup.com/FacilityDetail/FacilityID/58.
The Karnes County Residential Center is managed by GEO Group, Inc. under an intergovernmental service
agreement with Immigration and Customs Enforcement (ICE).
4
For example, see (last accessed June 28, 2018): https://www.aclu.org/files/field_document/ACLU%20%20Family%20Detention.pdf.
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

3

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

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opening of the South Texas Family Residential Center, then Secretary Jeh Johnson stated, “I
believe this is an effective deterrent.” 5
10.

Using ITSA, I analyze the potential deterrent effect of the expanded use of family

detention on the monthly number of U.S. Border Patrol apprehensions of family units at the
Southwest border.
11.

The results are reported in Table 1 below.6 Model 1 estimates the relationship

between the expanded use of family detention, measured by the conversion of the Karnes County
Residential Center in July 2014 (ß2) and each subsequent month thereafter (ß3), and the monthly
number of U.S. Border Patrol apprehensions of family units at the Southwest border. If the
expanded use of family detention has a deterrent effect, we would expect ß2 and ß3 to be negative
and statistically significant, meaning the monthly number of U.S. Border Patrol apprehensions
of family units at the Southwest border decreases with the expanded use of family detention.
12.

In Model 1, the ß1 coefficient is positive and statistically significant, which

affirms that the monthly number of U.S. Border Patrol apprehensions of family units at the
Southwest border was increasing before July 2014. However, both the ß 2 and ß3 coefficients are
statistically insignificant, which suggests that the expanded use of family detention is not
statistically significantly related to an immediate decrease or longer-term decreases in the
monthly number of U.S. Border Patrol apprehensions of family units at the Southwest border.
Otherwise put, the data do not provide evidence to suggest that family detention has a deterrent
effect, as the monthly number of U.S. Border Patrol apprehensions of family units at the
Southwest border was increasing before July 2014, and apprehensions did not decrease in a
statistically significant way after July 2014.

24
25
26

5

Available at (last accessed June 28, 2018): http://nytimes.com/2014/12/16/us/homeland-security-chiefopens-largest-immigration-detention-center-in-us.html.
6
An autoregressive model AR(1) is specified and Newey-West standard errors are used to address
autocorrelation.
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

4

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1

Table 1

2

Model 1
ß1 Pre July 2014
227.9**
(88.27)
ß2 July 2014
-2,708.1
(2,002.46)
ß3 Post July 2014
-140.5
(97.38)
ß0 Constant
-1,179.1
(1,037.25)
Observations
80

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22

Note: eight additional models were run specifying eight different pseudo-interventions, which all
produce qualitatively similar results. * significant at the .05 level; ** significant at the .01 level; ***
significant at the .001 level.

13.

Moreover, eight additional models were run specifying eight different pseudo-

interventions, meaning different start dates for the expanded use of family detention. These
pseudo-interventions address the possibility that policy changes need time to take effect. The
pseudo-interventions analyzed include the months shortly after the conversion of the Karnes
County Residential Center, the month of the opening of the South Texas Family Residential
Center, and the three months after the opening of the South Texas Family Residential Center.7
These models produce qualitatively similar results, wherein the expanded use of family detention
is not statistically significantly related to decreases in the monthly number of U.S. Border Patrol
apprehensions of family units at the Southwest border.
14.

Recent events provide a second intervention to test. Beginning in July 2017, as

reported by the New York Times 8 and by Vox,9 the Trump administration piloted a zero tolerance
policy, wherein all persons caught attempting to enter the U.S. without authorization are referred
to the Department of Justice for prosecution, including parents who are apprehended with their

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26

7

These models specify the intervention as August 2014, or September 2014, or October 2014, or
November 2014, or December 2014, or January 2015, or February 2015, or March 2015.
8
Available at (last accessed June 28, 2018): https://www.nytimes.com/2018/04/20/us/immigrantchildren-separation-ice.html.
9
Available at (last accessed June 28, 2018): https://www.vox.com/policy-andpolitics/2018/5/8/17327512/sessions-illegal-immigration-border-asylum-families.
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

5

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

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children. As it relates to family units, in prosecuting all persons caught attempting to enter the
U.S. without authorization, children have been separated from their parents. Whereas the Obama
administration used family detention in response to Central American families and
unaccompanied children arriving at the Southwest border, the Trump administration has used
family separation. In March 2017, in response to the question of whether the Trump
administration was going to separate children from their parents, current White House Chief of
Staff and then Department of Homeland Security Secretary John F. Kelly stated, “Yes, I am
considering, in order to deter more movement along this terribly dangerous network [migrating
from Central America through Mexico to the U.S.], I am considering exactly that.” 10 As recently
as June 2018, Attorney General Jeff Sessions reiterated the administration’s belief in the
deterrent effect of family separation stating, “We cannot and will not encourage people to bring
their children or other children to the country unlawfully by giving them immunity in the
process.”11
15.

Using ITSA, I analyze the deterrent effect of family separation on the monthly

number of U.S. Border Patrol apprehensions of family units at the Southwest border.
16.

The results are reported in Table 2 below. 12 Model 2 estimates the relationship

between the use of family separation, measured by the beginning of the zero tolerance pilot in
July 2017 (ß4) and each subsequent month thereafter (ß 5), and the monthly number of U.S.
Border Patrol apprehensions of family units at the Southwest border while controlling for the
expanded use of family detention in July 2014.
10

Available at (last accessed June 28, 2018):
https://twitter.com/CNNSitRoom/status/838877868453064704?ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembe
d%7Ctwterm%5E838877868453064704&ref_url=http%3A%2F%2Fwww.businessinsider.com%2Fkellyproposed-family-separation-to-deter-illegal-immigration-in-2017-2018-6.
11
Available at (last accessed June 28, 2018):
https://twitter.com/NBCNews/status/1008736238495559680?ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembed
%7Ctwterm%5E1008736238495559680&ref_url=http%3A%2F%2Fthehill.com%2Fhomenews%2Fadministratio
n%2F392785-sessions-on-separating-families-if-we-build-a-wall-and-pass.
12
An autoregressive model AR(1) is specified and Newey-West standard errors are used to address
autocorrelation.
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

6

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

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17.

affirming that the monthly number of U.S. Border Patrol apprehensions of family units at the
Southwest border was increasing before July 2014. Both the ß 2 and ß3 coefficients remain
statistically insignificant, also affirming the results in Model 1. The ß 4 coefficient is statistically
insignificant, which suggests that family separation is not statistically significantly related to an
immediate decrease in the monthly number of U.S. Border Patrol apprehensions of family units
at the Southwest border. Unexpectedly, the ß5 coefficient is positive and highly statistically
significant, which means that instead of a deterrent effect, the monthly number of U.S. Border
Patrol apprehensions of family units at the Southwest border has increased significantly after
July 2017. Otherwise put, the data do not provide evidence to suggest that family separation has
a deterrent effect, as the monthly number of U.S. Border Patrol apprehensions of family units at
the Southwest border has increased after July 2017, not decreased.
Table 2

14

Model 2
ß1 Pre July 2014
227.9**
(88.27)
ß2 July 2014
-3,090.3
(2,165.09)
ß3 Post July 2014 -105.83
(134.39)
ß4 July 2017
-4,093.9
(2,469.00)
ß5 Post July 2017 464.6***
(115.03)
ß0 Constant
-1,179.1
(1,051.17)
Observations
80

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In Model 2, the ß1 coefficient remains positive and statistically significant, again

Note: seven additional models were run specifying seven different pseudo-interventions, which all
produce qualitatively similar results. * significant at the .05 level; ** significant at the .01 level; ***
significant at the .001 level.

18.

Moreover, seven additional models were run specifying seven different pseudo-

interventions. To recall, these pseudo-interventions address the possibility that policy changes
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

7

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

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need time to take effect. The pseudo-interventions analyzed include the months during the zero
tolerance pilot after July 2017 (August 2017 to November 2017), as well as the three months
after the zero tolerance pilot. 13 These models produce qualitatively similar results, wherein
instead of a deterrent effect, the monthly number of U.S. Border Patrol apprehensions of family
units at the Southwest border has increased significantly after the zero tolerance pilot, not
decreased.
19.

In my last set of analyses, I turn to the more rigorous Autoregressive Integrated

Moving Average (ARIMA) interrupted time series method. ARIMA is the primary method of
analyzing quasi-experimental time series data. The ARIMA interrupted time series method
removes time trends (the “noise”) in order to isolate the impact of an intervention, such as a
policy change (the “signal”). ARIMA modeling begins by identifying and removing noise,
meaning the extent to which the data in a time series can be accurately predicted by time itself
(for example, addressing the extent to which the number of U.S. Border Patrol apprehensions of
family units at the Southwest border in one month can be accurately predicted by the number of
apprehensions during the previous month [autocorrelation] or the extent to which the number of
U.S. Border Patrol apprehensions of family units at the Southwest border in one month can be
accurately predicted by the number of apprehensions during the same month in a previous year
[seasonality]). After identifying and removing noise, this allows us to evaluate the extent to
which an intervention has an effect on our outcome of interest that is independent from
underlying time trends. Otherwise put, this allows us to evaluate whether policy changes such as
the expanded use of family detention or the use of family separation more accurately predict the
monthly number of U.S. Border Patrol apprehensions of family units at the Southwest border
than seasonal patterns or other time trends.

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13

These models specify the intervention as August 2017, or September 2017, or October 2017, or
November 2017, or December 2017, or January 2018, or February 2018.
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

8

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1
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20.

ARIMA modeling is important for our purposes here given the data on the

monthly number of U.S. Border Patrol apprehensions of family units at the Southwest border
exhibit seasonal trends. The figure below is a stacked line graph that shows the cumulative
number of U.S. Border Patrol apprehensions of family units at the Southwest border by month
from 2012 to 2017.14 As the figure shows, a strong seasonal trend emerges in 2014, wherein the
monthly number of U.S. Border Patrol apprehensions of family units at the Southwest border
increases beginning late-Winter (February and March) and continues to increase through Spring
(April, May, and June) before declining at the start Summer (July). The figure also shows that a
second peak may be emerging in Fall (October, November, December), however, it is too soon
to tell if this trend will hold given 2017 was the first year in the time series that we saw large
numbers of U.S. Border Patrol apprehensions of family units during these months.
Figure 1

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14

These are the years in the time series for which monthly data on U.S. Border Patrol apprehensions of
family units at the Southwest border are available for all of the months in the year.
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

9

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1
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21.

3 shows that after identifying and removing time trends, 15 there is no statistically significant
relationship between the expanded use of family detention, measured by the conversion of the
Karnes County Residential Center in July 2014, and the monthly number of U.S. Border Patrol
apprehensions of family units at the Southwest border. Model 4 shows that after identifying and
removing time trends, 16 there is no statistically significant relationship between family
separations, measured by the beginning of the zero tolerance pilot in July 2017, and the monthly
number of U.S. Border Patrol apprehensions of family units at the Southwest border. Model 5,
which includes both interventions, produces qualitatively similar results. 17
Table 3
Model 3
Model 4
Model 5
ARIMA(1,1,0) ARIMA(1,1,0) ARIMA(1,1,0)
-.135
-.173
July 2014
(.135)
(.135)
.101
.178
July 2017
(.197)
(.196)
Observations
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79

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Note: fifteen additional models were run specifying fifteen different pseudo-interventions, which all
produce qualitatively similar results.

Conclusion
22.

attempting to enter the U.S. without authorization have not had their desired deterrent effects.
•

26

As the data show, the expanded use of family detention is not statistically
significantly related to decreases in the monthly number of U.S. Border Patrol
apprehensions of family units at the Southwest border. This result is robust when

23

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Altogether, data on the monthly number of U.S. Border Patrol apprehensions of

family units at the Southwest border shows that recent policies intended to deter families from

22

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Table 3 reports the results of the ARIMA interrupted times series analysis. Model

15

The dependent variable in Model 3 is the first order difference of the natural log of the monthly
number of U.S. Border Patrol apprehensions of family units at the Southwest border.
16
The dependent variable in Model 4 is also the first order difference of the natural log of the monthly
number of U.S. Border Patrol apprehensions of family units at the Southwest border.
17
These results are also robust when testing the range of pseudo-interventions described above.
DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

10

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1

testing eight pseudo-interventions and when using ARIMA interrupted time series

2
3
4

analysis.
•

related to decreases in the monthly number of U.S. Border Patrol apprehensions of

5

family units at the Southwest border; instead, U.S. Border Patrol apprehensions of

6

family units at the Southwest border have increased following the zero tolerance

7

pilot. This result is robust when testing seven pseudo-interventions and when using

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As the data also show, the use of family separation is not statistically significantly

ARIMA interrupted time series analysis.
•

Moreover, the data show that U.S. Border Patrol apprehensions of family units at the
Southwest border has followed seasonal trends, wherein the monthly number of
apprehensions increases beginning late Winter (February and March) and continues
to increase through Spring (April, May, and June) before declining at the start
Summer (July).

I declare under penalty of perjury under the laws of the State of California and the United
States of America that the foregoing is true and correct.
DATED this 29th day of June, 2018 at San Diego, California.

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TOM K. WONG

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DECLARATION OF TOM K. WONG IN
SUPPORT OF PLAINTIFFS’ MOTION
FOR EXPEDITED DISCOVERY

11

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

EXHIBIT A

Wong: CV (1/2018)

TOM K. WONG, PH.D.

Email: [e-mail] | Google Voice: [phone]
Website: www.tomwongphd.com | bit.ly/tomkwong_citations

ACADEMIC APPOINTMENTS
2017 -

ASSOCIATE PROFESSOR, POLITICAL SCIENCE
University of California, San Diego

2012 - 2017

ASSISTANT PROFESSOR, POLITICAL SCIENCE
University of California, San Diego

OTHER POSITIONS
2013 -

DIRECTOR, INTERNATIONAL MIGRATION STUDIES PROGRAM MINOR
University of California, San Diego

2016

ADVISOR, IMMIGRATION PORTFOLIO
WHITE HOUSE INITIATIVE ON ASIAN AMERICANS AND PACIFIC ISLANDERS

EDUCATION
2011

PH.D. IN POLITICAL SCIENCE
University of California, Riverside
Focus in Comparative Politics, International Relations, and Research Methods
Dissertation: Immigration Control in the Age of Migration

2005

B.A. IN POLITICAL SCIENCE
University of California, Riverside
Focus in International Relations
Magna Cum Laude

BOOKS
(2) Tom K. Wong. 2017. The Politics of Immigration: Partisanship, Changing Demographics, and American National
Identity. Oxford University Press.
NPR, ABC News/Yahoo.com, LA Times, Univision, Monkey Cage
(1) Tom K. Wong. 2015. Rights, Deportation, and Detention in the Age of Immigration Control. Stanford University
Press. Oxford Law blog

JOURNAL ARTICLES
(7) Tom K. Wong, Angela Garcia, and Carolina Valdivia. 2018. “The Political Incorporation of
Undocumented Youth,” Social Problems.
(6) Tom K. Wong and Hillary Kosnac. 2017. “Does the Legalization of Undocumented Immigrants in the US
Encourage Unauthorized Immigration from Mexico? An Empirical Analysis of the Moral Hazard of
Legalization,” International Migration vol. 55 no. 2: 159-173.

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Wong: CV (1/2018)

(5) Tom K. Wong and Angela Garcia. 2016. “Does Where I Live Affect Whether I Apply? The Contextual
Determinants of Applying for Deferred Action for Childhood Arrivals (DACA),” International
Migration Review vol. 50 no. 3: 699-727.
C-Span, Associated Press
(4) Tom K. Wong, Donald Kerwin, Jeanne M. Atkinson, and Mary Meg McCarthy. 2014. “Paths to Lawful
Immigration Status: Results and Implications from the PERSON Survey,” Journal of Migration and
Human Security vol. 2 no 4: 287-304.
NBC News.com
(3) Tom K. Wong. 2014. “The Politics of Interior Immigration Enforcement,” California Journal of Politics and
Policy vol. 6 no 3: 381-399.
(2) Tom K. Wong and Justin Gest. 2013. “Organizing Disorder: Indexing Migrants’ Rights and International
Migration Policy,” Georgetown Immigration Law Journal vol. 28 no 1: 257-269.
(1) Tom K. Wong. 2012. “The Politics of Interior Immigration Control in the United States: Explaining Local
Cooperation with Federal Immigration Authorities,” Journal of Ethnic and Migration Studies vol. 38 no.
5: 737-756.

BOOK CHAPTERS
(4) Tom K. Wong. 2014. “Conceptual Challenges and Contemporary Trends in Immigration Control.” In
Controlling Immigration: A Global Perspective (3rd edition), edited by James F. Hollifield, Philip Martin,
and Pia Orrenius. Stanford University Press.
(3) Tom K. Wong. 2014. “Nation of Immigrants or Deportation Nation? Analyzing Deportations and
Returns in the United States, 1892-2010.” In The Nation and Its Peoples: Citizens, Denizens, and Migrants,
edited by John S.W. Park and Shannon Gleeson. Routledge.
(2) James F. Hollifield and Tom K. Wong. 2014. “The Politics of International Migration: How Can We
‘Bring the State Back In’?” In Migration Theory: Talking Across Disciplines (3rd edition), edited by
Caroline B. Brettell and James F. Hollifield. Routledge.
(1) Karthick Ramakrishnan and Tom K. Wong. 2010. “Partisanship, Not Spanish: Explaining Municipal
Ordinances Affecting Undocumented Immigrants.” In Taking Local Control: Immigration Policy Activism
in U.S. Cities and States, edited by Monica W. Varsanyi. Stanford University Press.

WORKS UNDER REVIEW/IN PROGRESS (SELECTED LIST)
Tom K. Wong and Justin Gest. “Looks Skin Deep: Do Immigrant Legislators Better Represent Immigrant
Interests?”
Tom K. Wong and Carolina Valdivia. “In Their Own Words: A Nationwide Survey of Undocumented
Millennials,” Working Paper 191, Center for Comparative Immigration Studies.
New York Times, Washington Post, The Hill, La Opinión, Univision, NBC News.com
Tom K. Wong. “President Obama’s Executive Actions on Immigration and the 2016 Presidential Election.”
This project uses a nationally representative survey of Latinos (n = 820) and Asians (n = 950) fielded
in late to analyze how knowing someone who is undocumented and potentially eligible for legal

ii

Wong: CV (1/2018)

status via programs like DAPA affects the civic engagement of Latino and Asian citizens. The survey
was fielded by GfK and commissioned w/Dan Hopkins and Efren Perez.
Tom K. Wong. “Mobilizing Low-Propensity Voters of Color” and “Governing Diversity.” These projects
examine how demographic changes are reshaping the American electorate and how policymakers are
responding. The former project includes multiple voter mobilization experiments utilizing direct
voter contact run during the 2016 presidential cycle. These experiments analyze interventions
designed to convey the urgency of voting to Latino, Asian, and immigrant-origin voters using
political discourse around immigration policy and refugee admissions.
w/Justin Gest. “International Migrants Bill of Rights.” This project aims to create cross-national indicators
on government respect for and recognition of the human rights of migrants. Funding from the
World Bank (obtained by Gest) will be used to pilot a 58 item index across 5 countries.

REPORTS
Tom K. Wong et al. 2017. DACA Recipients’ Economic and Educational Gains Continue to Grow. Washington,
D.C.: Center for American Progress.
Tom K. Wong. 2017. The Effects of Sanctuary Policies on Crime and the Economy. Washington, D.C.: Center for
American Progress.
Tom K. Wong et al. 2016. New Study of DACA Beneficiaries Shows Positive Economic and Educational Outcomes.
Washington, D.C.: Center for American Progress.
Tom K. Wong et al. 2015. Results from a Nationwide Survey of DACA Recipients Illustrate the Program’s Impact.
Washington, D.C.: Center for American Progress.
Tom K. Wong. 2014. Statistical Analysis Shows that Violence, Not Deferred Action, Is Behind the Surge of
Unaccompanied Children Crossing the Border. Washington, D.C.: Center for American Progress.
Tom K. Wong et al. 2013. Undocumented No More: A Nationwide Analysis of Deferred Action for Childhood Arrivals
(DACA). Washington, D.C.: Center for American Progress.
C-Span, Associated Press

OTHER PUBLICATIONS
Tom K. Wong. 2017. “The Effects of Sanctuary Policies on Crime and the Economy,” Migration and
Citizenship: Newsletter of the American Political Science Association Organized Section on Migration and
Citizenship vol. 5 no. 2.
James F. Hollifield and Tom K. Wong. 2012/2013. “International Migration: Cause or Consequence of
Political Change,” Migration and Citizenship: Newsletter of the American Political Science Association Organized
Section on Migration and Citizenship vol. 1 no. 1.
Tom K. Wong. 2012. “The Commission on Wartime Relocation and Internment of Civilians.” In The
Encyclopedia of Transitional Justice, edited by Lavina Stan and Nadya Nedelsky. Cambridge University
Press.
Karthick Ramakrishnan, Dino Bozonelos, Louise Hendrickson, and Tom K. Wong. 2008. “Inland Gaps:
Civic Inequalities in a High Growth Region,” Policy Matters vol 2 no 1.
iii

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Karthick Ramakrishnan and Tom K. Wong. 2007. “Immigration Policies Go Local: The Varying Responses
of Local Governments to Undocumented Immigration.” Chief Justice Earl Warren Institute on Race,
Ethnicity, and Diversity. Working Paper Series on Immigration.

RESEARCH GRANTS (AS A FACULTY MEMBER)
•
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•

$341,127, Multiple Funders, “U.S. Immigration Policy in the 21 st Century,” 2017-2019
$22,500, UCSD USMEX Fellowship, 2016-2017
$16,000, UCLA Institute for Research on Labor and Employment, 2015-2016
$365,000, MacArthur Foundation, 2015-2017 (partially awarded, terminated after the DAPA program was
enjoined by the Supreme Court)
$25,000, UCSD Frontiers of Innovation Scholars Program Grant, 2015-2016
$15,000, UCSD Faculty Career Development Program Grant, 2014-2015
$30,000, Unbound Philanthropy, 2014
$100,000, Department of Homeland Security, 2013
$30,000, Center for American Progress, 2013
$10,000, UCSD Center for International, Comparative, and Area Studies Grant, 2013
$10,000, UCSD Academic Senate, 2013
$1,500, UCSD Diversity, Equity, and Inclusion Grant, 2013

TEACHING AT UCSD
•
•
•
•
•
•

Diversity, Equity, and Inclusion Teaching Award, 2014-2015
The Politics of Immigration (upper-division, 280 students)
International Human Rights Law: Rights of Migrants (upper-division, 200 students)
The Politics of Multiculturalism (upper-division, 100 students)
Immigration Politics and Policy (graduate seminar, 4 students)
Undergraduate Honors Seminar (upper-division, 15 students)

INVITED PRESENTATIONS (SELECTED)
2018 |

“Surveying Undocumented Immigrants.” UC Berkeley, June 12, 2018.
“The Integration of DACA Recipients.” Scripps College, May 3, 2018.
“The Impact of the Trump Administration’s Immigration Policies on Undocumented
Immigrants: Evidence from Survey Experiments.” Race, Ethnicity, and Politics Workshop,
Northwestern University, April 13, 2018.
“Immigrant Political Incorporation.” UC Migration Conference, UCSD, March 2, 2018.
“The Future of DACA.” Columbia University, February 22, 2018.
“Immigration and DACA in the Age of Uncertainty, Middlebury College, February 20, 2018.

iv

Wong: CV (1/2018)

2017 |

“The Future of U.S. Immigration Policy in the Age of Trump.” Citizenship and Equality
Colloquium, University of Colorado, November 16, 2017.
“The Determinants and Effects of Sanctuary Policies.” Cornell University, November 9-10,
2017.
“The Determinants and Effects of Sanctuary Policies.” Presentation at the 2017 APPAM
Fall Research Conference, Chicago, IL, November 2-4, 2017.
“Immigration and the U.S. Constitution.” Seminar at the Robert H. Smith Center for the
Constitution at James Madison’s Montpelier, Orange, VA, July 31-August 2, 2017.
“The Determinants of U.S. Immigration Policy.” University of California, Santa Barbara,
June 1, 2017.
“Paths to Legal Status for Undocumented Immigrants.” Presentation at the CLINIC annual
conference, Atlanta, GA, May 25, 2017.
“The Effects of Sanctuary Policies on Crime and the Economy.” Presentation at the
Sanctuary Cities Convening, New York City Council, New York, NY, March 27-28, 2017.
“The Future of U.S. Immigration Policy in the Age of Trump.” Yankelovich Center for
Social Science Research, University of California, San Diego, March 15, 2017.
“Child Migration.” World Migration Report workshop, International Organization for
Migration (IOM) Geneva, Switzerland, March 9-10, 2017.
“The Politics of Immigration.” American Academy of Arts and Sciences, San Diego
Program Committee, University of California, San Diego, February 9, 2017.

2016 |

“Post-Election Panel.” Center for Comparative Immigration Studies (CCIS), University of
California, San Diego, November 21, 2016.
“Mobilizing Immigrant Communities in the Age of Trump.” Tulane University, October 14,
2016.
“Immigrant Integration and the Obama Administration: DACA, DAPA, and Implications
for the 2016 Presidential Election.” Institute for Research on Labor and Employment,
UCLA, April 28, 2016.
“Mobilizing Low-Propensity Voters of Color: Towards an Electorate That Reflects a
Changing America.” Presentation at the Asian Americans Advancing Justice conference, Los
Angeles, CA, March 31, 2016.
“Immigrants in American Society.” Presentation at KPBS, San Diego, CA, March 21, 2016.
“Immigration Policy.” Presentation to Mi Familia Vota, Riverside, CA, January 14, 2016.

2015 |

“The European Refugee Crisis.” Center for Comparative Immigration Studies (CCIS), the
European Studies Program, the Lifelong Learning Program of the EU, and the Scholars
Strategy Network (SSN), University of California, San Diego, October 27, 2015.

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Wong: CV (1/2018)

“U.S. Immigration Politics and the 2016 Presidential Election.” Presentation at the Wilson
Center, Washington DC, October 26, 2015.
“The Political Incorporation of Undocumented Youth.” Presentation at the “Challenging
Borders” conference, University of California, Riverside, October 23, 2015.
“The Consequences of Inequality: Why Does it Matter and How.” Symposium on Capital in
the 21st Century with Thomas Piketty, University of California, San Diego, October 22,
2015.
“U.S. Immigration Politics and Policy.” Presentation at the U.S. Consulate in Tijuana,
October 13, 2015.
“UC National Summit on Undocumented Students.” University of California Office of the
President, May 7-8, 2015.
“Irregular Migration.” Presentation at the “Politics and Policies of International Migration:
Europe and the U.S.” conference, Université Libre de Bruxelles, Belgium, April 28-29, 2015.
“Opportunities and Limits of the Executive Actions Proposed by President Obama.”
Presentation at the Mexican Ministry of Foreign Affairs, Mexico City, Mexico, April 13-14,
2015.
“Administrative Relief Implementation and Impact Project.” Presentation at the Center for
Migration Studies (CMS), New York, NY, March 25, 2015.
“Research Roundtable.” Presentation at the “Ready America: Implementing Immigration
Action” conference, Washington DC, February 9-11, 2015.
2014 |

“Insights from Implementing DACA for Administrative Relief.” Presentation at the
National Immigrant Integration Conference, Los Angeles, CA, December 16, 2014.
“Deferred Action for Childhood Arrivals.” American Immigration Council (AIC),
Washington, D.C., November 7, 2014.
“Immigration Policy and the November 2014 Midterm Elections.” California Immigrant
Policy Center (CIPC), October 29, 2014.
“The Many Paths to Legal Status: Results and Implications from the PERSON Survey.”
Presentation to the Center for Migration Studies (CMS), New York, NY, September 29,
2014.
“The Congressional Politics of Interior Immigration Enforcement.” Presentation at the
“Migration During Economic Downturns” workshop, German Historical Institute,
Washington, DC, April 4-5, 2014.
“Mapping DACA Renewals.” Presentation to U.S. Citizenship and Immigration Services
(USCIS), March 13, 2014.
“Latino Politics: Left, Right, or Down the Middle?” Presentation at the Hispanic Radio
annual conference, San Diego, CA, March 10, 2014.

vi

Wong: CV (1/2018)

2013 |

“Undocumented No More: A Nationwide Analysis of Deferred Action for Childhood
Arrivals.” Center for Comparative Immigration Studies (CCIS), University of California, San
Diego, October 2, 2013.
“DACA Turns 1.” Presentation at the Center for American Progress, Washington, DC,
August 15, 2013. [Televised on CSPAN]
“The Prospects for Comprehensive Immigration Reform.” Presentation at the Mexican
Ministry of Foreign Affairs, Mexico City, Mexico, August 12, 2013.
“A Look at the Stats: How Will Congressional Representatives Vote on Comprehensive
Immigration Reform?” Presentation at the “Changing Face of America” conference,
University of California, Berkeley, May 3, 2013.
“Will Comprehensive Immigration Reform Pass? Predicting Legislative Support and
Opposition to CIR.” Center for Comparative Immigration Studies (CCIS), Univeristy of
California, San Diego, April 29, 2013.
“Race, Ethnicity, the 2012 Elections, and the Politics of Comprehensive Immigration
Reform.” Presentation at the Beyond the Headlines speaker series, UCLA, February 26, 2013.
“International Migrants Bill of Rights (IMBR) Initiative.” Georgetown Law School,
Washington, DC, February 8-9, 2013.

2012 |

“Immigration Policy After the 2012 Elections.” Center for the Study of International
Migration, UCLA, November 16, 2012.
“PBS Need to Know 2012 Election Special: America by the Numbers.” Presentation for
KPBS at the Jo and Vi Jacobs Center, San Diego, CA, October 10, 2012.
“Immigrants in American Society.” Presentation at the U.S. Citizenship and Immigration
Services (USCIS) field office, Dallas, TX, March 6, 2012.

2011 |

“The Radical Right and the Politics of Immigration Control in Europe.” University of
Neuchâtel, Switzerland, June 16-17, 2011.
“Conceptual Challenges and Contemporary Trends in Immigration Control.” Presentation at
the “Immigration Policy in an Era of Globalization” conference at the Federal Reserve Bank
of Dallas, TX, May 18-20, 2011.
“Enforcing Like a State: A Mixed-Methods Study of the Politics of Immigration Control.”
Presentation at the University of California Center for New Racial Studies conference,
UCLA, April 21, 2011.
“Immigration Enforcement in the Age of Obama.” Center for Ideas and Society, University
of California, Riverside, March 8, 2011.

2010 |

“The Politics and Determinants of Immigration Control: Evidence from 25 ImmigrantReceiving Democracies.” Department of Political Science and the Center for Research on
Immigration, Population, and Public Policy, University of California, Irvine, December 1,
2010.

vii

Wong: CV (1/2018)

“States, Irregular Migrants, and a Theory of Selective Immigration Control: Evidence from
European Gateway Cities.” Presentation at the “Beyond Arizona: Laws Targeting
Immigrants in the US and Europe” conference at the Warren Institute on Race, Ethnicity,
and Diversity, University of California, Berkeley, October 25, 2010.
2009 |

“Immigration Control in Industrialized Democracies: What Explains Their Variations.”
Presentation at Metropolis, an initiative of Citizenship and Immigration Canada, Ottawa,
Canada, December 2, 2009.

PROFESSIONAL ACTIVITIES
•

•
•
•
•
•
•
•
•
•
•
•
•

Reviewer: American Journal of Political Science, American Politics Research, Du Bois Review, International
Migration, International Migration Review, International Studies Quarterly, Journal of Ethnic & Migration Studies,
Journal of Politics, Journal of Race, Ethnicity, and Politics, Law & Social Inquiry, National Science Foundation,
Political Research Quarterly, Russell Sage Foundation, Social Identities, Social Problems
Advisory Board, Center for Comparative Immigration Studies (CCIS), 2012-present
Advisory Board, Integrated Voter Engagement study, 2016-present
Advisory Board, Unbound Philanthropy, 2015-2017
APSA, Executive Committee, Migration and Citizenship Section, Treasurer, 2012-2015
APSA, Migration and Citizenship Section Program Co-Chair, 2018
Editorial Board, Journal of Migration and Human Security (JMHS), 2014-present
Editorial Board, Politics, Groups, and Identities (PGI), 2016-present
Executive Committee, Center for Comparative Immigration Studies (CCIS), 2015-present
Member, California Census Complete Count Committee, 2018-present
MPSA, International Relations and Domestic Politics Section Program Chair, 2016
WPSA, (Im)Migration and Citizenship Section Program Chair, 2015, 2017
WPSA, Dissertation award committee, 2016

viii

Exhibit 43

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
STATE OF WASHINGTON, STATE OF
CALIFORNIA, et al.

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Plaintiffs,
V.

NO. 2:18-CV-00939
DECLARATION OF MARK
GREENBERG IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

THE UNITED STATES OF AMERICA,
et al.,
Defendants.

12
13

I, Mark Greenberg, declare as follows:

14

1.

I am over the age of 18 and have personal knowledge of all the facts stated

15

herein. I joined the Migration Policy Institute (MPI) as a Senior Fellow in July 2017. My work

16

focuses on the intersections of migration policy with human services and social welfare

17

policies. From 2009-17, I worked at the Administration for Children and Families (ACF) in the

18

U.S. Department of Health and Human Services. I served as ACF Deputy Assistant Secretary

19

for Policy from 2009-13; Acting Commissioner for the Administration for Children, Youth,

20

and Families from 2013-15; and Acting Assistant Secretary from 2013-17. ACF includes the

21

Office of Refugee Resettlement (ORR), which has responsibility for the refugee resettlement

22

and unaccompanied children program. Previously, I was Executive Director of the Georgetown

23

Center on Poverty, Inequality, and Public Policy, a joint initiative of the Georgetown Law

24

Center and Georgetown Public Policy Institute. In addition, I was Executive Director of the

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Center for American Progress' Task Force on Poverty, and the Director of Policy for the

26

Center for Law and Social Policy (CLASP). I am a graduate of Harvard College and Harvard
DECLARATION OF MARK
GREENBERG IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

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Law School.

If called as a witness, I could and would testify competently to the matters set

forth below.
2.

MPI is an independent, nonpartisan, nonprofit think tank in Washington, DC

dedicated to analysis of the movement of people worldwide. MPI provides analysis,
development, and evaluation of migration and refugee policies at local, national, and
international levels. It aims to meet the demand for pragmatic and thoughtful responses to the
challenges and opportunities that large-scale migration, whether voluntary or forced, presents
to communities and institutions in an increasingly integrated world.
3.

During the time that I was Acting Assistant Secretary of the Administration for

Children and Families (ACF), from October 2013-January 2017, I worked very closely with
the Office of Refugee Resettlement (ORR) on many issues concerning the Unaccompanied
Alien Children Program. I worked with both ORR leadership and staff on issues of program
administration and policy development and met with ORR leadership on a weekly or biweekly
basis and frequently talked or corresponded with program leadership or staff numerous times
each day. To the best of my recollection, I visited the Border at least five times during this
period, visiting shelters and talking with shelter staff, program staff, and children. In addition
to visiting shelters in Texas, I also visited shelters in California and New York while at ACF. I
frequently met with colleagues from Customs and Border Protection (CBP) and Immigration
and Customs Enforcement (ICE) and other parts of the Department of Homeland Security,
along with colleagues from the Department of Defense and other federal agencies on aspects of
inter-agency coordination. I testified before Senate Committees or Subcommittees four times
concerning the Unaccompanied Alien Children Program during my time as Acting Assistant
Secretary.
4.

Throughout my tenure as ACF Acting Assistant Secretary, it was always my

understanding, and I repeatedly stated, that the Unaccompanied Alien Children Program at

DECLARATION OF MARK
GREENBERG IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

2

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

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ORR was a program designed to provide shelter and services to children who arrived at the
border unaccompanied by a parent or guardian. It is a program with detailed policies to
address the circumstances and needs of children arriving unaccompanied. However, to my
knowledge, the program has no policies or procedures to address the distinct needs and
circumstances or reunification procedures for children who the U.S. government has separated
from their parents, because that was not a purpose of the program before the Zero Tolerance
policy was established.
5.

In the ordinary operation of the Unaccompanied Alien Children Program,

children who arrive at the border unaccompanied are apprehended by CBP and placed in CBP
custody until they can be transported to a shelter of a grantee or contractor of the Office of
Refugee Resettlement. When they arrive at an ORR shelter, they receive a medical screening
and a set of services, including health, mental health, education, case management, recreation,
legal screenings, access to religious observances, and other services in accordance with the
requirements of the Flores v. Reno consent agreement. While at the shelter, efforts are made to
determine if the child has a parent, relative or family friend - referred to as a sponsor - with
whom the child can live while awaiting their immigration proceedings. In accordance with
applicable law, efforts are made to place the child in the least restrictive setting in the best
interest of the child, giving consideration to risk of danger to self or others and risk of flight.
6.

The policies governing the sponsorship process have historically sought to

strike an appropriate balance between the importance of ensuring that sponsor placements are
safe and appropriate, and the need to help children move from a shelter to a parent, relative or
family friend as rapidly as is prudent, in light of both requirements of the law and the
recognition that the best interest of children is to be with their parent, and if that is not possible
with a relative or if necessary a family friend who can care for them in a non-institutional
setting.

DECLARATION OF MARK
GREENBERG IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

3

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

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7.

Like millions of Americans, I was deeply concerned when I learned about the

US Government policy of separating parents and children and sending the children to ORR
custody. In addition, I was concerned about the use of ORR Unaccompanied Alien Children
shelters for this purpose, because as the former Assistant Secretary, based on my experience, I
believe that using the shelters to facilitate family separation is antithetical to the basic goals
and mission of the program. In addition to causing pain for separated families and children, I
believe this is likely to create highly stressful work environments for staff in shelters, insofar as
they are being asked to perfonn a function that is virtually the opposite of their customary role
of working to reunify children with parents, relatives, and family friends. Moreover, staff are
being required to respond to the needs of young and in some instances very young children
who are likely to be disconsolate because they do not know where their parent is and why their
parent is not with them. I believe the stressful environment is likely to be detrimental to the
basic operation of the shelters. The shelters are under additional pressures because of the large
numbers of separated children referred to ORR custody within a short period of time.
8.

From multiple media accounts, it is my understanding that in many cases,

parents do not know where their child is, and children do not know where their parent is. I am
frankly baffled as to how such a situation has come to be. I do not know the details of the
current internal planning process for the Office of Refugee Resettlement, but I do understand
that when a child is referred to ORR by CBP, there is normally narrative infonnation provided
at that time concerning the circumstances of the child's apprehension. If this information
included the statement that the parent and child were separated, it should then have been a
straightforward matter for ORR to communicate back to CBP and ICE providing information
about the location of the child.
9.

I have also seen multiple media accounts of difficulties parents are having

communicating with their child. I am aware that under the ORR Policy Guide, available at

DECLARATION OF MARK
GREENBERG IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

4

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

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https://www.acf.hhs.gov/orr/resource/children-entering-the-united-states-unaccompanied­
section-3#3.3.10, shelters must allow children a minimum of two ten minute calls a week to
parents or other family members. That is a minimum, and I believe there is nothing in
published ORR policy that would prevent allowing more contact.
10.

I am aware that under the joint DHS-HHS Policy Statement entitled Zero

Tolerance Prosecution and Family Reunion, dated June 23, 2018, text indicates that parents
seeking reunification may proceed to utilize the sponsorship process generally applicable to
any prospective sponsor. I was troubled to read this because the ordinary sponsorship process
seems highly inappropriate for parents who have recently been forcibly separated from their
children.
11.

The ordinary process for approving a sponsor for an unaccompanied alien child,

is described in Section 2 of the ORR Policy Guide, available at
https://www.acf.hhs.gov/orr/resource/children-entering-the-united-states-unaccompanied­
section-2#2. l. Under the Policy Guide requirements, a potential sponsor must submit an
application, available at
https://www.acf.hhs.gov/sites/default/files/orr/frp 3 family reunification application 05 14
18.pdf, be subject to fingerprinting for herself and all adult household members, and then be
subject to criminal records checks, immigration checks, and a sex abuse registry check. The
approval process would also involve an assessment which would include making inquiries such
as the sponsor's motivation for wanting to sponsor the child or youth; the sponsor's
understanding of the unaccompanied alien child's needs, as identified by ORR and the care
provider; the sponsor's plan to provide adequate care, supervision, access to community
resources, and housing; and the sponsor's strengths, resources, and mitigating factors in
relation to any risks or special concerns of the child. Assessment areas of inquiry are described
in Section 2.4.1 of the Policy Guide, available at

DECLARATION OF MARK
GREENBERG IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

5

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

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https://www.acf.hhs.gov/orr/resource/children-entering-the-united-states-unaccompanied­
section-2#2.4.1.
12.

While such an inquiry may be appropriate for a relative, family friend or parent

who has not resided with a child in many years, I believe it is wholly inappropriate for a child
who has recently been forcibly separated from her parent by the US Government. Moreover,
in my experience, it is a process that may take weeks or months to complete. Because the
ORR Policy Guide is simply a statement of policy, not a promulgated rule, I am aware of no
reason why ORR could not simply publish revised policy to provide for a streamlined and
expedited reunification process.
13.

Moreover, under ORR policy, https://www.acf.hhs.gov/orr/resource/children-

entering-the-united-states-unaccompanied-section-2#2.8.2, if a child is being released to a
sponsor and the sponsor cannot come to the facility to receive the child, the sponsor must pay
for the cost of transportation for the child, including the cost for a care provider escort if one is
needed. During the Obama Administration in periods of significant spikes in numbers of
unaccompanied children in ORR care, the Administration waived this requirement as a
mechanism to speed up reunited unaccompanied children with the sponsors in the U.S. To my
knowledge, the current Administration has not stated that this policy would be waived or
modified for children in ORR care due to the family separation policy.
I declare under penalty of perjury under the laws of the State of California and the
United States of America that the foregoing is true and correct.
Executed on this 29th day of June, 2018 in Washington, D.C.

23
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Mark Greenb��---­
Senior Fello

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26
DECLARATION OF MARK
GREENBERG IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

6

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

Exhibit 44

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

8
9

STATE OF WASHINGTON, et al.,

10
11
12
13

NO. 2:18-cv-00939 - MJP

Plaintiffs,

DECLARATION OF
LINDSAY LENNOX

v.
DONALD TRUMP in his official capacity
as President of the United States, et al.,
Defendants.

14
15

I, Lindsay Lennox, declare as follows:

16

1.

I am over the age of 18 and have personal knowledge of all the facts stated herein.

17

2.

I am an attorney with the Northwest Immigrant Rights Project (NWIRP). I have

18

been with NWIRP for almost three and a half years, and before I joined NWIRP I was a public

19

defender for King County (King County Office of Public Defense/Northwest Defenders

20

Division, formerly Northwest Defenders Association) for over eight years.

21

3.

The majority of my current legal practice involves representing non-citizen

22

children under the age of 21 in pending immigration proceedings. In the past 3 years and

23

approximately 5 months, I have handled approximately 80 such cases. I have represented

24

immigrant youth in counties in the State of Washington including King, Pierce, Thurston, Skagit,

25

Mason, Whatcom, Kitsap, and Snohomish counties.

26

DECLARATION OF
LINDSAY LENNOX
2:18-CV-00939 - MJP

1

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
206-464-7744

1

4.

My clients often reside with Washington sponsors. These sponsors are individual

2

Washington residents and families who have taken responsibility for the care of my immigrant

3

youth clients while they pursue their immigration cases. Unaccompanied children who are

4

awaiting immigration proceedings (for example the adjudication of an asylum application, visa

5

approval or adjustment of status), are entitled to access many state-funded programs.

6

example, my clients use Washington courts. Many of my clients are eligible to apply for Special

7

Immigrant Juvenile Status (SIJS). The federal immigration system relies on the expertise of state

8

courts in making determinations regarding a child’s welfare for purposes of entering the

9

predicate findings for SIJS. Thus, SIJS-eligible children may seek SIJS predicate findings from

10

a state’s juvenile court, where the judge determines whether the child qualifies for protection

11

under state child welfare laws. Under statutes and regulations promulgated by the federal

12

government, my clients must obtain an order from state court with these predicate findings before

13

they can pursue that form of congressionally authorized immigration relief.

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5.

For

Clients I have represented have accessed state courts in counties including King,

15

Pierce, Skagit, Kitsap, Snohomish, Mason, and Whatcom. It is my experience that in some

16

counties, probation officers must first determine that a dependency petition is reasonably

17

justifiable before the petition may be filed. It is also my experience that Guardians Ad Litem

18

(GALs) are sometimes appointed by the court to appear in dependency cases.

19

dependency cases, parents are appointed a public defender to represent them. My understanding

20

is that the appearance of GALs and public defenders in the cases relating to immigrant youth are

21

funded with state resources, as are the court facilities and personnel.

22

6.

Also, in

My clients are often eligible for Medicaid through the Apple Health program. My

23

clients often receive medical and mental health care coverage through the State of Washington,

24

and I often encourage them to apply for Medicaid if they are eligible and not otherwise receiving

25

care.

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DECLARATION OF
LINDSAY LENNOX
2:18-CV-00939 - MJP

2

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
206-464-7744

Exhibit 45

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASIDNGTON

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STATE OF WASHINGTON,
Plaintiff,

10

NO. 2:18-cv-00939-RAJ
DECLARATION OF JONI KJMOTO

v.

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12

DONALD TRUMP in his official
capacity as President of the United
States, et al.,

13
Defendants.

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15

I, Joni Kimoto, declare as follows:

16

1.

I am over the age of 18 and have personal knowledge of all the facts stated

2.

I was born in Portland, Oregon on November 19, 1938. I have lived in the

17
18

herein.

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United States my entire life, and I have lived in Portland for the past 54 years.

20

grandparents immigrated to this county in the early 1900s to seek a better life, and they settled

21

in Portland. My mother was born in Portland, and my father was born in Seattle.

22

3.

My

l was 3 years old when World War II started. In January 1942, the government

23

imposed curfews and travel bans on Japanese Americans, including my family. The FBI came

24

to my home and interrogated me and my parents. One FBI agent asked me whether there were

25

any guns in the home. l responded that there were, and showed him two toy pistols. The FBI

26

DECLARATION OF JONl KrMOTO

F:rror! AutoText entry not defined.

l

seized my father's camera, binoculars, and radio because they believed them to be evidence

2

that my family posed a threat to national security.

3

4.

In the spring of 1942, my parents were given 10 days to sell their store and pack

4

all of our belongings into three suitcases. We were first taken to the Portland Livestock

5

Exhibition Center, renamed Portland Assembly Center, and housed where animals were

6

previously exhibited and slept on hay mattresses. To this day, I still remember the smell of

7

feces, hay, and livestock.

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9

5.

In the Fall of 1942, we were put on trains. TI1e curtains on the trains were shut

so that we could not see where we were being taken. When we arrived, we were greeted by the

10

military, who escorted us into an encampment with uninsulated barracks.

1l

remember being surrounded by barbed wire and sentries with guns, and my mother warning me

12

not to get close to the wires because it was not safe.

13

6.

I distinctly

Dw-ing the summer of 1944, we were photographed and fingerprinted like

J4

criminals. Only after that were we issued indefinite release cards that allowed us to travel

15

outside of the encampment. My family left on July 9, 1944. I still have a copy of my release

16

card, which has my photograph and fingerprint.

17

7.

The policy of separating children from their parents at the border has resonated

18

with me on a deeply personal level, even more so since I understand that fathers are being

19

detained in my home state of Oregon and there may even be children here separated from their

20

parents. It reminds me of my experiences of being taken from my home and put in an

21

incarceration camp, causing me to experience psychological distress. In both situations, the

22

government is imprisoning people without due process. The only djfference is that, in my

23

situation, I had my parents to comfort me. I can only imagine the trauma these children must

24

be experiencing upon separation from their parents. It is heart breaking and frightening to

25

think about.

26
DEC LARA TJON OF JONI KIMOTO

2

Error ! Au toTcxl entry not d efined.

1

8.

I understand that now the federal government is planning to detain people in

2

military camps, just as my family and I were imprisoned in camps that were guarded by the

3

army. It 1nakes me wonder, how is it possible that we did not learn from wh.at V.'e did to

4

Japanese Americans in World War II? I feel a lot of despair because it is happening again.

5
6
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8

I declare under penalty of perjury under the laws of the State of Washington and the
United States of America that the foregoing is true and correct.
DATED this ~ day of June, 2018 at

9

I

JJo;rf/~, Oregon.

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23

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DECLARATION OF JONl KIMOTO

3

l:rror!

AutoTe~t entry

not defined.

Exhibit 46

Exhibit 47

Exhibit 48

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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10
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STATE OF WASHINGTON,
Plaintiff,
12
v.
13
14
15

NO.

DECLARATION OF LAURA
BRIGGS IN SUPPORT OF THE
STATE OF WASHINGTON

DONALD TRUMP in his official
capacity as President of the United States,
et al.,
Defendants.

16
17
18

I, Laura Briggs, declare as follows:

19

1.

I am over the age of 18 and have personal knowledge of all the facts stated

2.

I am a professor and chair of Women, Gender, Sexuality Studies at the

20
21

herein.

22

University of Massachusetts. I hold a Ph.D. in American Civilization from Brown University.

23

My curriculum vitae, a true and correct copy of which is attached as Exhibit A, further details

24

my qualifications and lists all of the publications I have authored in the previous 10 years.

25
26

3.

A true, correct, and complete statement of my opinions, the bases and reasons

for them, and the facts and data I considered in forming them is attached as Exhibit B.

DECLARATION OF LAURA BRIGGS IN
SUPPORT OF THE STATE OF
WASHINGTON

1

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

Exhibit A: Briggs CV
LAURA BRIGGS
Chair and Professor
Department of Women, Gender, Sexuality Studies
University of Massachusetts Amherst
208 Bartlett Hall
130 Hicks Way
Amherst, MA 01003
413.545.5330
Education
Brown University, Ph.D., American Civilization,1998.
Harvard University, M.T.S., Theology and Secondary Education,1989.
Mount Holyoke College, A.B., Women's Studies, 1986
Employment
Chair and Professor, Department of Women, Gender, Sexuality Studies, University of
Massachusetts Amherst, August 2011-present.
Associate Dean, Social and Behavioral Sciences, University of Arizona, March 2010July 2011.
Head, Department of Gender and Women’s Studies, University of Arizona, 2006-07,
2008-2010
Women’s Studies and Anthropology, University of Arizona, 1997-2011.
Honors, Awards, Fellowships
Nominee, Distinguished Teaching Award, 2016s
James A. Rawley Prize for Best Book in the History of US Race Relations, Organization
of American Historians, 2013.
Inter-American Foundation Award for travel to Mexico,
UA Magellan Circle Faculty Award for Research, 2009.
UA Magellan Circle Award for Excellence in Graduate Teaching, 2009.
Comparative Ethnic Studies Prize, American Studies Association, 2007.
Tanner Humanities Center Fellow, University of Utah 2007-08.
University of Michigan Eisenberg Institute for Historical Studies Fellow, Oct.-Nov., 2007.
UA Social and Behavioral Sciences Research Institute Professorship, 2007 (declined).
UA SBSRI Research Professorship, Spring 2004.
AACU Science Education for New Civic Engagements and Responsibilities Model Course, 2002
Constance A. Rourke Prize, American Studies Association, 2002.
Harvard University, Warren Center Fellowship, Fall 1999.

Publications/Creative Activity
Scholarly Books and Monographs
How All Politics Became Reproductive Politics: From Welfare Reform to Foreclosure to Trump
(Berkeley: University of California Press, 2017).
Somebody’s Children: The Politics of Transnational and Transracial Adoption. (Durham: Duke
University Press, 2012).
Diana Marre and Laura Briggs, eds. International Adoption: Global Inequalities and the
Circulation of Children (New York: NYU Press, 2009).
Reproducing Empire: Race, Sex, Science and U.S. Imperialism in Puerto Rico
(University of California Press, American Crossroads Series, December 2002).
Journal Articles
“Adoption, from Private to Public: Intimate Economies,” Adoption and Culture 6:1 (2018). Special
Issue: Critical Adoption Studies.
“Central American Child Migration: Militarization and Tourism,” Special Issue on
Militarism and Tourism American Quarterly 68:3 (September 2016): 573-582.
“Imperialism as a Way of Life: Thinking Sex and Gender in American Empire,” Radical
History Review Special Issue: Sexing Empire 123 (October 2015).
with Maylei Blackwell and Minnie Chiu, “Roundtable: Transnational Feminism,” in
Frontiers 36:3 (Spring 2015): 1-24.
“Making Race, Making Sex: Theorizing Torture” International Feminist Journal of
Politics 16:1 (2014): 1-20.
“Wither Women’s Studies in the Current Crisis in Higher Education?” Feminist Studies
39:2 (2013): 1-5.
With Faye Ginsburg, Elena Gutiérrez, Rosalind Petchesky, Rayna Rapp, Andrea Smith,
and Chikako Takeshita, “Roundtable: Reproductive Technologies and
Reproductive Justice,” Frontiers 34:3 (December 2013): 102-25.
“Biopolitics of Adoption,” Scholar and the Feminist Online 11:3 (Summer 2013).
http://sfonline.barnard.edu/life-un-ltd-feminism-bioscience-race/
“Notes from Antigua Naval Base,” American Quarterly 65:2 (June 2013): 303-08.
Briggs and Karen Dubinsky, ”The Politics of History and the History of Politics.” In
American Indian Quarterly Special issue: Native Adoption in Canada, the United
States, New Zealand, and Australia 37: 2 (Spring 2013): 129-35.
”La economía política de la adopción: La neoliberalización del bienestar infantil,” Scripta
Nova special issue: El prinicipio del ‘interés superior’ de niñez: Adopción,
politicas de acogimiento y otras intervenciones. Perspectivas espaciales y disciplinares comparativas.
16 (Spring 2012).
“Feminism and Transnational Adoption: Politics, Precarity, and the Politics of Raising
(Other
People’s?) Children.” Feminist Theory 13.1 (April 2012): 81-100.
“Reproductive Technology: Of Labor and Markets” Feminist Studies 36:2 (Summer
2010): 359-374.
”Somebody’s Children,” Utah Law Review 2 (Fall 2009): 421-454.
"Adoption, Immigration, and Privatization: Transnational Transformations in Family,”

2

S&F Online 7.3 (Summer 2009):
http://www.barnard.edu/sfonline/sexecon/briggs_01.htm
“Activisms and Epistemologies,” Social Text 26:4 97 (Winter 2008): 79-95.
(with J.T. Way and Gladys McCormick), “Transnationalism: A Category of Analysis,”
American Quarterly 60:3 (September 2008): 625-648. (Entire issue won the 2009
award for Best Special Issue from the Council of Editors of Learned Journals).
Reprinted in David Gutierrez and Pierrette Hondagneu-Sotelo, eds. Nation and
Migration (Baltimore: Johns Hopkins University Press, 2009).
Book Chapters Presenting Original Research
“Foreign and Domestic: Adoption, Neoliberalism, Immigration” in Eileen Boris and
Rhacel Salazar Parreñas, eds. Intimate Labors: Cultures, Technologies, and the
Politics of Care (Stanford University Press, 2010): 49-62.
“The Pill” in Puerto Rico and the Mainland United States: Negotiating Discourses of Risk
and Decolonization,” in Lori Reed and Paula Saukko, eds. Governing the Female
Body (SUNY Press, 2010): 159-185
“Becoming Welfare Island: Reforming Children in the Puerto Rican 1970s,” in Anita
Casavantes Bradford and James Schrader, eds. Little Nations: Childhood, Family, and the State
in Cold War Latin America (accepted).
“Reproductive Politics,” in Christopher Nichols, Andrew Preston, Elizabeth Borgwardt, eds.,
Rethinking Grand Strategy (New York: Oxford University Press, accepted).
Book Chapters Reviewing the State of the Field
“Transnational” Oxford Handbook of Feminist Theory, ed. Mary Hawkesworth and Jane
Disch. (New York: Oxford University Press, 2016), pp. 999-1009.
“State of the Field: Gender and U.S. Imperialism,” in Vicki Ruiz, Eileen Boris, Jay
Kleinberg, eds. The Practice of U.S. Women's History: Narratives, Intersections, and Dialogues.
(Rutgers, 2007): 146-160.
Book Reviews and Short Articles
Amrita Pande, Wombs in Labor; Sharmilla Rudrappa, Discounted Life; Marcia Inhorn, Cosmopolitan
Conceptions. In Signs: Journal of Women in Culture and Society 42:4 (Summer 2017): 10421047.
Kathryn Joyce, The Child Catchers. In Ms. Magazine (Spring 2013).
Margaret Ward, Missing Mila, Finding Family: An International Adoption in the Shadow
of the Salvadoran Civil War. In Hispanic American Historical Review 93:1
(February 2013): 151-53.
Karen Dubinsky, Babies Without Borders: Adoption and Migration across the Americas
for Canadian Journal of Ethnic Studies 43:1 (2011): 289-92.
Michele Bratcher Goodwin, Baby Markets, for International Journal of Sociology of the
Family 37: 1 (Spring 2011): 173-175.
Of Lesbians and Technosperm, Queering Reproduction by Laura Mamo, GLQ: A
Journal of Lesbian and Gay Studies 15.2 (2009): 335-337.

3

Adoption History (web site) by Ellen Herman. Journal of American History (March 2008): 5.

Invited Seminars, Colloquia, Lectures
International
Seminar on How All Politics Became Reproductive Politics: From Welfare Reform to Foreclosure to Trump,
Reproductive Sociology Research Group, Cambridge University, September 26, 2017.
“Gender and North America” Gendering Modern World History, Jesus College, Cambridge
University, September 27-30.
Keynote, “The Intimate Politics of Race and Globalization: Transracial and Transnational
Adoption in the United States.“ Designing Modern Families: International Perspectives on
Intercountry and Transracial Adoptions. November 17-18, 2017, Universität Kassel,
Kassel, Germany.
Keynote, “Where Did Trump Come From? Reproduction, Whiteness, and Neoliberalism,” for
Reproductive Politics from the Welfare Reform to the Trump Era, November 16, 2017,
Adopción, Familias, Infancias Research group, Universitat Autonomo de Barcelona,
Barcelona, Spain.
Transborder Reproductive Surrogacy and Adoption, International Forum on InterCountry Adoption and Global Surrogacy, 11-13 August 2014, The Hague, The
Netherlands. Published at http://repub.eur.nl/res/col/9760/
Human Rights, the Hague Convention, and Guatemala. Encontro circulação de
crianças, Universidade do Estado do Rio de Janeiro, June 11-13, 2009.
Keynote, “Making Race, Making Sex: Theorizing Science in a Moment of Torture, War,
and (Re)Productive Uncertainty,” BIOSEX conference, Department of
Philosophy, Université Paris Sorbonne, May 29, 2009.
National
Where Did Trump Come From? Reproductive Politics, Whiteness, and Neoliberalism, April 12,
2018, University of Southern California, Department of American Studies.
Where Did Trump Come From? Reproductive Politics, Whiteness, and Neoliberalism, History
Department, April 10, 2018, Pomona College.
Gay Family Values, Vern and Bonnie Bullough Distinguished Lecture, History Department,
University of Utah, March 2018.
Where Did Trump Come From? Reproductive Politics, Whiteness, and Neoliberalism. WGSS,
UConn Stamford. February 28, 2018.
Where Did Trump Come From? Reproductive Politics, Whiteness, and Neoliberalism, Women
and Gender Studies, Distinguished lecture, Gender and Women’s Studies, UT/Austin,
February 8-11, 2018.
Where Did Trump Come From? Reproductive Politics, Whiteness, and Neoliberalism, Brown
University, Center for the Study of Race and Ethnicity, December 14, 2017.
Organizer, Critical Transnational Feminisms Seminar, Institute for Research on Women
and Gender, University of Michigan, March 2017.
“Fertility, Infertility, Race: Of ARTs and Infant Mortality,” Yale History of Medicine,

4

February 20, 2017.
“All Politics are Reproductive Politics,” Keynote, Annual Roe v. Wade Dinner, University
of Vermont Law School, April 15, 2016.
Roundtable participant, “Transnationalism,” Transnational Feminisms Summer Institute,
Ohio State University, July 7-14, 2014.
“Transnational and Transracial Adoption: The Intimate Politics of Race and Empire.”
NYU, Social and Critical Analysis, April 3, 2014.
“From Baby Veronica to CHIFF: Questions of Power, Race, and Justice in Transracial
and Transnational Adoption,” Keynote at Adoption and Culture Conference,
Tallahassee, FL, March 27-30, 2014.
“Imperialism as a Way of Life,” Keynote at American Empire conference, Notre Dame,
South Bend, IN, March 21-22.
Keynote at Sleeping Giants in Adoption: Power, Privilege, Class Conference. St. John’s
College, Queens, May 29, 2014.
Reproductive Politics, SUNY Stonybrook, March 2013.
Eugenic Legacies and Infrastructures of Reproduction. UCLA Center for the Study of Women
Roundtable. October 11, 2013.
“Reproductive Governance,” SUNY Stonybrook, September 2012
“Reclaiming a Useable Past: Identifying an Anti-Racist, Anti-Imperialist Feminist
Tradition before 1984." Brown University, April 2012.
Keynote, Reimagining the Child and the Place of Child Studies in the Academy,
Dartmouth College, May 1, 2012.
Plenary Speaker on Immigration and Women’s Studies, National Women’s Studies
Association, November 2011.
Gay adoption and Organ Theft: The limits of human rights and reproductive rights,
National Library of Medicine, June 8, 2010.
Transnationalizing American Studies seminar, Brown University, February 24, 2010.
Guatemalan Family Values: The Christian Right, International Adoption, and the
Transnationalization of the Culture Wars, Brown University, February 24, 2010.
Adoption, Immigration, and Privatization. 34th Annual Scholar & Feminist Conference,
The Politics of Reproduction: New Technologies of Life, Barnard College,
Barnard Center for Research on Women, New York, NY, February 28, 2009.
Adoption, Immigration, and Reproductive Labor. Institute for Humanities Research,
Arizona State University, April 16, 2008.
Conferences
2016 “Gay Married, with Children,” National Women’s Studies Association Quebec City,
Quebec, November.
“The Problem with Thinking Through the Nation: The Case of Central American Child
Migrants,” American Studies Association Annual Meeting, Denver, CO
“Disposable Children: Theorizing Futurity, Queer and Otherwise, in the Americas”
Tepoztlán Institute for Transnational History. Tepoztlán, Morelos, Mexico, July.
The United States in a Caribbean World. Invited Panel, Organization of American q
Historians. Providence, RI

5

2015 ASA
NWSA
Comment. “Género en movimientos y diásporas indígenas. Tepoztlán Institute for
Transnational History. Tepoztlán, Morelos, Mexico, July 2015.
2014 “Accumulation by Dispossession: Finance, Foreclosure, and the High Cost of Reproduction
in Puerto Rico,” National Women’s Studies Association, San Juan, Puerto Rico, November
13-16, 2014.
“Transnational Feminism,” National Women’s Studies Association, San Juan, Puerto Rico,
November 13-16, 2014.
“Lessons Learned from the Transnational Feminisms Summer Institute,” National Women’s
Studies Association, San Juan, Puerto Rico, November 13-16, 2014.
Comment, The Politics of Need and Desire in Neoliberal Culture, American Studies
Association, November 5-8, Los Angeles, CA.
“Nannied out: Reproductive Stratification, Migration, and Long-Distance Motherhood,”
Berkshire Conference on the History of Women, Toronto, ON May 22-25, 2014.
Roundtable participant, Radical Texts & Political Acts: Forty Years of Reading Margaret
Randall, Berkshire Conference on the History of Women, Toronto, ON May 22-25, 2014.
2013 From Cold War Latin America to Occupy Student Debt: Forty Years of Structural
Adjustment. American Studies Association Annual Meeting. Washington, DC, November
20-24.
All Politics are Reproductive Politics, National Women’s Studies Association Annual
Meeting, Cincinnati, OH, November 7-10.
Comment, Brave New Worlds: Race, Capital, Reproduction, Rethinking Marxism
Conference, Amherst, September 19-22.
With Christie Barcelo, Eve Ng, Banu Subramaniam, and Julie Russo, “Digital Feminisms.”
At Mediating Public Spheres,” Five College Women’s Resource Center. May 2013.
2012 “Overpopulation Revisited: The Globalization of Evangelical Christian “Family Values,”
Adoption, and the New Fight Over What to Do About ‘Their’ Children,” American Studies
Association, invited panel on Global Health and Empire, San Juan, Puerto Rico, November
15-18.
“Reproductive Technologies and Social Justice,” National Women’s Studies Association
Annual meeting, Oakland, CA November 8-11.
2011 Comment, Gender and Indigenous Adoption, Berkshire Conference on the History of
Women, Amherst, MA June 7-12.
2010 Comment, World Hunger and the Politics of Poverty: A Dialogue among
Historians of Africa, Latin America, and the United States, American
Historical
Association, San Diego, January 7-10.
2009 Puerto Rican Women and Sterilization: The Problem of Agency and the Politics of
Reproductive Justice. American Anthropological Association. Philadelphia, PA,
December 3-6.
“Foreign and Domestic: Stratified Reproduction, Adoption, Migration,” American
Studies Association Annual Meeting, Washington, DC, November 5-8.
“Picturing the Sad-eyed Child: Producing Orphans, Producing U.S. Foreign

6

Policy,” Feeling Photography Conference, Toronto, October 16-17. (Invited)
"Children of Guatemala’s Civil War: Disappearances, Human Rights, and
Adoption," Tepoztlán Institute for the Transnational History of the Americas Meeting
July 22-29.
“The Political Economy of Adoption: The Neoliberalization of Child Welfare,”
Unequal Childhoods II: Adoption and Fostering, LASA Conference, June 11-14.
2008 “Transnationalism and Diaspora in the History of Race and Medicine,” Making
Race, Making Health: Historical Approaches to Race, Medicine and Public
Health, University of Texas at Austin, Austin, TX, November 13-15. (Invited)
Transracial Adoption and the Multiracial Family, 1950–2000: Pinko Queer Revolt
or Neoliberal Wet Dream? American Studies Association Conference,
Albuquerque, NM October 16-19.
“From Billy Graham to Pedro Pan: Evangelicals, Anticommunism, and
Immigration Law in Transnational Adoption to the U.S.,” Organization of American
Historians, New York, NY, March 28-31.
Roundtable, Toward a Transnational History of Disability, American Historical
Association, Washington D.C., January 3-6.
Grants
State
Arizona Humanities Council, Faculty Mentors for Youth ($3000), 2002-03.
University
2012Digital Feminism
2013

$15,000

Co-PI

Provost’s Author Support Fund, University of Arizona ($1000), 2008.
Faculty Research Development Grant, University of Arizona ($500), 2008.
Faculty Research Development Grant, University of Arizona ($500), 2006.

TEACHING
Courses (last 10 years)
Semester
Fall 2017

Number
187

Spring 2017

691B

Fall 2016

230

Spring 2016

285

Fall 2015

295M

Course name
Gender, Sexuality
and Culture
Issues in Feminist
Research
Politics of
Reproduction
Intro to Biology
Of Difference
Politics of
Reproduction

7

Enrollment
94
15
28
52
24

Five College Inc.
Digital Humanities

Spring 2015

695A

Fall 2014

295M

Spring 2014

285

and Mothering
Transnational
Feminisms
Politics of
Reproduction
and Mothering
Bio of Difference

Fall 2013

791B

Feminist Theory

17

Spring 2013

WOMENST 285

Bio of Difference

45

Fall 2012

695A

Transnational
Feminisms

8

Spring 2012

WOMENST 285

Bio of Difference

60

Fall 2011

WOMENST
392G

Race/Gender:
Genealogies,
Formations,
Politics

7

Spring 2011

GWS 240-1
GWS 240-2

14
29
25

Gender in a
98
Transnational
World
Fall 2010
GWS 639
Feminist and
7
Related Social
Movements
Spring 2010
GWS 240-1
Gender in a
96
GWS 240-2
Transnational
World
Fall 2009
GWS 639
Feminist and
8
Related Social
Movements
Spring 2009
WS/ANTH 586
Transnational
18
Feminisms
Fall 2008
Course release per terms of Dept. Head offer
Teaching Awards and Grants
ABOR Learner-Centered Education Grant, ““Developing a Library of Online
Course Materials for Gender and Women’s Studies” ($7,918.45), 2010.
UA Magellan Circle Award for Excellence in Graduate Teaching, 2009.
UA Magellan Circle Award for Excellence in Graduate Teaching, 2009.
Departmental Sponsor

8

Aviva Richardson
Maria Bastos-Stanek
Paige Smith-Hogan
Carrie Nagle
Stephanie
Undergraduate Internship Supervisor (last five years)
WGSS Digital Presence, 2012.
Planned Parenthood, 2009.
Women in Science and Engineering High School Mentoring, 2009.
ASUA Women’s Resource Center 2007, 2008, 2009.
Aurora Foundation, Summer 2006.
EO/AA Office, University of Arizona, Fall 2006.
Arizona’s List (2), Fall 2006.
Planned Parenthood, Spring 2005.
Jewish Community Nursing Home, Spring 2005.
Undergraduate Independent Studies
Maribel Morales, Div III exam, Hampshire College, 2013-2015
Madeleine Burrows, Div III exam, Hampshire College, 2012-13.
Digitizing the Public Sphere, 2012.
Eugenics (3), Fall 2008.
McNair Program Student Advisor, Summer 2007.
Summer Research Institute Student Advisor, Summer 2007.
Histories of U.S. State Repression from the Red Scare to the Patriot Act, Spring, 2003.
Cloning, Abortion, and Breast Cancer Research, Spring, 2002.
Cloning and Stem Cell Research, Fall 2001.
Postcolonial and Critical Race Feminisms, Fall, 2000.
Race in the United States, Spring, 2000.
Gender and Science, Spring, 1999.
Undergraduate Honors Theses
Naomi Mastico, WGSS, Honors Thesis 2015-16
Megan Lieff, 2012-13
Sara Tankersley, “Guatemala: A Baby Factory?” 2008-09.
Naomi Mastico, 2015-16
Graduate Reading Groups
Central America 2016-17
Jose Muñoz Queer Theory Reading Group, 2014
Critical Hermaneutics, Spring 2010.
Globalizations/Transnationalism Reading Group, Spring, 2006.
Dissertations, Committee Member, Current

9

Faune Albert, English, UMass
Kevin Henderson, Political Science, UMass
Julieta Chaparro, UMass Anthropology
Martha Balaguera, Political Science, UMass
Eli Bromberg, English, UMass
Ana Maria Ospina Pedraza, Political Science
Joy Jansen, English
Grad Certificate Projects, present
Katty Alhayek
Ana Ospina
Julieta Chaparro
Kevin Henderson
Woori Han
Comprehensive Exams, Present
Joy Jansen, English, UMass
Comprehensive Exams, past
Berra Topcu, UMass Anthropology
Julietta Chaparro, Anthropology
Dissertations, Directed, Past
Maria Galup, Gender and Women’s Studies, UA
Erin Durban, "Postcolonial Homophobia: United States Imperialism in Haiti and the
Transnational Circulation of Anti-Gay Sexual Politics." Gender and Women’s
Studies, UA. **2015 Winner of the prestigious Ralph Henry Gabriel Prize from the
American Studies Association and the NWSA-University of Illinois First Book Prize**
Ronit Fainman-Frenkel, "’On the Fringes of Dreamtime…’: South African Indian
Literature and the Instability of Post-Apartheid Racial Taxonomies," Comparative
Cultural and Literary Studies.
Jodi Kelber-Kaye, “Straighten Up and Breed White: The Representation of Race and
Sexuality in Films About Reproductive Technologies” Comparative Cultural and
Literary Studies.
Dissertations, Committee Member, Past
Eva Payne, Harvard University, American Studies
Chris Barcelos, Pubic Health
Sara Matthiessen, Brown University, American Studies
Kelly Grey, UMass Higher Ed
Amy Grey, History, UA
Jamie Wilson, Spanish and Portuguese, UA
Wendy Vogt, Anthropology
Eva Romero, Spanish and Portuguese

10

Lucy Lee Blaney, Spanish and Portuguese
Lee Blouin, English
Karin Fredrichs, Anthropology.
Lauren Carruth, Anthropology
Araceli Masterson, Spanish & Portuguese, "Producing Space and Cultural
Cartographies: Ecuadorian Migrants in Madrid, Spain." (2009)
Angela Ross, English, "The Princess Production: Locating Pocahantas in Time
and Place" (2008).
Kate Goldade, Anthropology, “South-to-South Migration, Reproduction, and
Medical Citizenship: The Paradoxes of Proximity for Nicaraguan Labor
Migrant Women in Costa Rica” (2008).
Grad Certificate Projects, past
Faune Albert, English
Seda Saluk, Anthro
Martha Balaguera
Jennifer Zenovich
Erika Arthur, UMass History
MA Theses, Directed
Angela Stoutenburgh, GWS
Adrian Flores, GWS
Heather Fukunaga, Women’s Studies.
Jonna Lopez, Women's Studies.
Lucas Whitman, Latin American Studies.
Ellis Ogburn, Women's Studies.
Jean Li, Women's Studies.
Shefali Desai, Women's Studies and Law.
Adrienne Crump, Women's Studies.
Natalie Josef, Women's Studies.
Yasuko Doguchi, Women's Studies.
Jennifer Tersigni, Women's Studies.
MA Theses, Committee Member
Erin Durban, Women's Studies
Mari Galup, GWS
Carly Thomsen, Women’s Studies.
Jeanette Silleck, Women’s Studies.
Dylan Simosko, Women’s Studies.
Miluska Martinez, Latin American Studies.
Lucas Whitman, Latin American Studies.
Laura Belous, Mexican American Studies.
Alexa Priddy, Women’s Studies.
Lucy Lea Blaney, Latin American Studies.

11

Darcy Alexandra, Language Reading & Culture.
Heather Mikolaj, American Indian Studies.
Lisa Knisely, Women’s Studies.
Kate Goldade, Anthropology.
Erika Giesen, Women's Studies.
Sarah Arvey, Latin American Studies.
Development and Scholarly activity supporting teaching
articles
Interviewed in Diana Turk et al., Teaching U.S. History: Dialogues among Social
Studies Teachers and Historians (Rutgers: Rutgers University Press,
2010).
(with Jen Croissant, Sharla Fett, and Marta Civil) “Gender and Science across
the Curriculum: Students Respond,” Caryn McTighe Musil, ed., Gender,
Science, and the Undergraduate Curriculum: Building Two-Way Streets
(Washington, AAC&U, 2001).
“New Technologies and Education,” in Women's Review of Books (February,
2001).

Service/Outreach
Articles for a Popular Audience
”Little Bug Wants a Doll,” in Lori Rotskoff and Laura Lovett, eds. When We Were Free
to Be: Looking Back at a Children’s Classic and the Difference it Made.
(Charlotte, NC: University of North Carolina Press, 2012).
”Women’s History Month,” OAH Newsletter 36: 1 (February 2008): 1, 6.
Service to the Profession
External Reviewer for Tenure/Promotion
New York University
The Ohio State University
Boston College
Notre Dame
City University of New York (3)
University of California, Santa Barbara
University of California, San Diego
University of North Texas
Washington State University
University of Michigan (2)
University of Texas
Drake University
External Program Reviewer
University of California/Santa Cruz

12

Vanderbilt University
Wesleyan College
Williams College
Manuscript Reviewer
University of California Press
Duke University Press
New York University Press
Rowman and Littlefield
Rutgers University Press
American Quarterly
Centro de Estudios Puertorriqueños Bulletin
Signs
Comparative Studies in Society and History
Critical Sociology
Gender and History
Gender and Society
GLQ
Journal of American History
Journal of Women's History
National Endowment for the Humanities
NWSA Journal
Social Forces
Meridians
Social Problems
Reproductive Biomedicine and Society
Professional Service
Rourke Prize Committee, American Studies Association, 2004, 2015, 2016.
International Committee, American Studies Association, 2014-2017.
National Council, American Studies Association, 2014-2017.
International Committee, American Studies Association.
Book Review editor, American Quarterly, 2014-18.
Co-chair, Transnational Feminisms Task Force, National Women’s Studies Association, 2014.
ADVANCE PAID panel member, National Science Foundation, January 2013
Organizing Committee, Transnational Feminisms conference, Summer 2014.
LGBTQ History Task Force, Organization of American Historians, 2011-2012.
Editorial Committee, American Crossroads Series, University of California Press, 2009Editorial Board, Reproductive Justice Series, University of California Press, 2016-present
Tepoztlán Institute for Transantional History, collective member, 2004-2010; codirector, 2009-2010.
Committee on the Status of Women in the Historical Profession, Organization of
American Historians, 2005-09; Chair, 2007-08.

13

Service to the University
Joint Task Force Resource Allocation, UMass, 2014-2016.
Program Review Committee, Stonewall Center, Fall 2014.
Search Committee, Endowed Chair in Nonviolence Studies, 2013.
Academic Matters Committee, Faculty Senate, UMass, 2013.
Sherill Creative Teaching Awards Committee, UA, Spring 2010, 2011.
Search Committee, VP for Legal Affairs/Office of the General Counsel, 2009.
Search Committee, Dean of Social and Behavioral Sciences, 2009.
SBS Scholarship Selection Committee, Spring 2009.
Elected Representative, Dept. Head’s Advisory Committee to UA President Shelton,
2008-2010.
Service to Communities
Community Boards/Advisory Committees
Women’s Studies Advisory Committee, 2008-10.
Women’s Plaza of Honor Board, Publicity Committee 2008-10.
Elizabeth Lapovsky Kennedy Graduate Fellowship fundraising committee, 2008-10.
Voices: Community Stories, Past and Present (youth magazine), 2000-04.
Faith-based Immigration Groups: Guatemala Project, Samaritans, Humane Borders,
2003-2007.
Member
National Organization for Women, Tucson, 2008-2011.
Arizona List, 2006-2012.
YWCA, Tucson, 2008-2011.
Public/Community Talks
“Feminism” for Social Justice Week, Northampton High School, May 18, 2015.
Panelist, Screening of “The Response” (on torture), ACLU, September 29, 2009.
Panelist, Politics of Birth Control, ASUA Women’s Resource Center, March 12, 2009.
Panelist, Women and Politics: The 2008 Election, ASUA Women’s Resource Center
and Arizona List, October 28, 2008.
Societal Implications of Genetic Research, Panelist. University of Arizona Genetics and
Society Roundtable, Tucson, September 19, 2008.
AFFILIATIONS
American Studies Association
Organization of American Historians
American Historical Association
Latin American Studies Association
National Women’s Studies Association

14

Exhibit B: The History of Child Separation in order to Deter Actions by Parents
with Respect to Native Children in the United States and Purported Leftists in Latin
America
1. The current policy of separating children from their parents in order to deter
border crossers is not the first time that the U.S. federal government has separated
children from their parents in order to achieve a political goal. It also separated
Native American children from their parents as a strategy to end the Indian Wars
of the nineteenth century. Child separation was also the policy of a number of
Latin American dictators and paramilitaries in the mid-twentieth century, which
sought to terrorize communities thought to be involved in insurgencies and to
avoid the raising of another generation of “reds.”
2. In each of these instances, people of conscience found these policies abhorrent,
and activists and government policy-makers reformed them.
Native American Child Separation
3. Beginning in the late 1870s, separating Native children from their families and
communities was foundational to federal policy to “civilize” the savage, to teach
children English, and to extinguish traditional religions, tribal organization, and
ways of life.
4. On July 20, 1867, during a pause in the Indian Wars, Congress established the
Indian Peace Commission to negotiate with Plains Indian tribes who were warring
with the United States in order to secure frontier settlements, land for agriculture,
mining and mineral rights, and to allow for the building of the
railroads. The Peace Commission met in St. Louis, Missouri, on August 6, 1867,

2
and traveled throughout the contested lands, from Missouri to the Dakotas to
California. The Commissioners argued that lasting peace was contingent upon
separating Indians regarded as "hostile" from those regarded as friendly, removing
all Indian tribes onto reservations away from the routes of U.S. westward
expansion, and making provision for their maintenance.1
5. The official report of the Commission to the President of the United States, dated
January 7, 1868, described numerous social and legal injustices to Indians,
repeated violations of numerous treaties, including settlement on their land, acts
of corruption by many of the local agents, and culpability of Congress in failing to
fulfill certain legal obligations. Members of the Commission charged that
employees of the railroad were shooting down Indians “in wonton cruelty.”
6. The purpose of detailing these depredations by whites was to inaugurate a new
policy: of civilizing the Indians in order to secure their lands, build new
settlement, expand agriculture and mining. The Commission said that beyond the
dishonesty, massacres, and unkindness of whites, the problem was also “the tribal
or clannish organization” of Native people, and their failure to speak English. And
so the Commission proposed the following plan:
“Agriculture and manufactures should be introduced among them as rapidly as
possible; schools should be established which children should be required to
attend; their barbarous dialects should be blotted out and the English language
substituted...The object of greatest solicitude should be to break down the
1

“Report to the President by the Indian Peace Commission” (January 7, 1868), in Annual
Report of the Commissioner of Indian Affairs for the Year 1868, (Washington, D.C.:
Government Printing Office, 1868).

3
prejudices of tribe among the Indians; to blot out the boundary lines which divide
them into distinct nations, and fuse them into one homogeneous mass. Uniformity
of language will do this -- nothing else will.” 2
7. The proposal of the Peace Commission, in short, was to shift Native economies to
those that would integrate well with the United States and require a much smaller
land base (and one that could be held by individuals, rather than tribes, making it
easier for whites to buy or take the land), through boarding school education. This
was, ultimately, exactly what happened as a result of the Dawes Act and boarding
school policy. It is estimated that the land base of Indian country was depleted
from 138 million acres of treaty land in 1887 to a mere 48 million acres when
allotment was finally halted in 1934, of which 20 million of the remaining land
was desert or semi-desert.3
8. The shift from warfare to schools that could exterminate “barbarous dialects” and
teach children to farm, however, was not fully taken up for nearly another decade,
until after open warfare between the Sioux (or Dakota/Lakota) and the US
Cavalry flared again in a dispute over mining in the Black Hills, sacred to the
Lakota, in a war that included the defeat of the 7th Cavalry at the Battle of Little
Bighorn (“Custer’s last stand.”). U. S. Grant annexed the Black Hills in 1877,
after a military “surge” and great loss of life on both sides, including the
culmination of an effort to starve Native peoples through the slaughter of buffalo

2

Francis Paul Prucha, ed., Documents of United States Indian Policy, 2nd Edition ed.
(Lincoln: University of Nebraska Press, 1990)., p. 107.
3
William C. Canby, Jr., American Indian Law in a Nutshell. 4th ed. Nutshell Series. St.
Paul, MN: West, 2004.

4
and demoralize them through assaults on women and children. Various chiefs of
of the Sioux federation sought peace, including Red Cloud (Oglala) and Spotted
Tail (Sicangu), though the Sioux never ceded the Black Hills (even when the US
carved presidents’ faces in them and renamed one the Mount Rushmore National
Monument).4
9. When it became clear that final military victory would remain elusive, the US
federal government finally substituted boarding schools for the Cavalry. In 1878,
the War Department ordered Lieutenant Richard Pratt to go Dakota Territory to
begin the work of Indian education, specifically contacting “friendly” chiefs, Red
Cloud and Spotted Tail, and taking children as “hostages for the good behavior of
their people.”5 Pratt was chosen because of his experience commanding a Black
Cavalry regiment in Oklahoma (“Buffalo soldiers”), and experiments in the
education and discipline of Indian prisoners from the Red Hills War at Fort
Marion in St. Augustine, Florida, and at Hampton Institute. The Fort Marion
prisoners were considered singularly uncivilized and hostile, and Pratt had
succeeded by mixing tribes, having Indians of different tribes guard and discipline
each other, cutting their hair, teaching them English, compelling them to clean
and cook, and instituting military drills and tribunals (in which some prisoners
sent others to the dungeon) and forcing prisoners to attend church. (He also

4

James C. Olson, Red Cloud and the Sioux Problem (Lincoln: University of Nebraska
Press, 1968); David Humphreys Miller, Ghost Dance (Lincoln: University of Nebraska
Press, 1985).
5
Linda F. Witmer, The Indian Industrial School, Carlisle, Pennsylvania, 1879–1918
(Carlisle, PA: Cumberland County Historical Society, 1993), p. 31.

5
participated in torturing and killing some of them.)6 In 1879, while still on active
duty, he opened the Carlisle Indian School, using many of these same practices
and taking Dakota children far away to Pennsylvania and teaching them English,
farming, and Anglo-American ways of living. Children were prevented from
returning home during the summer months, because of concerns that they would
revert to “savagery,” and were instead distributed to local households—girls to do
housework, boys to farm. Pratt relied on military-style drills, corporal
punishment, and capture and incarceration of runaways to enforce his educational
methods. Epidemics of cholera, influenza, and tuberculosis devastated children’s
numbers there, and many were buried in a cemetery on the grounds. Pratt’s goal,
he said, was to “kill the Indian to save the man”—eliminate children’s “Indianness” as an alternative to warfare and extermination.7
10. Following the success of Pratt and the War Department, Christian missionaries
and civil society “Friends of the Indian” groups began opening larger numbers of
boarding schools in the 1880s to “civilize” indigenous peoples. In 1881, Congress
declared school attendance for Indian children compulsory, and authorized the
Indian Bureau to deny benefits guaranteed by treaty right if children failed to
attend; they were to “withhold rations, clothing, and other articles from those
parents who resisted sending their children to school.” 8 Indian boarding schools

6

Richard Henry Pratt, Battlefield and Classroom: Four Decades with the American
Indian, 1867-1904, ed. Robert Marshall Utley (New Haven: Yale University Press,
1964).
7
Hayes Peter Mauro, The Art of Americanization at the Carlisle Indian School
(Albuquerque: University of New Mexico Press, 2011).
8
Theodore Fischbacher, A Study of the Role of the Federal Government in the Education
of the American Indian, cited in David Wallace Adams, ‘‘Fundamental Considerations:

6
spread through the West and Midwest. “Before and after” photos were popular
throughout the United States to show the process of “civilizing” Indian children.
Boarding school photos circulated like trophies among whites. As American
Indian Studies scholar K. Tsianina Lomawaima writes, “The famous ‘before and
after’ pictures of Carlisle students are as much a part of American iconography as
the images of Custer’s Last Stand. ‘Savages’ shed buckskin, feathers, robes, and
moccasins; long black hair was shorn or bobbed or twisted into identical,
“manageable” styles; pinafores, stiff starched collars, stockings, and black oxfords
signified the ‘new woman.’9
11. The process of separating Native children from their parents was often violent and
involved children as young as five or six. One witness, writing in 1930, reported
on conditions on the Navajo (Diné) reservation. “In the fall the government
stockmen, farmers, and other employees go out into the back country with trucks
and bring in the children to school…the wild Navajos, far back in the mountains,
hide their children at the sound of a truck. So stockmen, Indian police, and other
mounted men are sent ahead to round them up. The children are caught, often
roped like cattle, and taken away from their parents, many times never to return…
I have heard too many stories of cowboys running down children and bringing
them hogtied to town to think it is all an accident…They are transferred from
school to school, given white people's names, forbidden to speak their own

The Deep Meaning of Native American Schooling, 1880–1900.’’ Harvard Educational
Review 58, no. 1 (1988): 1–28.
9
K. Tsianina Lomawaima, "Domesticity in the Federal Indian Schools: The Power of
Authority of Mind and Body," American Ethnologist 20, no. 2 (1993).

7
tongue, and when sent to distant schools are not taken home for three years.”
Some, especially children who ran away, would be taken across the country and
did not return until they were 16 or 18.10
12. Tribes, and occasionally even white lawyers and courts, were shocked by the
violence of the Pratt system of Indian education and the removal of Indian
children. In 1899, a federal district court granted a writ of habeas corpus to an
Iowa tribe that demanded the return of Native child from a boarding school in
1899, suggesting an alternative trajectory that might have ended boarding schools
much sooner had it been followed. It found that tribes had to consent to the
removal of a child.11
13. Nevertheless, federal agents and missionaries ignored this court order and
continued to promote compulsory off-reservation boarding schools, in some
places until the late 1970s,12 arguing that it was essentially to the civilization
process. Few Native children attended day schools or lived at home. Living on the
reservation, especially with their parents, meant that children would revert to
“savagery” by night, undoing the good work of the school’s civilizing mission by
day.13 Visits home were also seen to impede the assimilation process, and were

10

Dane Coolidge, "'Kid Catching' on the Navajo Reservation: 1930," in The Destruction
of American Indian Families, ed. Steven Unger (New York: Association on American
Indian Affairs, 1977)., pp. 18-21.
11
In re Lelah-Puc-Ka-Chee 98 F. 429 (N.D. Iowa 1899).
12
Unsigned, "Historic School Victory," Indian Family Defense: Bulletin of the
Association on American Indian Affairs, Inc. 1976.
13
Annual Report of the Commissioner of Indian Affairs, 1880, cited in David Wallace
Adams, "Fundamental Considerations: The Deep Meaning of Native American
Schooling, 1880-1900," Harvard Educational Review 58, no. 1 (1988). P. 13.

8
discouraged as a matter of policy.14 Instead, children across the country were
“farmed out” in the summers, boys working as ranch hands and farm laborers,
girls doing domestic labor.15
14. Scholars agree that the regimens at boarding schools were harsh. Children were
punished, often beaten, for speaking indigenous languages; dress was carefully
monitored and checked by staff.16 Some scholars have suggested that sexual abuse
of both girls and boys was rife in boarding schools; an investigation into sexual
abuse in boarding schools in Canada in the 1970s resulted in 3,400 complaints of
sexual abuse. No similar investigation took place in the United States, although
some have argued that any full inquiry into the crimes in U.S. Indian boarding
schools would find not only starvation, but also medical experimentation,
involuntary sterilization of girls, and physical punishment that amounted to
torture.17 A recent survey of boarding school attendees found that nearly 30%
reported that they had been sexually abused there.18
15. Yet there was one official inquiry into boarding schools in the United States.
Throughout the 1920s, Indian policy reform advocates ran ever-more vociferous

14

Brenda Child, "Runaway Boys, Resistant Girls: Rebellion at Flandreau and Haskell,
1900-1940," Journal of American Indian Education 35 (1996).
15
Margaret Archuleta et al., Away from Home: American Indian Boarding School
Experiences, 1879-2000 (Phoenix, Ariz.; Santa Fe: Heard Museum; Distributed by
Museum of New Mexico Press, 2000).
16
Ibid.
17
Andrea Smith, Conquest: Sexual Violence and American Indian Genocide (Cambridge,
MA: South End Press, 2005).
18
T. Evans-Campbell, Walters, K. L., Pearson, C. R., & Campbell, C. D. (2012). “Indian
Boarding School Experience, Substance Use, and Mental Health among Urban TwoSpirit American Indian/Alaska Natives.” The American Journal of Drug and Alcohol
Abuse, 38(5), 421–427.

9
campaigns about the horrors of Indian policy, including ongoing land-theft,
detribalization, and the suppression of Native culture, language, and religious
practices, and insisting that child-separation and boarding school policies were a
keystone. As a result of this public pressure, Hubert Work, the Secretary of the
Interior commissioned an independent report by the Institute for Government
Research, aiming to prove that the public campaign was rank exaggeration. The
1928 report, The Problem of Indian Administration, (better-known as the Meriam
Report, for its author), suggested that things were, if anything, worse than the
press accounts had had it, with special reference to boarding schools. It described
children living in overcrowded dormitories, without even adequate toilet facilities
at times, subsisting on a vastly inadequate diet, subject to terrible health
conditions, ill-clad. Boarding schools “operated below any reasonable standard of
health and decency,” as Lewis Meriam wrote. Children suffered high rates of
illness and death, and were subject to a curriculum of little value; the report noted
continued high rates of illiteracy. They had virtually no leisure time, and were
forced to do manual labor to support the school (in apparent violation of child
labor laws, the report noted). It urgently recommended that children be returned to
their parents and communities. “The continued policy of removing Indian
children from the home and placing them for years in boarding schools largely
disintegrates the family and interferes with developing normal family life.”19

19

See e.g., John. Collier, ‘‘American Congo.’’ Survey, August 1, 1923; ‘‘America’s
Treatment of Her Indians.’’ Current History (August 1923): 771–78. Kenneth R. Philp,
John Collier’s Crusade for Indian Reform, 1920–1954. Tucson: University of Arizona
Press, 1977. Institute for Government Research, The Problem of Indian Administration;
Report of a Survey Made at the Request of Honorable Hubert Work, Secretary of the

10
16. The report’s effect was electric. President Hoover immediately and publicly
increased the allocation to boarding schools for food and clothing for children.
Within a few years, a leader of the reform campaign, John Collier, was heading
up the Bureau of Indian Affairs, and introduced significant changes designed to
recognize tribal organization and Native religion and culture, halt the reduction of
the land base of Indian Country, and close boarding schools in favor of day
schools.20
17. The effects of boarding schools on children and Native communities was
devastating. Mortality rates among children were very high. Those children who
did return had often forgotten their native language and sometimes had no
language in common with their parents. As one agent with the Indian Service,
Dane Coolidge, noted, “Back in the hogans of their people the returned
school[children] are quite unfitted for their life…They start in all over again to
learn to spin and weave and handle their sheep and goats.” 21 Many attribute high
rates of violence, family dysfunction, alcoholism, and drug abuse among some
Native communities to the legacies of the boarding school experience, and the
fact that for years, few Indian children were raised by their parents. One scholar
wrote, “I have attended several Native wellness workshops in which participants
are asked to draw a family tree that shows the generation in their family in which

Interior, and Submitted to Him, February 21, 1928. (Washington: Brookings Institute,
1928). Quotes at pp. 348, 15.
20
Philp, Collier’s Crusade.
21
Dane Coolidge, "'Kid Catching' on the Navajo Reservation: 1930," in The Destruction
of American Indian Families, ed. Steven Unger (New York: Association on American
Indian Affairs, 1977).

11
violence, substance abuse, and other related problems develop. Almost invariably,
these problems began with the generation that first went to boarding school.”22 In
the 1970s, the American Psychiatric Association published an influential editorial
that called boarding schools “a hazard to mental health.”23 In 1977, psychiatrist
Joseph Westermeyer testified before Congress that the American Indian family
was in “crisis” as a result of the “ravages” of boarding schools and other familial
separations, citing alcoholism and suicide attempts by parents who lost their
children.24
18. The legacy of boarding schools lives in people who are currently alive and among
us. Although day schools became more common in the 1930s, and boarding
schools were largely phased out in the 1970s, the harm of being separated from
parents at a young age continues into the present. In 1974, a survey by the
American Association of Indian Affairs found one in three Native children
separated from their parents, either in boarding school, foster care, or adoptions.25
That number had actually risen by 1987, when another survey found even higher

22

Smith, Conquest, p. 44.

23

"A Hazard to Mental Health: Indian Boarding Schools." American Journal of
Psychiatry, 131(3), pp. 305–306.
24

Select Committee on Indian Affairs, Indian Child Welfare Statistical Survey, July
1976, Appendix G, First Session on S. 1214, To establish standards for the placement of
Indian children in foster or adoptive homes, to prevent the breakup of indian families, and
for other purposes, 4 August 1977; Select Committee on Indian Affairs, Indian Child
Welfare Act of 1977: Hearing, First Session on S. 1214, To establish standards for the
placement of Indian children in foster or adoptive homes, to prevent the breakup of
Indian families, and for other purposes, 4 August 1977.
25
Joseph A. Myers, They Are Young Once but Indian Forever: A Summary and Analysis
of Investigative Hearings on Indian Child Welfare, April 1980 (Oakland, Calif.:
American Indian Lawyer Training Program, 1981), 92-93. Pp. 92-93.

12
rates of children separated from their Indian parents.26 Scholars, mental health
professionals, and activists may debate the proportions in which this is a legacy of
policy—the habit of and deeply ingrained belief in separating Native children
from parents--or familial pain in the aftermath of the trauma of the boarding
school experience. Regardless, it is amply clear that Indian families continue to
suffer as a result of federal policy that separated children from parents, even many
generations later.
19. When children who had been separated at early ages from their parents grew into
adults, they passed their trauma to their own children. In 2006, mental health
professionals who surveyed nearly 500 Native American adults and youth found
not only that the boarding school attendees in the group had much-elevated rates
of suicide attempts, alcoholism, and drug abuse, but that children raised by
boarding school attendees “are significantly more likely to have a general anxiety
disorder, experience posttraumatic stress disorder symptoms, and have suicidal
thoughts in their lifetime compared to others.”27
Latin America’s Child Separation Policies
20. Right-wing dictatorships in Latin America in the 1970s, 80s, and 90s also
kidnapped children and placed them in adoptions in the context of civil wars.

26

Margaret Plantz, Indian Child Welfare: A Status Report: Final Report of the Survey of
Indian Child Welfare and Implementation of the Indian Child Welfare Act and Section
428 of the Adoption Assistance and Child Welfare Act of 1980 (Washington, D.C.: U. S.
Department of the Interior, 1988.)
27
T. Evans-Campbell, K. L. Walters, C. R. Pearson, and C. D. Campbell, “Indian
Boarding School Experience, Substance Use, and Mental Health among Urban TwoSpirit American Indian/Alaska Natives,” The American Journal of Drug and Alcohol
Abuse, 38:5 (2012): 421–427.

13
These governments received backing from the United States, although it is
unclear whether there was also support for the deliberate separation of children.
Ultimately, however, human rights activists uncovered—and continue to
uncover—these practices and reunified children with their parents and biological
relatives. In Argentina, activists have found 117 of the estimated 500 children
who were taken from their leftist parents during the military dictatorship from
1976-1983—separated either at the time of left activists’ murder or incarceration,
or later, after the rape and torture of women prisoners had resulted in the birth of a
child. Members of the military described the goals of the program in two ways,
either as a desire to prevent the children from learning to be “subversives” from
their parents, or to frighten leftists into desisting.28 The actions of the Madres de
Plaza de Mayo and the Abuelas de Plaza de Mayo (mothers and grandmothers of
the Central Square in Argentina) has resulted in the creation of a DNA database
that has, in many cases, helped identify these children (in adulthood) and restore
some relationship to their natal family. The harm of the adoption has generally
been found to have been greater than learning the truth, but the experience has
been deeply traumatizing. As geneticists Victor B. Penchaszadeh wrote, “The
emotional shock experienced by the children when learning that the adults who
were raising them had been, at a minimum, accomplices in the disappearance and
murder of their parents, was of great magnitude in all cases. Initial disbelief and

28

Abuelas de la Plaza de Mayo, "Abuelas de la Plaza de Mayo,"
http://www.abuelas.org.ar/. Rita Arditti, Searching for Life: The Grandmothers of the
Plaza de Mayo and the Disappeared Children of Argentina (Berkeley: University of
California Press, 1999).

14
feelings of despair led some older children and adolescents initially to resist.”29
All but a few, however, have reignited ties with their natal parents’ surviving
family.
21. In Central America’s Northern Triangle (Guatemala, El Salvador, Honduras),
there is a significant history of militaries and paramilitaries punishing civilians for
their actions or beliefs (or purported beliefs) through murder and terror. The USbacked Guatemalan and Salvadoran right-wing governments’ government’s
policy of “disappearing” civilians in the 1970s, 80s, and 90s is well-known.
Between 1954 and 1968, during the Guatemalan Civil War, an estimated 40,000
to 50,000 people were disappeared by the government, accused of backing leftist
insurgents. (Many of these people were undoubtedly innocent, guilty of nothing
more than belonging to certain indigenous groups, as the actual insurgency was
quite small.) In Salvador, right-wing death squads killed as many as 35,000
civilians between 1980-83.30 Honduras’ death squad from the 1980s, Battalion
316, killed or disappeared hundreds. It is widely believed to be operating again
today in the aftermath of the 2009 (and 2017) coups d’état.31

29

Victor B. Penchaszadeh, “Ethical, Legal and Social Issues in Restoring Genetic
Identity after Forced Disappearance and Suppression of Identity in Argentina.” Journal of
Community Genetics 6.3 (2015): 207–213.
30
Cynthia J. Arnson, "Window on the Past: A Declassified History of Death Squads in El
Salvador," in Bruce Campbell and Arthur Brenner, eds, Death Squads in Global
Perspective: Murder with Deniability (New York: St. Martin’s Press, 2000), p. 88.
31
Gary Cohn and Ginger Thompson, "When a Wave of Torture and Murder Staggered a
Small U.S. Ally, Truth was a Casualty," The Baltimore Sun. (11 June 1995). Available at
http://www.baltimoresun.com/news/maryland/bal-negroponte1a-story.html. Nina
Lakhani, “Did Hillary Clinton Stand By As Honduran Coup Ushered in Era of
Violence?” The Guardian (31 August 2016). Available at
https://www.theguardian.com/world/2016/aug/31/hillary-clinton-honduras-violencemanuel-zelaya-berta-caceres. Sarah Kinosian, “Crisis of Honduras Democracy Has Roots

15
22. Less well-documented but increasingly important to international publics is the
story of children disappeared in Guatemala and Salvador during the armed
internal conflicts. Some were smuggled into international adoptions. Over time,
documentation, identification, and sometimes reunions of Central American
children disappeared during the war has grown steadily. In Guatemala, for
example, a very multilingual country where many indigenous communities were
wiped out and where distant mountainous communities were often unconnected to
cities, the documentation process has been slow. In 1998, the official Truth
Commission took testimony about 183 children kidnapped by militaries and
paramilitaries during the war, but believed there were many more that the
government should search for. 32 The Archbishop’s Commission on Human Rights
initially documented 216 disappeared children, then, in a later report, 444.33 When
the government continued to refuse to search for children disappeared, a number
of NGOs came together to document cases, forming a single group, Todos por el
Reencuentro (All for Reunification) which found 650 cases, arranged for 200
people to meet the families from which they had been separated, and estimated
the total numbers of cases to be numbered in the thousands.34

in US Tacit Support for 2009 Coup,” The Guardian (7 December 2017). Available at
https://www.theguardian.com/world/2017/dec/07/crisis-of-honduras-democracy-hasroots-in-us-tacit-support-for-2009-coup
32
Comisión para el Esclarecimiento Histórico (Guatemala) [CEH], Guatemala, Memoria
del Silencio = Tz'inil Na'tab'al, vol. 12 v. ([Guatemala, Guatemala]: CEH, 1998)., capitol
de recomendaciones, p. 66 (my translation)
33
Oficina de Derechos Humanos de Arzobispado de Guatemala [ODHAG], Hasta
Encontrarte: Niñez Desaparecida Por el Conflicto Armado Interno en Guatemala, 3rd
ed. (Guatemala, Guatemala: ODHAG, 2005 [2000])., p. 60.
34
Maco Garavito, personal communication, May 21 2008.

16
23. Human rights groups in El Salvador and Guatemala have collected testimony of
survivors, such as the follow story from Jacinto Guzmán in Guatemala. He told
Todos:
“In 1983, because of the armed conflict and the scorched earth policy that General
Efraín Ríos Montt directed against the population of Nebaj, soldiers captured me
at the Sumal Grande mountain. At that time I was nine years old... During the
years I was separated from my family I suffered a lot because the person who
adopted me treated me very badly. I wasn’t given food, I was beaten for every
little thing, I was discriminated against because I didn’t understand or speak
Spanish…it was a lot of suffering that I lived through. I couldn’t stand all that
mistreatment.”35
Guzmán did not see his family again for 19 years, until he was 28.
24. His mother, Petrona Santiago, also provided testimony about the “acts of
genocide” against indigenous people, including the taking of children:
“Before the war we lived in the village of Vijolom. There we had a little ranch,
our cornfield and some animals. In 1982 the soldiers came among us and began to
kill the people, burned the house, destroyed the crops with a machete, killed and
stole the animals. We were terrified and for that reason we fled to the mountain,
we hid ourselves, but the soldiers stayed a long time in that place. Afterward we
went further, into the mountain of Sumal Grande, but our tortillas ran out, we had
no food, we had no salt, now all we ate was grass with the children. For this
35

Liga Guatemalteca de Higiéne Mental, Corazones en Fiesta: Historias de Familias
Reunidas Despues del Conflicto Armado (Guatemala: Magna Terra Editoriales, 2005)., p.
53.

17
reason one day in the morning, my late husband told me that he was going to go
look for potatoes to eat, because if he did not go the children were going to die of
hunger. I remember that that day Jacinto left with his father to help him, but,
according to my late husband, there was a lot of fog and he didn’t see that the
soldiers were hidden in the mountains. The came out and grabbed him and
Jacinto, who was nine, and then they didn’t come back. From that moment on, I
cried constantly. Suddenly, after four days, my late husband came back alone and
I asked him where Jacinto was, and he said that he had stayed with the soldiers,
that they didn’t want to release him. I only remember that I became very sad and
began to cry for my son. There were times when I thought maybe they were going
to let him go and I was going to wait for him; but my Jacinto never came back.
Thus they took my Jacinto.”36
25. In the decade after 2000, Todos published three books of testimony about
disappeared, adopted, and (sometimes) reunited children.37 For example, a father
who lost his children in 1984, Tomás Choc relates:
“The army surprised us when we were in Guacamayas, Uspantán. It was a day in
which the army surprised the [community’s] look-outs, and when we knew what
was happening, there were soldiers throughout the camp. Bullets flew
everywhere. The only thing we could do was to go out running. When we

36

Ibid., p. 55.
Liga Guatemalteca de Higiéne Mental, De Barro y de Hierro: Familiares de Niñez
Desaparecido en el Conflicto Armado Interno en Guatemala (Guatemala: Liga
Guatemalteca de Higiéne Mental, 2002); Corazones; "Todos Por el Reencuentro,"
http://www.ligatpr.org/; Murillo Estrada and Liga Guatemalteca de Higiéne Mental, A
Voz en Grito: Contra el Olvido y el Silencio.
37

18
succeeded in liberating ourselves from the danger of the soldiers, we started to
look for our children. After a few hours I ran into the terrible surprise that the
children were not with my wife. She didn’t have more than one of our four
children. We looked for them all night and all the next day, but nothing...We
spent several weeks looking for them but failed. Sometimes it was me who gave
up hope and cried, and when she saw me, my wife also collapsed. Other times it
was her; she would cry and her sorrow was contagious to me.38
Years later, he would find one daughter, Ana, married to a soldier; the children
had been adopted by families in other indigenous highlands communities. But it
was not until 2001, and with the help of Todos, that he would learn the fates of all
of them. The youngest, he learned from the adoptive family, had sickened and
died. The two other daughters, they found.
26. Choc’s story points up one of the features that made the Guatemalan experience
of losing children so painful: even if they could be found, not only were they
grown strangers, but almost always they had lost their mother tongue, and adopted
the identity of a different indigenous or ethnic group. “The experience of being
reunited with my daughter made me realize the harm the war did to the whole
family. In addition to the death of my wife, [my children] Magdalena and Jose,
this violence changed us, made us different from each other. Today my children
have other [indigenous or ethnic] identities: Ana is Ladina [Spanish/mestizo],
Julia is Q’eqchi, Catarina is Kiché,” said Choc, who is Ixil.39 His children, like

38
39

Liga Guatemalteca de Higiéne Mental, Corazones.p. 45.
Ibid., p. 49.

19
many found by Todos por el Reencuentro, had been kidnapped by members of the
paramilitary civil patrols (PACs).40
27. Another Maya-Ixil man, Pedro Santiago, told of trying to reconstruct a
relationship with his daughter in the aftermath of her forced disappearance. In
1984, he and his three-year old daughter Rosa were wounded by the same bullet
as he carried her on his back and they were caught in a shower of bullets from
soldiers. Both were taken to the hospital, but separately. Rosa was picked up by
the military and left in another hospital, while her father searched for her in the
first, and she was subsequently adopted by a family from Aguacatán,
Huehuetenango. It was twenty-one years before Pedro Santiago saw her again,
and she arrived for the reunion with her parents wearing the traditional clothing
[traje] of another indigenous group. For Santiago, seeing his daughter in the
“wrong” traje was an event invested with significance.
“The day that they were coming, early in the morning some of our brothers from
the evangelical church came, and all morning we had a musical group and a
religious service to give thanks to God for the life of our daughter. My wife and
other women from the community started making little tamales really early. I
think that they had made a thousand tamales, maybe more. They killed a chicken
and made a stew. At about noon three cars arrived. Then we lit fireworks and
went to meet Rosa. She arrive wearing traje from Aguacatán and her three
daughters with traje from Cobán. When I saw her…my eyes filled with water and
she hugged me. After that my wife received her and her husband. It was a really
40

Ibid.p. 46.

20
happy thing and it brought tears from us. Then we began the activities...[they
prayed, told stories about their lives]. Afterward, my wife took Rosa inside the
house and together with other women they dressed her as an Ixil. For us it is very
important that one day little Rosa returns to her traje from Nebaj and I hope that
she can learn to speak our language, because now she can’t.41
28. When Rosa narrated the story from her point of view, she too dwelt on the traje,
the symbol of her lost Ixil identity.
“When we got there, there were like two hundred people in my parents’ house,
they had arranged everything for me. Later I understood that many were my
family members. My family sure is big! Many people spoke; my father spoke to
everybody in Ixil and Don Pedro [from Todos] was translating for us so I could
understand; my father told how they shot at us both, but the best was to realize
that my family had always loved me and that they too had suffered because of the
war. They dressed me in Ixil traje; I was nervous but I liked it…in front of
everyone they put a wide ribbon through my hair. After that, many of the people
who were there came by and greeted me and gave me money, gifts, food. I was
very emotional.”42
However, distance, poverty, and differences of language prevented them from
seeing each other again after that day.
29. In El Salvador, the Catholic Church was actively involved in searching for and
documenting, the disappearance of children. In 1989, six Jesuit priests were killed

41
42

Liga Guatemalteca de Higiéne Mental, Corazones., 40-41.
Ibid., pp. 43-44.

21
in the middle of the night by the military with their with their housekeeper and
daughter, were killed. One member of that community, Father Jon Cortina, was
away on a pastoral visit to a community, and survived. He went on, five years
later, to found Pro Búsqueda de Niñas y Niños Desaparecidos, a search group for
the children disappeared by the military during the war.43
30. With help from the orphanage director, the human rights commission, and
members of the Catholic Church, parents and children—mostly grown or in their
final years of high school—met again after eleven and a half years. One of the
children, Andrea, described that meeting:
“When the children arrived in a microbus at the plaza [in Guarjila] there
was a big group of people waiting for us. We got out and, in that moment,
the shouting and the hugging began. A tall man hugged [two of the
orphanage children] Marta and Angelica so impetuously that his hat fell
off. They started weeping too. [Another child] Juan Carolos disappeared
into a group of women who all hugged him at the same time.
31. “I didn’t see anybody I knew, and nobody came over to me. Maybe my
family had not come after all. I started to feel worried when someone told
me that my family had come in [to the plaza] from the street. I don’t
remember if it was Father Jon [Cortina], the priest of Guarjila, who told
me: “Those are your parents.” I walked toward them. My parents came

43

Juan Hernández Pico, "Child Adoption: Another Form of Violence." Revista Envío,
November 2008 2008. Laura Briggs, "Interview with Jon Cortina, Founder of Pro
Búsqueda." San Salvador, El Salvador, July 19, 2005. Asociación pro Búsqueda de Niñas
y Niños Desaparecidos, El Día Mas Esperado (San Salvador: UCA Editores, 2001).

22
into the middle [of the plaza] and around them were walking so many
children, big and small, who had to be my brothers and sisters. When I
saw how much one of my little brothers looked like me, I could not
contain my tears. We met at the edge of the little plaza and started to
hug.44
32. News of the meeting—and that disappeared children had been found alive—
spread through rural communities like wildfire. A few months later, in August
1994, families and Cortina founded Pro Búsqueda [For Searching]. Within a few
years, with the help of DNA testing through groups like Physicians for Human
Rights and the hard, slow, sifting and matching of newspaper stories and the
archival records of orphanages, Pro Búsqueda began finding lost children—in
adoptive families in France, in Spain, in the United States.45
33. For the “found” children, as well as their families, integrating their experiences
and renewing their relationships was frustratingly difficult. After more than a
decade of waiting, worrying, and wondering, it was hard to learn that
relationships did not just start over where they had left off; often, there was
unresolvable pain about how the disappearances themselves had taken place. In
Central America in the eighties, militaries and paramilitaries targeted entire
44

Pro Búsqueda, El Día Mas Esperado, p. 39.
Dalton, "Cicatrices No Cerradas de la Guerra."; Dina Coloma, "El
Salvador/Guatemala: "¿Dónde Están Los Niños?" (Where Are the Children?)," Amnesty
International, http://news.amnesty.org/index/ENGAMR020012004; Andrew Buncombe,
"El Salvador's War Children Return to Their Roots," The Independent, July 17 2006;
Joseph Kahn, "War Child Who 'Disappeared' Finds Her Way Back: Mass. Woman Sees
El Salvador Family," Boston Globe, April 5 2007; Larry Rohter, "El Salvador's Stolen
Children Face a War's Darkest Secret," New York Times, August 5 1996; Pro Búsqueda,
El Día Mas Esperado.

45

23
communities, resulting in scenes of murder, mayhem, and anguished flight. As
Andrea understood her story, from her parents and her own memory, he
disappearances began with event know as the Guinda de Mayo (the flight in May
[1982]):
“[When the people got to a place called] Los Alvarenga, they couldn’t get
out. There were a ton of people, maybe a thousand, hidden in the
vegetation of a tiny hill. It was only a question of time before the soldiers
found us. Thus, they said that they were going to try to break through the
wall [of the military]. The guerillas [who were trying to escort the people
past the military] started to shoot and the people to run. In order to
organize its ambushes, the army had hidden in place where they believed
the people would pass. My father had to pass through the middle of the
shooting, running with me against his chest and [her sister] Carmen in his
arms. My mother ran with [another child] Argelia in her arms and Arturo
[the oldest son, ran] with my brother Luis, but with all the people they
could not follow my father. The people ran, terrified. The dead fell before
them and behind them. The wounded on the ground shouted, “Kill me,
please!” because they did not want to continue suffering. In the road, you
could see only the dead and wounded and the uproar of the people who
fled, while the soldier shot at them. Following an avalanche, my father
came to a huge cliff. But the helicopters had arrived. Now they were
shooting from the hills and from the air. The people were throwing
themselves off the cliff, a fall of many meters. They were falling on top of

24
each other, hitting each other, shouting in pain. At the edge of cliff, around
my father, the dead and the wounded were piled up. Others threw
themselves without even looking, as if they didn’t realize there was a cliff
in front of them. My father thought that if he threw himself holding both
girls, we would surely all three die. In this moment, he decided to leave
me. He lay me down under a tree [she had been seriously wounded days
before by a rocket attack on their community, and couldn’t stand] at the
edge of the bank, gave me a final kiss, and jumped with my sister in his
arms…My father was the one who suffered the most from my loss. He
spent months crying and lamenting for having left me. He felt very guilty.
Personally, I think he made the correct decision. Nevertheless, it is a
decision that no one, no human being, ever should be forced to make, a
decision of life or death, save one or the other.”46
34. On a practical level, reunion did not resolve loss. Parents’ and children’s lives had
developed trajectories that were not overlapping. Andrea, for example, intended
to go to college with help from the orphanage. Although she and her parents and
siblings took great pleasure from their meetings, and their subsequent
connections, none of the children went to live with their parents again. Seeing
each other continued to be important, but finding each other did not heal all the
wounds; their lives had taken separate paths for more than a decade. In birth

46

Ralph Sprenkels and the Asociación Pro Búsqueda de Niñas y Niños Desaparecidos,
eds., Historias Para Tener Presente: Los Relatos Extraordinarios de Cinco Jóvenes Que
Perdieron a Sus Familias y Que, Luego de la Guerra, Las Volvieron a Encontrar (San
Salvador: UCA Editores,2002)., pp. 56-57.

25
families, new children had been born, sometimes a mother or father had died and
the surviving partner had remarried. As Pro Búsqueda grew, there was mutual
support but also friction and resentment when some families found their children
and others did not. All—children, parents of found children, parents of lost
children—had been through tremendous upheaval, loss, and trauma. Some had
lost children as a result of guerrilla forces, while the majority had lost their
children to the army. The strength of pro-Búsqueda, though, was that it
simultaneously emphasized political and mental health approaches, and in fact did
not see the two as that different from each other. In support groups, participants
would try to sort out the political context that gave rise to their own, and others,
actions and feelings. Responding to critics who wanted to know why ProBúsqueda couldn’t just leave the question of lost children alone, so many years
after the kidnapping, Jon Cortina spoke in terms of wounds that parents, children,
and the society as a whole carried that could not heal until people knew the truth,
and justice was done.47
35. On March 1, 2005, pro-Búsqueda won a significant legal victory in seeing the
military held responsible for the kidnapping of children. The military had long
insisted that it had only acted in humanitarian ways, picking up lost children and
taking them to the Red Cross; under unusual circumstances, raising war orphans

47

Dalton, "Cicatrices No Cerradas de la Guerra."; Rosa América Laínez Vilaherrera,
Gianina Hasbún Alvarenga, and Asociación pro Búsqueda de Niñas y Niños
Desaparecidos, Tejiendo Nuestra Identidad: Sistematización de la Experiencia del
Equipo de Psicología de Pro-Búsqueda (San Salvador: UCA Editores, 2004).

26
in military barracks and teaching them skills.48 In 2005, though, the InterAmerican Court of Human Rights issued a decision condemning the Salvadoran
government in the case of the Serrano Cruz sisters, Ernestina and Erlinda, who at
the ages of 2 and 7 were taken from their family at gunpoint during the military’s
“Operacion Limpieza” (Operation Clean-Up) in 1982. As they watched, family
members said, soldiers took the little girls into a military helicopter, which flew
away and disappeared. The girls have never been found, nor have the individuals
responsible been identified. Their mother initiated the case, but did not live to see
its fruition, but their sister, Suyapa, was able to testify in her stead. The
Salvadoran government, for its defense, suggested that the girls never existed—
the logical culmination of the process of “disappearance.” The court ordered the
Salvadoran government to apologize to the family, to make monetary restitution,
to open the military archives to searchers, and to develop a state-level
organization to find Salvador’s lost children.49 The government ignored the court
order.
36. Most of the leadership of the Guatemalan and Salvadoran militaries in these
decades were trained by the U.S. military and intelligence in counterinsurgency.50
There is no clear evidence on way or another about whether this was a tactic

48

Rohter,‘‘Salvador’s Stolen Children.”
Juan José Dalton, "Ante la Corte Interamericana," Proceso, 22 marzo 2005; Dalton,
"Cicatrices," Proceso, 25 October 2003; Juan José Dalton, "El Salvador: La Deuda Con
Los Niños Deaparecidos," Proceso, 8 March 2003; Marcelo Izquierdo, "Abuelas de la
Plaza de Mayo: 25 Años de Búsqueda," Proceso, 25 October 2002.
50
Greg Grandin, Empire’s Workshop: Latin America, the United States, and the Rise of
the New Imperialism (New York: Metropolitan, 2006).
49

27
promoted by the United States, and hence whether it was directly modeled on
boarding school policy, or only copied.
37. The children that lived through the Guatemalan and Salvadoran governments’
policy of child separation were born in the 1970s and eighties. They are the
generation of the parents and grandparents of children currently being separated at
the United States border.

Exhibit 49

1
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

8
9

STATE OF WASHINGTON, et al.,

10
11
12
13

NO. 2:18-cv-00939 - MJP

Plaintiffs,

DECLARATION OF
MARTHA S. JONES

v.
DONALD TRUMP in his official capacity
as President of the United States, et al.,
Defendants.

14
15

I, Martha S. Jones, declare as follows:

16

1.

I am over the age of 18 and have personal knowledge of all the facts stated herein.

17

2.

I joined the Johns Hopkins University Krieger School of Arts and Sciences

18

Department of History on June 1, 2017 as the Society of Black Alumni Presidential Professor

19

and Professor of History. I came from the University of Michigan College of Literature, Science,

20

and the Arts where I was a Presidential Bicentennial Professor, Professor of History and

21

Afroamerican and African Studies. I was a founding director of the Michigan Law School

22

Program in Race, Law & History and a senior fellow in the Michigan Society of Fellows. I hold

23

a Ph.D. in history from Columbia University and a J.D. from the City University of New York

24

School of Law. My curriculum vitae, a true and correct copy of which is attached as Exhibit A,

25
26

DECLARATION OF
MARTHA S. JONES
2:18-CV-00939 - MJP

1

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
206-464-7744

I

further details my qualifications and lists all of the publications I have authored in the previous

2

10 years.

3

3.

4

A true, correct and complete statement of my opinions, the bases and reasons for

them, and the facts and data I considered in forming them is attached as Exhibit B.

5

4.

6

I declare under penalty of perjury under the laws of the State of Washington and the

7
8

I am being paid $1,000 for my study and testimony in this case.

United States of America that the foregoing is true and correct.
France

Paris

DATED this 2nd day of July, 2018 at

10
Martha S. Jones
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12
13
14
15
16
17
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19
20
21
22
23
24
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DECLARATION OF
MARTHA S. JONES
2:18-CV-00939 - MJP

2

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
206-464-7744

Exhibit A

MARTHA S. JONES
Society of Black Alumni Presidential Professor
Professor of History
Johns Hopkins University
301 Gilman Hall
Baltimore, MD 21201
410-516-7575. [e-mail]
www.marthasjones.com
ACADEMIC APPOINTMENTS
Johns Hopkins University, Krieger School of Arts and Sciences. Baltimore, Maryland.
SOBA (Society of Black Alumni) Professor of History. 2017-present.
Gilder-Lehrman Institute of American History, Summer Teacher’s Institute, NY. 2002-present.
Instructor, Reconstruction: America’s Unfinished Revolution (with Eric Foner).
University of Michigan, College of Literature, Science and Arts. Ann Arbor, MI. 2001- 2017.
Presidential Bicentennial Professor. 2016-2017.
Arthur F. Thurnau Professor. 2013-2017.
Professor of History and Afroamerican and African Studies. 2015-2017.
Associate Professor of History and Afroamerican and African Studies. 2007-2015.
Assistant Professor of History and Afroamerican and African Studies. 2001-2007.
University of Michigan Law School, Ann Arbor, MI. 2004-2017.
Affiliated LSA Faculty. 2010-2017.
Visiting Professor of Law. 2008-2017.
Visiting Assistant Professor of Law. 2004-2007.
École des Hautes Études en Sciences Sociales (EHESS), Paris, France. 2006, 2007 & 2009.
Directrice d’Études Invitée.
Barnard College. New York, NY. 2000-2001.
Visiting Assistant Professor of History.
New School University, Eugene Lang College. New York, NY. 1997-2001
Adjunct Lecturer.
EDUCATION
COLUMBIA UNIVERSITY, New York, NY
Ph.D. History 2001; M. Phil. History 1998; M.A. History 1997.
CITY UNIVERSITY OF NEW YORK (CUNY) SCHOOL OF LAW, Queens, NY
J.D. 1987.
HUNTER COLLEGE, New York, NY
B.A. 1984.
HONORS AND AWARDS (selected)
Berkshire Conference of Women Historians. Co-President. 2017-present.
Organization of American Historians. Executive Committee. 2017-present.

Jones, 1 of 14

William L. Clements Library. Board of Governors. Member. 2018-present.
Organization of American Historians. Distinguished Lecturer. 2010-present.
Princeton University. Program in Law and Public Affairs. Fellow. 2017-18. (declined.)
Harvard University. Radcliffe Institute for Advanced Study. Fellow. 2016-17. (declined.)
University of Michigan. Presidential Bicentennial Professor. 2016-2017.
Michigan Society of Fellows. Senior Fellow. 2015-2017.
National Humanities Center. William C. and Ida Friday Fellow. 2013-14.
American Council of Learned Societies. Fellow. 2013-14
University of Michigan. Arthur F. Thurnau Professorship. 2013-2017.
University of Michigan. Harold R. Johnson Diversity Service Award. 2011.
University of Michigan. Office of the Vice President for Research. Michigan Humanities Award. 2010-11.
Columbia University. Center for the Critical Analysis of Social Difference. Visiting Fellow. 2009-11.
University of Michigan. Eisenberg Institute for Historical Studies. Faculty Fellow. 2009-2010.
University of Pennsylvania Law School and the National Constitution Center. Visiting Scholar. 2008.
Gilder-Lehrman Institute Fellowship in American History. Research Fellowship. 2003-04.
The Library Company of Philadelphia and Historical Society of Pennsylvania. Research Fellowship. 2003-04.
University of Michigan. Institute for the Humanities. Michigan Faculty Fellowship. 2003-04.
BOOKS
Birthright Citizens: A History of Race and Rights in Antebellum America (New York: Cambridge University Press,
2018.)
All Bound Up Together: The Woman Question in African-American Public Culture, 1830-1900 (University of North
Carolina Press, 2007.)
EDITED VOLUMES
Editor. Toward an Intellectual History of Black Women, eds. Mia Bay, Farah J. Griffin, Martha S. Jones and Barbara
D. Savage. (University of North Carolina Press, 2015.)
Guest editor. Proclaiming Emancipation. Journal of the Civil War Era. 3, no. 4 (December 2013.)
Editor. Women & Performance: A Journal of Feminist Theory. Special Issue: Pass*ing. Co-editor, with John L. Jackson,
Jr. 29, no. 1(Fall 2005.)
ARTICLES (selected)
“Navigating Free Black Citizenship: Port City Encounters from Baltimore to Rio de Janeiro," in Whitney
Stewart and John Marks, eds. Race and Nation in the Age of Emancipations (University of Georgia Press,
2018.)
“Forgetting the Abolition of the Slave Trade in the United States: How History Troubled Memory in 2008.”
Distant Ripples of the British Abolitionist Wave? Africa, the Americas and Asia, eds. Myriam Cottias and Marie
Jeanne Rossignol (Trenton, NJ: Africa World Press Tubman Institute Series, 2018.)
“Birthright Citizenship and Reconstruction’s Unfinished Revolution,” in Forum: The Future of
Reconstruction Studies, Journal of the Civil War Era 7, no. 1 (March 2017): 10.
“False Starts, Missed Opportunities, and a Pioneering Historian,” The Quarto 46 (Fall-Winter 2016.)
“First the Streets, Then the Archives,” American Journal of Legal History 56, no. 1 (March 2016): 92-96.

Jones, 2 of 14

“Marin et citoyen : être noir et libre à bord des navires états-uniens avant la Guerre civile.” Le Mouvement
Social 3 (2015): 93-112.
“Histories, Fictions, and Black Womanhood Bodies: Rethinking Race, Gender, and Politics in the TwentyFirst Century.” Toward an Intellectual History of Black Women, eds. Mia Bay, Farah Griffin, Martha S.
Jones and Barbara D. Savage (University of North Carolina Press, 2015.)
“History and Commemoration: The Emancipation Proclamation at 150.” Journal of the Civil War Era, 3, no. 4
(December 2013): 452-457.
“Emancipation’s Encounters: Seeing the Proclamation Through Soldiers’ Sketchbooks.” Journal of the Civil
War Era, 3, no. 4 (December 2013): 533-548.
“Hughes v. Jackson: Race and Rights Beyond Dred Scott.” 91, no. 5 North Carolina Law Review (June 2013):
1757-1783.
“The Case of Jean Baptiste, un Créole de Saint-Domingue: Narrating Slavery, Freedom, and the Haitian Revolution
in Baltimore City.” Chapter 5 in The American South and the Atlantic World eds. Brian Ward, Martin Bone,
and William A. Link (Gainesville: University Press of Florida, 2013): 104-128.
“Historians’ Forum: The Emancipation Proclamation.” (with Kate Masur, Louis Masur, James Oakes, and
Manisha Sinha.) 59, no. 1 Civil War History (March 2013.)
“Time, Space, and Jurisdiction in Atlantic World Slavery: The Volunbrun Household in Gradual
Emancipation New York.” Law and History Review 29, no 4 (November 2011): 1031-1060.
“Overthrowing the ‘Monopoly of the Pulpit’: Race and the Rights of Churchwomen in Nineteenth Century
America.” No Permanent Waves: Recasting Histories of U.S. Feminism, ed. Nancy Hewitt (New Brunswick, NJ:
Rutgers University Press, 2010.)
“Leave of Court: African-American Legal Claims Making In the Era of Dred Scott v. Sandford.” Contested
Democracy: Politics, Ideology and Race in American History, eds. Manisha Sinha and Penny Von Eschen
(New York: Columbia University Press, 2007.)
“Make us a Power”: African-American Methodists Debate the Rights of Women, 1870-1900.” Women and
Religion in the African Diaspora, eds. R. Marie Griffith and Barbara D. Savage. (Baltimore, MD: Johns
Hopkins University Press, 2006).
“Perspectives on Teaching Women’s History: Views from the Classroom, the Library, and the Internet,”
Journal of Women’s History 16, no. 2 (Fall 2004): 143-176.
ESSAYS and COMMENTARY (selected)
“’I Had a Dream About You Last Night – A Sexual Dream’: Women Have Heard It All,” Chronicle of
Higher Education. April 2018.
“Trump Said Protesting NFL Players ‘Shouldn’t Be in This Country,’” Washington Post, May 2018.
“Demoting ‘Maryland, My Maryland’ Ends a Struggle Begun by Black Baltimoreans in 1863,” History
News Network, April 1, 2018.
“Michelle Obama and the Black Women of the White House,” Washington Post. February 2018.
“The Blood is in the Details: When Scars of Slavery are Markers of Freedom.” Muster: The Blog of the
Journal of the Civil War Era. December 1, 2017.
“Why Calling Elizabeth Warren ‘Pocahontas’ is a Slur Against All Mixed-Race Americans.” Washington
Post. November 29, 2017.
“What Mark Lilla Gets Wrong About Students.” The Chronicle Review. August 2017.
“The 14th Amendment Solved One Citizenship Crisis, but it Created a New One.” Washington Post. July
2017.

Jones, 3 of 14

“Before Frederick Douglass: William Watkins Speaks for Black Americans on Independence Day. July 4,
1831.” Medium. July 4, 2017.
“At the University of Michigan, Confronting Controversy to Move Forward.” Detroit Free Press. April 2017.
“Ava Duvernay’s 13th: It’s About Hope, Not History.” Medium. October 30, 2016.
“Are There New Lives for Old Objects at the National Museum of African American History and Culture?”
Muster: The Blog of the Journal of the Civil War Era. October 2016.
“Thurgood Marshall and His Hometown Courthouse.” We’re History. July 2016.
“The Color of History.” Color Code: The Exhibition Catalog (Ann Arbor: University of Michigan
Department of Afroamerican and African Studies, 2016.)
“Julian Bond’s Great-Grandmother a “Slave Mistress?: How the New York Times Got it Wrong.” History
News Network. August 2015.
“We Are the Intellectuals.” Roundtable: Toward an Intellectual History of Black Women.” African-American
Intellectual History Society Blog. June 5, 2015.
“On The Cherokee Rose, Historical Fiction, and Silences in the Archives.” Process: The Blog of the
Organization of American Historians. May 26, 2015.
“Who Here is a Negro?” Michigan Quarterly Review. 53, no. 1 (Winter 2014): 23-28.
“Why We Still Need “Black History Month, Even Though #28DaysAreNotEnough.” CNN. February 25,
2015.
“From Michael Stewart to Michael Brown: A Reflection on #FergusonOctober.” Huffington Post. November
14, 2014.
“Supreme Court Ruling Upholds America's Mixed View.” CNN. April 24, 2014.
“Who Here is a Negro?” Michigan Quarterly Review. 53, no. 1 (Winter 2014): 23-28.
“When it Comes to Diversity, Who Counts?” Huffington Post. March 26, 2014.
“What’s in a Name? Mixed, Biracial, Black.” CNN. February 19, 2014.
“Biracial, and also Black.” CNN. February 12, 2014.
“History, Myth and the Emancipation Proclamation.” Proclaiming Emancipation: The Exhibition Catalogue (Ann
Arbor, MI: The William L. Clements Library, 2013.)
“Turning Back the Time of Racism.” Huffington Post. February 12, 2013.
“Understanding Race.” Huffington Post. February 5, 2013.
“A Bellwether: Phil Lapsansky at the Library Company of Philadelphia.” Phil Lapsansky: Appreciations
(Philadelphia, PA: Library Company of Philadelphia, 2012.)
“Edward Clay’s Life in Philadelphia.” An Americana Sampler: Essays on Selections from the William L. Clements
Library, eds. Brian Leigh Dunnigan and J. Kevin Graffagnino (Ann Arbor, MI: The William L. Clements
Library, 2011).
“Reflections of an Archive Rat.” (Ann Arbor, MI: The William L. Clements Library, 2009.)
“Reframing the Color Line.” Reframing the Color Line: The Exhibition Catalog (Ann Arbor, MI: The William L.
Clements Library, 2009.)
“Learning a Pedagogy of Love: Thomas Merton.” Living Legacies at Columbia, ed, Wm. Theodore de Bary
(New York: Columbia University Press, 2006.)
“Mining Our Collective Memory: Beyond the Academic-Activist Divide in Black Studies,” Souls: A Critical
Journal of Black Politics, Culture, and Society. 6, no. 3/4 (October 2004): 71-76.

Jones, 4 of 14

CURATORIAL EXPERIENCE
“Stumbling Blocks.” University of Michigan President’s Bicentennial Colloquium on the Future University
Community. May 2017. Creator and curator.
“The Arabella Chapman Project.” www.arabellachapman.com. June 2015.
“Proclaiming Emancipation.” The William L. Clements Library. Ann Arbor, Michigan. October 2012February 2013. Co-curator, with Clayton Lewis.
“Revolution: The Atlantic World Reborn.” New-York Historical Society. November 2011-April 2012.
Historical advisor.
“Reframing the Color Line: Race and the Visual Culture of the Atlantic World.” The William L. Clements
Library. Ann Arbor, Michigan. October 2009 –February 2010. Co-curator, with Clayton Lewis.
“And Still We Rise” (permanent exhibition.) The Charles H. Wright Museum of African American History.
Detroit, Michigan. 2003. Historical advisor.
BOOK REVIEWS
“Review of Redemption Songs: Suing for Freedom before Dred Scott by Lea Vandervelde, in Law & History Review 33,
no. 4 (November 2015): 1009-1011.
“Review of Encountering Revolution: Haiti and the Making of the Early Republic by Ashli White,” in Slavery &
Abolition 33, no 1 (March 2012): 187-189.
“Review of What Blood Won’t Tell: A History of Race on Trial by Ariela J. Gross,” in Law & Society Review 44,
no. 3-4 (September/December 2010): 877-79.
“Review of Sarah Johnson’s Mount Vernon: The Forgotten History of an American Shrine by Scott E. Casper,” in
The American Historical Review, 114, no. 5 (December 2009).
“Review of ‘We Are Coming’: The Persuasive Discourse of Nineteenth-Century Black Women by Shirley Wilson
Logan,” in Gender & History. 16, no. 1 (April 2004).
“Review of Disciples of Liberty: The African Methodist Episcopal Church in the Age of Imperialism, 1884-1916 by
Lawrence Little.” The North Star: A Journal of African-American Religious History, 7, no. 2 (Spring
2004).
“Review of Come Shouting to Zion: African American Protestantism in the American South and British Caribbean
To 1830 by Sylvia Frey and Betty Wood,” in The North Star: A Journal of African-American Religious History, I,
no. 2 (Spring 1998).
INVITED PRESENTATIONS (selected)
2018
“Belonging.” Commencement Address. University of Michigan, Flint. May.
“A New History of the 14th Amendment: Birthright Citizens.” National Constitutional Center. April.
“Birthright Citizens.” University of Connecticut. April.
“George Hackett’s Journey to Birthright Citizenship.” University of Texas, Dallas. Dallas, TX. April.
“Citizenship: Race, Gender, and Foreignness.” Radcliffe Institute, Harvard University. Cambridge, MA. April.
“Walking Roger Taney’s Walk: Memory and the Notorious.” Duke University. Durham, NC. March.
“Slavery and Memory: Remembering and Forgetting Enslavement in Popular Culture, Law, and the
University: Comment.” International Association of Inter-American Studies. Coimbra, Portugal. March.

Jones, 5 of 14

“Which Marriage is a “Black” Marriage: Rethinking the Color Line in Tera Hunter’s Bound in Wedlock,” Red
Emma’s Bookstore. Baltimore, MD. March.
“Birthright Citizens.” University of Georgia. Athens, GA. February.
“Who Are We? Who Might We Want to Become as Historians?” Yale University. New Haven, CT. February.
“History, Memory, and a Pseudo-Confederate Past: Taking Down Monuments in Baltimore City,” Roger
William School of Law. Bristol, RI. January.
2017
“Confederates, Monuments, and the Curious Case of Baltimore’s Roger B. Taney.” Ecole des Hautes Etudes
en Sciences Sociales. December.
“Birthright Citizens: Winner and Losers in the Long History of the 14th Amendment.” Notre Dame Law
School. November.
“The Power of History; The Urgency of Now.” Yale University, Gilder-Lehrman Center for the Study of
Slavery, Resistance, and Abolition,” November.
“What is Justice in the Case of Celia, A Slave?” Historians Against Slavery UK. October.
“Confederates, Monuments, and the Curious Case of Baltimore’s Roger B. Taney.” Duke University, Center
for Scholars and Publics. September.
“The Changing Face of Higher Education.” National Association of College and University Business
Officers Annual Meeting. August.
“Toward an Intellectual History of Black Women…and Back.” Keynote. Conservative/Progressive Summit.
Hauenstein Center, Grand Valley State University. May.
“Threats of Removal.” University of Miami School of Law. April.
“Writing Black Women’s Intellectual History.” Tulane University. March.
“Toward an Intellectual History of Black Women.” With Tiya Miles and Megan Sweeney. Institute for
Research on Women and Gender. University of Michigan. January.
“Threats of Removal.” Rutgers School of Law. January.
2016
“Threats of Removal.” University of Virginia Law School. November.
“Finding William Yates.” History Department. University of Pennsylvania. November.
“To See and be Seen: A Tribute to Mary Frances Berry,” Plenary. Association for the Student of African
American Life and History. October.
“Threat of Removal,” History Department. Johns Hopkins University. October.
“A History of the South: Colonization, Birthright and the Rights of Black Americans.” History Department.
University of North Carolina, Chapel Hill. September.
“Wade in the Water,” Bennett College. September.
“Fugitivity, Irredeemablity, and the Law of Black Boyhood,” Law and Humanities Junior Scholar Workshop.
UCLA School of Law. June.
“Seeing Slavery in the Juridical Archive: Signatures and Signs.” Le Centre de Recherches sur le Brésil Colonial
et Contemporain. École des Hautes Études en Sciences Sociales (EHESS), Paris. May.
"Birthright Citizens: Race and Rights in Antebellum America." Centre international de recherches sur les
esclavages. École des Hautes Études en Sciences Sociales (EHESS). Paris, France. May.
“The Color of History.” Marking Race, Making History: A Conference in Celebration of the Career of
Thomas Hot. University of Chicago. April.

Jones, 6 of 14

"Birthright Citizens: Race and Rights in Antebellum America." University of Wisconsin Law School. March.
"The Children of Loving v. Virginia: Law and Mixed Race Identity." Sciences Po (Paris.) March.
"Celia, A Slave: The History and Memory of Slavery and Sexual Violence." William Woods College. March.
"#SayHerName: Celia and the History of Slavery and Sexual Violence." University of Missouri. March.
"The Children of Loving v. Virginia: Law and Mixed Race Identity." University of Southern California (USC)
Program in Law, Culture and the Humanities. March.
"Birthright Citizens: A History of Race and Rights in Antebellum America." University of Southern California
Law School. March.
"Birthright Citizens: Race and Rights in Antebellum America." University of Detroit Mercy. February.
"The Criminalization of Poverty: An Origins Story." University of Michigan Law School. February.
"The Cherokee Rose: A Conversation with Tiya Miles." University of Michigan Library. January.
2015
"What is the Color of History?" Multiracial in a Monoracial World, University of Michigan Library. 2015.
"Red, White and Black: Writing a History of Mixed Race Identity." John Hope Franklin at 100. Duke
University. November.
"Showdown & Thurgood Marshall." With Will Haygood. Literati Booksellers. October.
"Landmark Cases: Dred Scott v. Sanford." CSPAN. October.
"Comment on Tomlins Freedom Bound." North American Labor History Annual Conference. 2015.
"Overturning Dred Scott." Association for the Study of Afroamerican Life and History Annual Meeting.
September.
"The Children of Loving v. Virginia." Franklin College. Franklin, Indiana. September.
"The Arabella Chapman Project." University of Michigan EIHS. September.
"Toward an Intellectual History of Black Women." Vineyard Haven Public Library. August.
"Toward an Intellectual History of Black Women." CIRESC (Paris.) June.
"Birthright Citizens." Columbia University Reid Hall (Paris.) June.
"Comment on Elijah Anderson's The Cosmopolitan Canopy." CNRS Pouchet (Paris.) June.
"Family, History, and Writing the Past of Mixed-Race Identity." Organization of American Historians. April.
"Silence and Slavery's Shards. Allure of the Judicial Archives." University of Michigan Law School. April.
"Reparation: A Conversation with Ta-Nehisi Coates." Duke University. March.
"Love and the Ethics of Law Practice". Keynote. Juan Tienda Dinner. University of Michigan Law School.
March.
“Navigating Free Black Citizenship: Port City Encounters from Baltimore to Rio de Janeiro.” Keynote.
Reperiodizing Latin America’s Nineteenth Century. Yale University. New Haven, CT. February.
“Black Women, Law, and the Politics of Pleasure.” Shondaland Symposium. Duke University. January.
“Children of Loving v. Virginia: Living at the Intersection of Law and Mixed-Race Identity.” Martin Luther
King, Jr. Day Address. University of Michigan Law School. January.
2014
“The State of Missouri v. Celia, a Slave: A History of Slavery and Sexual Violence.” CSPAN American
History TV. October 2014.
“Navigating Free Black Citizenship: From Baltimore to Valparaiso.” Circulation des Catégories Juridiques
et des Catégories Racial dans l'Espace Atlantique. École des Hautes Études en Sciences Sociales
(EHESS), Paris, France. June.

Jones, 7 of 14

“The Slaves’ Emancipation: How Lincoln's Proclamation Became Law.” City College of New York.
New York, NY. June.
“Rights that Cannot be Annulled”: Travel, Guns, and the Possibilities of Black Laws in Baltimore City.”
American Bar Foundation. Chicago, IL. May.
“Reading Kara Walker as Historian.” St. Louis Museum of Art. St. Louis, MO. May.
“Rights that Cannot be Annulled”: Travel, Guns, and the Possibilities of Black Laws in Baltimore City.”
Johns Hopkins University Department of History. Baltimore, MD. April.
““One hand upon the Constitution and the other upon the Discipline of the Church”: Church, State, and
Citizenship in Antebellum Baltimore.” Duke University Law School. Durham, NC. March.
“The Politics of Privacy: Black Women and the Culture of Dissemblance.” University of Michigan. Honors
Convocation. March.
“Civil Rights 2014.” Black History Month Keynote. Bennett College for Women. Greensboro, NC.
February.
“Navigating Free Black Citizenship: Port City Encounters from Baltimore to Rio de Janeiro.” Race and
Nation in the Age of Emancipation. Rice University, Houston, TX. February.
2013
“Hughes v. Jackson: Race and Rights Beyond Dred Scott." Duke University Law School. Durham, NC.
November.
Citizenship Before Birthright: The Puzzle of Free African Americans Prior to the 14th Amendment.”
National Humanities Center. Durham, NC. November.
“Emancipation as Translation: How Lincoln's Proclamation Became Law.” Center for the Study of Slavery
and Justice. Brown University. Providence, RI. November.
"Overturning Dred Scott: Race, Rights, and Citizenship in Antebellum America.” Triangle Legal History
Seminar. Research Triangle Park, NC. October.
“The Illogics of Race and Law in the Nineteenth Century United States.” University of Nantes (France.)
June.
“Popote: A Life History of Slavery and Law and the Haitian Diaspora.” École des Hautes Études en Sciences
Sociales. May.
“Governing the Free Black Family: Reflections on Scenes from Antebellum Baltimore.” Center for African
American Studies. Princeton University. April.
“One hand upon the Constitution and the other upon the Discipline of the Church”: Church, State, and
Citizenship in Antebellum Baltimore Religion Department. Princeton University. February.
2012
“The Illogics of Race and Law in the Nineteenth Century United States.” Systèmes de castes et systèmes
esclavagistes, Fondation Maison des Sciences de l’Homme (FMSH,) Paris. France. December.
“Hughes v. Jackson: Race and Rights Beyond Dred Scott.” Race Law Trials. University of North Carolina
Law School. October.
“Leave of Court: Race and the Right to Interstate Travel in the Era of Dred Scott.” Borders and Belonging
Sawyer Seminar. Rutgers University. October.
“Emancipation’s Encounters: Seeing the Proclamation Through Soldiers’ Sketchbooks.” Proclaiming
Emancipation. University of Michigan. October.

Jones, 8 of 14

“Popote: A Life History of Slavery and Law and the Haitian Diaspora.” Early American Biographies. The
Omohundro Institute and the University of Southern California-Huntington Library Early Modern
Studies Institute. The Huntington Library. Los Angeles, CA. June 2012.
“Re-enslavement and the Saint-Domingue Diaspora.” Duke University Haiti Lab. Durham, NC. March 2012.
“The Right to Travel: From the Baltimore City Courthouse to the US Supreme Court.” Black History Month
Meeting. Library Company of the Baltimore Bar. Baltimore, MD. February 2012.
2011
“Slave or Free?: Tracing Generations Through the Diaspora of Saint-Domingue/Haiti.” Keynote Address.
Berkshire Conference on the History of Women. Amherst, MA. June.
"Mulattoes and Other Tragedies in a Post-Obama America." University of Nottingham Law School. March.
“Writing the History of Slavery From the Artifacts of Law: A Perspective From the Local Courthouse.”
Reprèsentations de l’escalvage dans les Amériques (1763-1865.) UFR d’Études Anglophones, Université
Paris-Diderot. February.
“Reframing the Color Line: Race and Visual Culture in the Atlantic World.” École des Hautes Études en
Sciences Sociales (EHESS.) February.
“Court House Stories: The Everyday Life of Freedom.” With Liberty and Justice for All Martin Luther King,
Jr. Day Lecture. Henry Ford Museum. January.
2010
“Rituals of Rights in the Discharge of Debts: Overturning Dred Scott v. Sandford in Baltimore City.” Faculty
Workshop. University of Southern California Law School. October.
“Bearing Arms in Baltimore City: From Claims-making to Citizenship in the Era of Dred Scott.” Center for
Law, History and Culture, University of Southern California Law School. October.
“Time, Space, and Jurisdiction in Atlantic World Slavery: Freeing “French Negroes” in New York’s Era of
Gradual Emancipation,” Department of History. University of Southern California. October.
“The Case of Jean Baptiste, un Créole de Saint-Domingue: Narrating Slavery, Freedom, and the Haitian Revolution
in Baltimore City.” “W[h]ither the Atlantic World?: Understanding the American South in Transatlantic
Context.” Understanding the South, Understanding America Network. Clare College. Cambridge
University. May.
“I was born in…Croix-des-Bouquets”: Time, Space, and Jurisdiction in Gradual Emancipation New York.”
Haiti and History. Center for History and Economics. Harvard University. May.
“The Case of Jean Baptiste, un Créole de Saint-Domingue: Narrating Slavery, Freedom, and the Haitian Revolution
In Baltimore City.” Legal History Colloquium. New York University School of Law. April.
“Arming Black America: Race and Citizenship in the Era of Dred Scott v. Sandford.” Remaking Heritage Series.
Institute for the Humanities. University of Michigan. February.
“Rituals of Rights in the Discharge of Debts.” New York University, Department of History. New York, NY.
January.
“Rituals of Rights in the Discharge of Debts.” Legal Theory Workshop. University of Michigan Law School.
January.
“Remembering Lincoln in African American Visual Culture.” Lincoln in American Culture's Collective
Memory. The Ginsberg Center Arts of Citizenship Program and the University Musical Society.
University of Michigan. January.
“Race and National Memory in the Era of Barack Obama.” 23rd Annual Martin Luther King Day Celebration.
University of Michigan. January.

Jones, 9 of 14

2009
“Rituals of Rights and the Discharge of Debts.” Washington University in St. Louis School of Law. St. Louis,
MO. November.
“I was born in…Croix-des-Bouquets”: Time, Space, and Jurisdiction in Gradual Emancipation New York.”
Legal History Workshop. University of Michigan Law School. September.
“I was born in…Croix-des-Bouquets”: Time, Space, and Jurisdiction in Gradual Emancipation New York.”
American History Workshop. New York University. September.
“Overthrowing the ‘Monopoly of the Pulpit’: Race and the Rights of Churchwomen in Nineteenth Century
America.” Transregional Perspectives on Religion, Race, and Gender in History. University of Erfurt,
Erfurt, Germany. June.
“Confessions of an ‘Archive Rat’: The Many Histories of a Library.” Founder’s Day. The William L.
Clements Library. University of Michigan. Ann Arbor, MI. April.
“I was born in…Croix-des-Bouquets”: Space, Time, and Jurisdiction in Atlantic World Slavery.” Department
of History. Emory University. March.
"From Toussaint to Soulouque: Envisioning Haiti in Civil War-Era America." Museum of Southern History
Symposium on Southern History: The South and the World in the Civil War Era. Rice University,
Houston, TX. February 209.
2008
“The Politics of Reconstruction: The Intersections of Race and Gender, Then and Now.” The National
Constitution Center. Philadelphia, PA. November.
“I was born in…Croix-des-Bouquets”: Space, Time, and Jurisdiction in Atlantic World Slavery.” Department
of History. University of Maryland. November.
“Overturning Dred Scott v. Sanford: Everyday Histories of Race and Rights in American Legal Culture.”
University of Pennsylvania Law School. September.
2007
“La Question des Femmes dan la Culture Afroaméricaine.” Colloque Procréation et Democratie: GrandeBretagne, Etats-Unis, France.” UFR d’Études Anglophones – LARCA. Université Paris 7-Denis Diderot.
December.
“The Case of Jean Baptiste, Créole de Saint-Domingue: Writing the History of Slaves from the Artifacts of Law."
Histoire(s) atlantique(s) : L’Atlantique des Français, des Espagnols et des Américains. Université Paris 7Denis Diderot. June.
""Right Is Of No Sex": 1848 and the African American Framing of Women's Rights." Sociohistoire des
Pratiques Culturelles (XVI-XVIII siecle.) École des Hautes Études en Sciences Sociales (EHESS.) May.
"The Case of Jean Baptiste, un Créole de Saint-Domingue: Writing the History of Slaves from the Artifacts of
Law. Micro-Histoire et Histoires de Vie d'Esclaves. RTP-Esclavages. Paris, France. May.
“The Haitian Revolution in History and Memory: Surrogation, from Habitacion Drouillard to Project
Drouillard." Law and Political Development in Modern America. University of Pennsylvania Law School
and University of Chicago. Legal History Consortium. February.
"Finding the Juridical Agency of the Enslaved: The Case of Jean Baptiste, Créole de Saint-Domingue." Columbia
University, Department of History. January.

Jones, 10 of 14

CONFERENCE PRESENTATIONS (selected)
2018
“Black Women Rewrite the History of Women’s Suffrage.” Organization of American Historians.
Sacramento, CA. April 2018.
“Birthright Citizens.” American Association of Law Schools (AALS), Constitutional Law and Legal History
Sections Keynote. San Diego, CA. January.
“History, Fiction, and the Space in Between: Writing Histories of the Self.” American Historical Association.
Washington, DC. January.
2017
“Reading Cooper’s Beyond Respectability.” National Women’s Studies Association. November 2017.
“Reflections on Brophy’s Court, University, and Slave.” Southern Historical Association. November 2017.
“Slavery and Film: The Long Shadow of Birth of a Nation.” Society for Cinema and Media Studies. March
2017.
“Comment: Biography: An Evolving and Innovative Methodology for African American Intellectual
History.” African American Intellectual History Society. Vanderbilt University. Nashville, TN. March
2017.
“Comment: African American Intellectuals in the Atlantic World: Challenging Social, Political, and
Intellectual Boundaries.” African American Intellectual History Society. Vanderbilt Univeristy, Nashville,
TN. March 2017.
“The Two Stories of William Yates.” Emancipation Proclamations. CUNY Graduate Center and University
of Pennsylvania McNeil Center. February 2017.
2016
“Citizenship During Emergency: Birthright in the 19th Century United States. American Society for Legal
History. November.
2015
"Shards and Silence in Slavery's Archive." American Society for Legal History. November.
"Abigail's Story: Slavery, History and Memory in France and the US." Association for the Study of
Afroamerican Life and History. September.
"Enslaved Women Waging Law in the Nineteenth-Century American South." SHEAR Annual Meeting. July.
"We Are the Intellectuals." CAAR Bi-Annual Meeting, Liverpool. June.
“Beyond Mulatto: How to Write the History of Our Mixed-Race Past, and Present.” Organization of
American Historians. St. Louis, MO. April.
“The Children of Loving v. Virginia: Living at the Intersection of Law and Mixed-Race Identity.” Martin
Luther King, Jr. Day Lecture. University of Michigan Law School. Ann Arbor, MI. January.
“Finding Our Truths in the Judicial Archive.” American Historical Association. New York, NY. January.
“No Straight Line: Reflections on the JD-PhD Track.” American Historical Association. New York, NY.
January.

Jones, 11 of 14

2014
“Beyond the Bi-Racial South: How to Re-Tell Our Mixed-Race Past.” Southern Historical Association.
Atlanta, GA. November.
“Writing the History of Race and Citizenship: Who Wrote Yates’ Rights of Colored Men, and Why Does it
Matter?” Black Historians and the Writing of History in the 19th and early 20th centuries: What Legacy?
University Paris Diderot. Paris, France. June.
2013
“Proclaiming Emancipation: Interpreting Slavery’s Abolition through Visual Culture.” Law and Society
Association Annual Meeting. Boston, MA. June.
“Writing and Rewriting a Past: Lost Histories of Free People of Color in New Orleans.” (comment.)
American Historical Association Annual Meeting. New Orleans, LA. January.
“Law, Geography, and the Limits of Imperial Jurisdiction in the Colonial Caribbean.” (comment.) American
Historical Association Annual Meeting. New Orleans, LA. January.
2012
"Transforming American Advocacy: Race, Gender, and Local Courts in the Twentieth Century.” (comment.)
American Society for Legal History. St. Louis, MO. November.
“Popote: A Life History of Slavery and Law and the Haitian Diaspora.” Organization of American Historians
Annual Meeting. April.
2011
“A Tragedy of Metissage? Mulattoes in US Law and Culture.” (comment.) American Studies Association.
Baltimore, MD. October.
"Citizenship as Contestation in the Era of Dred Scott." Association for the Study of Law, Culture and the
Humanities. Las Vegas, NV. March.
2010
“Representing African American Womanhood in the Early Republic.” President’s Plenary. Society for Early
American History. Rochester, NY. June.
“Race, Servitude and Family.” (comment.) Ab Initio: Law in Early America. University of Pennsylvania Law
School. June.
“Reflections on Becoming a Research Subject: Or, Can an Activist Lawyer Write the History of Law.” CAAS
40th Anniversary Conference. University of Michigan. March.
2009
“Overturning Dred Scott v. Sandford: African American Citizenship in the Antebellum City.” American Society
for Legal History. Dallas, TX. November.
“I was born in…Croix-des-Bouquets”: Time, Space, and Jurisdiction in Gradual Emancipation New York.”
"Ambiguous Conditions: Law, Slavery and Freedom in the Atlantic World,” Universidade Estadual de
Campinas (UNICAMP,) Brazil. November.
“Trans-Atlantic Visions: The Case of Haiti’s Faustin Soulouque.” Reframing the Color Line: Race and the
Visual Culture of the Atlantic World. Clements Library, University of Michigan. October.

Jones, 12 of 14

“Meaning, Memory, and the Banning of the Slave Trade in 1808 and 2008: A View from the United States.”
Les Effets de l’Abolition de la Traite par la Grande Bretagne sur les Discourse Nationaux. Institut
Charles V & École des Hautes Études en Sciences Sociales (EHESS.) Paris, France. June.
“Eglise, Pratiques Culturelles de la Sphere Publique et Libres de Couleur aux Etats-Unis/Church, Public
Culture and Free People of Color in Early America.” Affranchis et Descendents d’Affranchis dans le
Monde Atlantique: Statuts Juridiques, Insertions Sociales et Identites Culturelles. Musee d’Aquitaine.
Bordeaux, France. May.
“Still “Pivoting the Center”: From African-American Women’s History to the History of the Atlantic
World.” Organization of American Historians Annual Meeting. Seattle, WA. March.
2008
“Haiti Re-Enslaved: Saint-Domingue Refugees and American Law in the Slave Markets in New Orleans.”
Southern Historical Association Annual Meeting. New Orleans, LA. October.
"Slavery and Naming in Gradual Emancipation New York City.” Naming Practices in Brazilian and
Caribbean History. Center for Latin American and Caribbean Studies. University of Michigan.
September.
“I was born in…Croix-des-Bouquets”: Space, Time, and Jurisdiction in Atlantic World Slavery.” Atlantic
Emancipations. The McNeil Center for Early American Studies. University of Pennsylvania. April.
2007
“From Croix-des-Bouquets to Baltimore: Reasserting and Resisting Mastery.” American Historical
Association. Washington, DC. January.
“Gender and the “Black Founders”: Looking for Black Women in the History of the Early Republic.” Society for the
History of the Early American Republic (SHEAR). Worcester, Mass. July.
“Baptiste v. de Volunbrun: Law, History, and the Re-Making of the Haitian Revolution.” French Colonial Historical
Society/Société d’Histoire Coloniale Française. LaRochelle. France. June.
PROFESSIONAL ACTIVITIES, AND SERVICE (selected)
Berkshire Conference of Women Historians. Co-President. June 2017Organization of American Historians. Executive Committee. 2017-present.
Society of Historians of the Early American Republic. Book prize committee. Member. 2015-present.
Journal of the Early Republic. Editorial Board Member. 2016-present.
Law & Social Inquiry. Editorial Board Member. 2015-present.
Slavery & Abolition. Editorial Board Member. 2015-present.
Souls: A Critical Journal of Black Politics, Culture and Society. Editorial Board Member. 2008-present.
American Society for Legal History. Nominations Committee. 2014-2017.
Organization of American Historians. Mary Jurich Nickliss Prize in U.S. Women's and/or Gender History
Committee. Member. 2016-17.
American Society for Legal History. Program Committee 2015 Co-Chair. 2014-2015.
Journal of Women’s History. Article Prize Committee. 2013-14.
Law and Society Association. J. Willard Hurst Prize Committee. 2012-13.
American Society for Legal History. Publications Committee. 2011-14.
Organization of American Historians. Merle Curti Award Committee. 2012-13.
Organization of American Historians. Darlene Clark Hine Award Committee. 2011-12.

Jones, 13 of 14

Journal of Women’s History. Editorial Board Member. 2006-2014.
Columbia University Center for the Critical Analysis of Social Difference. Toward an Intellectual History of
Black Women. Co-director. 2008-2011.
American Society for Legal History. Member, Board of Directors, 2009-2011.
Organization of American Historians. 2011 Annual Meeting Program Committee, 2009-2011.
Berkshire Conference of Women Historians. 2005 Conference Program Committee. 2004-2005.
American Quarterly, Journal of Social History, Journal of Women’s History, Gender & History, Law and History Review,
Law & Social Inquiry, Slavery and Abolition, Word & Image, Harvard University Press, Oxford University
Press, University of Georgia Press, University of Michigan Press, University of Illinois Press, University
of North Carolina Press, NYU Press, University of Pennsylvania Press, and Palgrave/MacMillan.
Manuscript reviewer. 2003-present.
At Johns Hopkins University
Agora Institute. Director search. 2017-present.
At the University of Michigan (selected):
Program in Race, Law & History. University of Michigan Law School. Co-director (with William J. Novak
and Rebecca J. Scott.) 2011-2017.
William L. Clements Library. Committee of Management. 2012-2017.
Rackham Graduate School. MORE Committee Member. 2015-1027.
The Law in Slavery and Freedom Project. Director (with Rebecca J. Scott and Jean Hébrard.) 2002-present.
Center for Research on Learning and Teaching (CRLT.) Advisory Board Member. 2014-2016.
Associate Chair of Afroamerican and African Studies, 2012-2013, 2014-2016.
Understanding Race Theme Semester. College of Literature, Science and the Arts. Co-chair. 2011-2013.
William Clements Library. University of Michigan. Price Fellowship Review Committee. Member. 2004-09.

Jones, 14 of 14

Exhibit B

1

Introduction

I am the Society of Black Alumni Presidential Professor and Professor of History at Johns
Hopkins University. Prior to joining the Johns Hopkins University faculty, I was the Presidential
Bicentennial Professor at the University of Michigan, Ann Arbor, where I was a member of the
faculties in law, history, and African American Studies. I hold a PhD in history from Columbia
University and a JD from the City University of New York School of Law. I am an
internationally recognized expert in the history of slavery, race, and law in United States History.
I am author of All Bound Up Together: The Woman Question in African American Public
Culture, 1830-1900 (2007), and Birthright Citizens: A History of Race and Rights in Antebellum
America (2018), and a co-editor of Toward an Intellectual History of Black Women (2015), as
well as author of numerous articles and essay. I am a member of the executive board of the
Organization of American Historians and a President of the Berkshire Conference of Women
Historians.

The report was prepared at the request of the Washington State Attorney General’s Office. It was
produced by way of a review of the scholarly historical literature on the subject of slavery in
British North America and the United States, with an emphasis on the antebellum (or pre-Civil
War) decades of 1830-1860.

2

Overview: Slavery in British North America

In the United States, slavery was an institution premised upon the notion of property in persons.
Historians have adopted this phrase to express how enslaved people were regarded
simultaneously as human beings and as property. Enslaved children, like adults, were viewed as
property: investments, collateral, commodities, and bound laborers. They were also recognized
as persons, exercising will, acquiring knowledge and skills, and constructing communities and
intimate relations. They could be bought and sold on the courthouse steps and also be held
culpable for their bad acts in a courtroom. What set this form of coerced labor apart from others,
including indentured servitude, was the ever-present possibility of individuals being sold, often
termed the chattel principle.1

Slavery was a fundamental component of North American economic, legal, and political
structures from the 17th century forward. The documented presence of Africans pre-dates this
period, but it was in the 1600s with European settlement that British colonial officials began to
regulate those held as slaves, including their family lives. By a 1662 Act, for example, the
colonial legislature of Virginia determined that the status of an enslaved woman’s children
would follow her condition, thus also becoming slaves: “Children got by an Englishman upon a
Negro woman shall be bond or free according to the condition of the mother….” This principle –
partus sequitur ventrem – would come to govern throughout the British North American colonies

1
On persons as property and the chattel principle, see Walter Johnson, Soul by Soul: Life Inside
the Antebellum Slave Market (Cambridge, MA: Harvard University Press, 1999).

3

and later the United States. This was a departure from English common law, which deemed that
children followed the status of their fathers.2

The regulation of slavery was not limited to any one region in North America, and extended up
and down the Atlantic seaboard, from what today we would term north to south. In 1690, people
of African descent comprised less than 15% of the populations of Virginia and Maryland. That
changed between 1690 and 1710, when the numbers of enslaved people being imported into
those states doubled. By 1770, people of African descent comprised 40 percent of the population
in Georgia. In the mid-18th century North, slaves were just over 9 percent of Rhode Island’s
population, 7.5 percent in New Jersey, and over 12 percent of the overall population in New
York. In the wake of the American Revolution, most northern states would set in place gradual
abolition schemes. Still, enslaved people continued to be held in that region up until the Civil
War in New Jersey.3 At the time of the first federal census in 1790, the number of enslaved

2
A. Leon Higginbotham, In the Matter of Color: Race and the American Legal Process, The
Colonial Period (New York: Oxford University Press, 1978.) Jennifer L. Morgan, “Partus
Sequitur Ventrum: Law, Race, and Reproduction in Colonial Slavery,” Small Axe 22, No. 1
(2018): 1-17.
3

Stanley L. Engerman, Richard Sutch, and Gavin Wright, “Slavery for Historical Statistics of the

United States,” University of California Project on the Historical Statistics of the United States,
March 2003.

4

people in the US totaled 29,264, or just over 35 percent of the overall population, with the largest
numbers of slaves held in Maryland, Virginia and North Carolina.4

Parent-child relations among enslaved people were not merely regulated, they were at risk. By
the mid-17th century, the separation of children from parents was commonplace in the New
England colonies. In Wethersfield, Connecticut, for example, youngsters were “given away or
sold in order to enhance an owner’s wealth, settle debts, or simply in exchange for a more
desirable commodity.”5 Courts frequently encountered questions about how to regard enslaved
families in the context of estate proceedings, both testate and intestate. Practice varied as courts
worked through questions about whether slaves were real or personal property. But overall,
interpretations strongly favored the right of inheritance, such that enslaved families were
frequently separated, or “portioned,” without restriction.6 It was possible even to bequeath an

4
Return of the Whole Number of Persons Within the Several Districts of the United States
(Philadelphia, PA: J. Phillips, 1793).
5

Peter Benes, “Slavery in Boston Households, 1647-1770,” Dublin Seminar for New England

Folklife Annual Proceedings 28 (July 2003): 12-30.
6

Thomas D. Morris, Southern Slavery and the Law, 1619-1860 (Chapel Hill, NC: University of

North Carolina Press, 1999.) On the frequency, durability, and resistance of enslaved families,
see Tera W. Hunter, Bound in Wedlock: Slave and Free Black Marriage in the Nineteenth
Century (Cambridge, MA: Harvard University Press, 2017).

5

enslaved woman’s future children to a party other than the woman’s owner, anticipating the
separation of parent from child.7

Slavery in the Antebellum United States.

This report principally concerns the experiences of enslaved families – including the separation
of parents and children -- in the era after the American Revolution, with an emphasis on the three
decades preceding the American Civil War (also known as the antebellum or prewar era.) This
period also followed Congress’s 1808 ban on the international slave trade, which barred the
importation of enslaved people from beyond the nation’s’ borders into the US. In this period,
slavery generated prosperity owing to the market success of slave-produced staple crops,
including cotton and sugar. Simultaneously, slavery was subject to a sustained challenge, with
the emergence of an abolitionist movement that called for slavery’s immediate end.

The pressures on enslaved families and also on single enslaved women to reproduce a workforce
grew in this period. The close of the international trade meant that future enslaved workers
would no longer be imported from Africa or the Caribbean, and instead they would be drawn
from a so-called natural increase in the domestic slave population. The reproductive labor of
enslaved women, whose children were deemed to follow their mother’s status, was now the sole
source of future bound laborers. The value of such children as workers increased as access to
imported slaves was closed. At the same time, a new sort of slave trade emerged, a domestic one

Thomas D. Morris, Southern Slavery and the Law, 1619-1860 (Chapel Hill, NC: University of

7

North Carolina Press, 1999.)

6

— buying and selling enslaved people strictly within the US — that forced the relocation of what
are estimated to have been between one to two million slaves. This trade relocated enslaved
people from upper South states such as Maryland and Virginia, where soil had been depleted and
the economy had shifted to a reliance upon wage laborers, to cotton, rice and sugar producing
regions further south. The related sales further disrupted the bonds of enslaved families.8

In antebellum America, between 1820 and 1860, two out of every five slaves were younger than
fifteen and one-third was younger than ten.9 The lives of enslaved children were especially
precarious. Rates of “mortality, morbidity, and injury” were high, with sickness and death being
commonplace. Slaveholders generally neglected the health of enslaved children, even at the risk
of losing valuable property. The capacities of enslaved parents to care for their children were
limited by the demands of work and the scarcity of resources. Slaveholders came between
parents and children in everyday ways, assigning work responsibilities and meting out
punishments. Still, the day-to-day rearing of children was generally left to enslaved parents and
their communities. Historians do not agree about the degree to which such parents could ensure

Steven Deyle, Carry Me Black: The Domestic Slave Trade in American Life (New York: NY:

8

Oxford University Press, 2005); Daina Ramey Berry, The Price for Their Pound of Flesh: The
Value of the Enslaved, from Womb to Grave, in the Building of a Nation (Beacon Press, 2017).
9

Historian Wilma King makes the point that age is only one criterion by which to determine who

is a child. As her the title of her 1997 book suggests, enslaved young people had much of the
childhoods “stolen,” by the demands placed upon them by slaveholders. Wilma King, Stolen
Childhood: Slave Youth in Nineteenth-Century America (Bloomington, IN: Indiana University
Press, 1997).

7

the well being of children. We do know that adults negotiated with slaveholders, trading their
labor and general deference for an owner’s special consideration for children and the granting of
parental autonomy over the care and raising of children. This was a delicate bargain enacted
between unequal parties, with slave owners holding the balance of power and enslaved parents
having no legally enforceable rights. These were frequently negotiations conducted in the
context of the ultimate threat: the separation of children from their parents.10

Slavery and Law.

Slavery was an institution rooted in and dependent upon law. From constitutions and statutes to
high courts and clerks’ offices, slavery was built upon the premise of property in persons. This
was no metaphor. Slaveholders and those who traded in or otherwise profited from the institution
depended upon law to formalize their interests, resolve their disputes, and generally ensure that
owners could premise their economic lives upon the future control of bound labor.

The US Constitution of 1787 was a proslavery document. Of course, slavery pre-dated its
ratification. Still, as the framers crafted a new governing text for the nation, they also ensured
that slavery would be part of that founding fabric. The Constitution shielded the international
slave trade from Congressional interference. (Article 1, section 9.) Slavery determined to an

10
Marie Jenkins Schwartz, “Ill and Injured Children on Antebellum Slave Plantations: A
Dangerous Childhood,” Southern Quarterly 53, no 3/4 (Spring/Summer 2016): 56-69; Marie
Jenkins Schwartz, Born in Bondage: Growing Up Enslaved in the Antebellum South (Cambridge,
MA: Harvard University Press, 2000).

8

important degree how representation in Congress and taxes would be determined, by way of the
3/5ths clause which granted slave holding states enhanced representation in Congress based upon
unfree persons who did not themselves exercise political rights. (Article 1, section 2.) The
fugitive slave clause authorized Congress to aid slaveholders who sought to recover fugitive
slaves by way of a “militia” that would “suppress insurrections,” a provision that had putting
down slave uprisings in mind. (Article 4, section 2.) A casual reading of the 1787 Constitution
might miss its pro-slavery character. This is because the framers employed coded language –
referring to slaves as, for example, “all other persons”—to shield the document from direct
criticism. Still, reading of the slim notes from the constitutional convention itself and the robust
ratification debates that followed, make plain that the framers knew they were helping to
guarantee slavery’s future.11

The US Supreme Court did not play a major role in the furtherance and protection of slavery. As
discussed below, largely state law governed the institution. Important exceptions are worth
noting, however, the most notorious being the decision in Dred Scott v. Sandford.12 Asked to
review a lower court decision that had deemed Scott a slave, the high court reached beyond that
issue to deny the authority of federal courts to hear freedom suits brought by enslaved people

11
James Oakes, “The Compromising Expedient: Justifying a Proslavery Constitution,” Cardozo
Law Review 17 (1995-1996): 2023; David Waldstreicher, Slavery’s Constitution: From
Revolution to Ratification (New York: Macmillan, 2010); and, Paul Finkelman, “Affirmative
Action for the Master Class: The Creation of the Proslavery Constitution,” Akron Law Review
32, no. 3 (1999): 423-470.
12

Scott v Sandford, 60 US 393 (1857).

9

altogether. Scott was as a black person, the decision opined, was not a citizen of the United
States. He was thus without standing to bring suit in federal court under diversity jurisdiction.
The court went on to conclude that no person of African descent, enslaved or free, could be a
citizen of the United States. As for slavery more broadly, the court deemed the Missouri
Compromise of 1820, which had emanated from Congress’s assumed authority to regulate
slavery in US territories, unconstitutional thus invalidating Congress’s power to govern slavery
there. Subsequent opposition to Dred Scott compromised the court’s reputation and its decision
was in essence superseded by the 13th and 14th Amendments, in 1865 and 1868 respectively.

Slavery was however, in the parlance of the period, a domestic institution, meaning that state
legislatures and courts largely regulated slavery. As discussed above, individual colonies had
early on governed slavery by positive law. This continued into the antebellum period as
individual states regulated the institution. There were those that abolished slavery in the North.
In the southern slaveholding states, state law governed slavery by way of public law, including
criminal codes that provided a unique set of charges and sanctions for enslaved offenders.
Private law too was extensively involved in regulating slavery, especially in the areas of contact
and trusts and estate. Few states governed by way of comprehensive codes, with Louisiana being
the exception. State legislatures and high courts were busy throughout the antebellum period
setting forth statutes and common law principles that managed nearly all aspects of slavery.
While only a small subset of enslaved people would ever be party to or the subject of court

10

proceedings, slaveholders relied upon the ever-available terms of state law, court, judges, and
clerks to organize and exert their power over bonds people.13
The separation of enslaved parent from their children was facilitated by the very same state laws,
and enforced by courts through otherwise ordinary proceedings. This was a widespread practice,
though precisely how far it is difficult to quantify. As important as the fact of separation was,
separation of families was also an ever-present threat. Slavery was not an institution governed
merely by the lash. Law was an essential instrument for slaveholders who looked to maximize
the profits of property in persons. But much of slavery’s day-to-day regulation was informal,
characterized by a persistent struggle between slaveholders and those hold in bondage.

Among the tools of coercion employed by slaveholders, as they sought to render enslaved people
compliant, was the threat of separating families. Historians of slavery emphasize that no threat
— not the lash, or degraded working conditions, or the curtailment of modest privileges — was
more potent and more feared that the threat that reluctant, resistant, or otherwise non-compliant
slaves would be sold. Instilling the fear of separation might be used as a weapon. But even in
slaveholding households where no such explicit threats were leveled, enslaved people knew that

Ariela J. Gross, Double Character: Slavery and Mastery in the Antebellum Southern

13

Courtroom (Princeton, NJ: Princeton University Press, 2000.) Thomas D. Morris, Southern
Slavery and the Law, 1619-1860 (Chapel Hill, NC: University of North Carolina Press, 1999.)

11

an owner’s death, bankruptcy, or other change of circumstances could result in the redistribution
of property in persons and hence separate enslaved parents from children.14

Enslaved people wrote with great feeling about the experience of being separated from their
families. Enslaved poet Phillis Wheatley survived the middle passage as a captive, in a journey
that took her from West African to Boston, Massachusetts. The year was 1761 and Wheatley was
just seven or eight years of age. Wheatley went on, under the tutelage of her owner, to publish
her poetry to critical acclaim. In her writings, Wheatley expressed her longings for Africa and
her parents whom she would never see again. Frederick Douglass is among the best remembered
of the antebellum period’s fugitive slaves, going on to a career as an anti-slavery activist,
journalist, orator, and statesman. Douglass published his first memoir in 1845, explaining his life
as an enslaved boy. In the opening chapter, he recounted how forced separations blunted his
feelings: “I never saw my mother, to know her as such, more than four or five times in my life;
and each of these times was very short in duration, and at night. … She died when I was about
seven years old, on one of my master’s farms. … Never having enjoyed, to any considerable

14
Walter Johnson, Soul by Soul: Life Inside the Antebellum Slave Market (Cambridge, MA:
Harvard University Press, 2001) and, Marie Jenkins Schwartz, Born in Bondage: Growing Up
Enslaved in the Antebellum South (Cambridge, MA: Harvard University Press, 2000).

12

extent, her soothing presence, her tender and watchful care, I received the tidings of her death
with much the same emotions I should have probably felt at the death of a stranger.”15

Sojourner Truth, the anti slavery and women’s rights orator, recounted how she was forcibly
separated from her son during her time as a slave in upstate New York. It was a story of how
slaveholders traded young enslaved people within white families, without regard for the bonds
among slaves themselves. Truth’s “old master … had sold her child, a boy of five years, to a Dr.
Gedney, who took him with him as far as New York city, on his way to England; but finding the
boy too small for his service, he sent him back to his brother, Solomon Gedney. This man
disposed of him to his sister's husband, a wealthy planter, by the name of Fowler, who took him
to his own home in Alabama. This illegal and fraudulent transaction had been perpetrated some
months before [Truth] knew of it.”16
The story of Matthew Matthews suggests that while some white Americans might act as allies to
enslaved people, slaveholder’s property interests were nearly always paramount. Originally from
Virginia, Matthews purchased his own freedom with the intent of also purchasing his children in

15
Vincent Carretta, Phillis Wheatley: Biography of a Genius in Bondage (Athens, GA:
University of Georgia Press, 2011); Frederick Douglass, Narrative of the Life of Frederick
Douglass, An America Slave, Written by Himself (Boston, MA: Anti-Slavery Office, 1845).
16

Sojourner Truth with Olive Gilbert. Narrative of Sojourner Truth, a Northern Slave,

Emancipated from Bodily Servitude by the State of New York, in 1828 (Boston: J. B. Yerrinton
and Son, 1850), 44.

13

1835. He was only partially successful, gaining legal custody of one child while being faced with
the threat that the owner of his remaining children, who faced hard financial times, might be
forced to sell his children at public auction and beyond their father’s reach. Matthew’s letters
suggest that he was dogged, ingenious, and had the capacity to enlist the support of other African
Americans, who loaned him money, and influential whites who interceded on his behalf.17

The dislocations of the Civil War only continued the problem of children being separated from
parents. They also gave enslaved people unprecedented opportunity to challenge and even rectify
the separation of parent from child. Rose Herera’s owners sought to avoid the incursion of
Union troops into the slaveholding city of New Orleans, Louisiana in 1862. They fled to Cuba,
taking with them three of Herera’s four children – aged two, four and six. It appeared that Herera
and her husband, a free man of color, had no recourse because the children were property,
following the status of their mother. But Herera neither forgot her children nor her desire to be
reunited with them. After the war’s end, three years later in 1865, Herera appeared before a local
magistrate to complain that her children had been kidnapped. What followed were months of
legal wrangling that resulted in a hard-won reunion. Still, Herera, her husband, and their children
endured years of separation and uncertainty in the interim.18

“Masters-Taylor-Wilbur Papers, 1796-1857,” The William L. Clements Library, University of

17

Michigan, Ann Arbor, MI.
18

Adam Rothman, Beyond Freedom’s Reach: A Kidnapping in the Twilight of Slavery

(Cambridge, MA: Harvard University Press, 2015). See also, Georgena Duncan, "’One negro,
Sarah … one horse named Collier, one cow and calf named Pink’: Slave Records from the
Arkansas River Valley,” Arkansas Historical Quarterly 69, no. 4 (Winter 2010): 325-345. Gail

14

S. Terry, “Sustaining the bonds of kinship in a trans-Appalachian migration, 1790-1811” The
Cabell-Breckinridge Slaves Move West,” Virginia Magazine of History & Biography 102
(October 1994): 455-476, and Laurence J. Kotlikoff, “The Structure of Slave Prices in New
Orleans, 1804-1862,” Economic Inquiry 17, no. 4 (October 1979): 496 – 518.

15

The Antislavery Critique of Separating Families

The abolitionist movement documented the separation of children from parents, and made this a
cornerstone in their case for the end of slavery. Families were central, sacred, and the bedrock of
American society, they argued. Slavery’s violence, injustice, and contradictions were revealed
nowhere more plainly than in those many instances in which families were broken up. The
movement relied to an important degree upon what was termed “moral suasion.” Among
abolitionists were those who believe that only by transforming the hearts and minds of white
Americans to the anti slavery cause, would the institution end. They utilized the podium,
newspaper and pamphlets – the media of the day – with great effectiveness. Eventually
experienced teams of speakers — black and white – were touring the US and Great Britain
seeking new subscribers to the movement. Their training included pamphlet such as La Roy
Sunderland 1837 Antislavery Manual.19

Sunderland armed anti slavery advocates with two points of view on the separation of children
from parents. The first was comparative. “Unlike American slavery,” what he termed “Jewish
Servitude” had be a more benign institution that respected domestic relations such that parents
and children could not be separated and when a woman was freed, her children remained with
her. His second point came in the form a story, borrowed from the narrative of a former slave,
Charles Ball. Ball had describe in poignant detail the day he was separated from his mother: “My
poor mother, when she saw me leaving her for the last time, ran after me, took me down from the
horse, clasped me in her arms, and wept loudly and bitterly over me. … The slave-driver who

La Roy Sunderland, Anti-Slavery Manual (New York, NY: Piercy & Reed, 1837).

19

16

had first bought her, came running in pursuit of her with a raw hide in his hand. When he
overtook us, he told her was her master now, and ordered her to give that little negro to its
owner, and come back to him.” My mother then turned to him and cried “Oh, master, do not take
me from my child!” “I never again heard the voice of my poor mother,” Ball wrote. Ball’s story
went on to suggest how such scenes might be repeated in one individual’s lifetime. He went on
to make his own family, only to be sold away from his wife and children.”20

No one piece of anti slavery literature had more influence than did Harriet Beecher Stowe’s
novel Uncle Tom’s Cabin. It was widely read in its own time, credited by Abraham Lincoln with
having helped start the Civil War, and was retold in newspaper installments, books, and also
stage productions. Stowe convincingly taught thousands upon thousands of Americans about the
evils of slavery, and first among those evil was the separation of children from parents: Uncle
Tom’s Cabin is an ambitious novel with many characters and plot-lines, but at its heart are
stories of three enslaved people whose lives were defined by family separations. Eliza and
George Harris learn that their son Harry is going to be sold away from them and run away. The
title character Tom Shelby is sold away from his wife and children, and spends the rest of the
novel trying to find his way back to them. Uncle Tom’s Cabin rested upon artful fiction, but its
success was attributable to how true Stowe’s story was in the lives of many unnamed enslaved
people. Northern sentiment arrived at a consensus that condemned the separation of children
from parents as among slavery’s most abhorrent practices.21

La Roy Sunderland, Anti-Slavery Manual (New York, NY: Piercy & Reed, 1837).

20
21

Ben Railton, “Considering History: Uncle Tom’s Cabin and Imagining Slavery’s Family

Separations,” The Saturday Evening Post, June 20, 2018. Henry Louis Gates, Jr. and Hollis

17

Critique Emerges in Proslavery Circles

The testimony of former slaves along with Stowe’s powerful narrative appear to have led
southern lawmakers to develop their own critique of separating children from parents. By the
1850s, individual states were revising their laws to place gentle but real curbs upon such
practices by slaveholders. There was of course a self-serving dimension to such reforms.
Proslavery lawmakers hoped to deflect broader criticisms by implementing modest changes. At
the same time, the decision to put in place reforms on precisely the question of family integrity
was linked to how widespread and compelling a critique there was.

There emerged a modest willingness to permit abolitionist criticism to enter law and policy. In
Georgia, for example, a new 1854 statute prohibited executors and administrators from selling
children under the age of five; they were to be placed together with their mothers. But there was
a caveat: “Unless such division cannot in any wise be affected without such separation.” The
right of inheritance outweighed even this effort to limit the horrors that slaves lived with because
of an inheritance.22 The Maryland Supreme Court in Homes v. Mitchell introduced the view that
there were limits to how enslaved children could be disposed of, and they were moral limits:

Robbins, The Annotated Uncle Tom’s Cabin by Harriet Beecher Stowe (New York: W. W.
Norton, 2007.)
22

Thomas D. Morris, Southern Slavery and the Law, 1619-1860 (Chapel Hill, NC: University of

North Carolina Press, 1999): 83.

18

“The infant cannot be torn from its mother and sold or transferred to the complainant. No one
would buy, and humanity would cry out against it.23

The Alabama code of 1852 critiqued separating young children from parents in a provision that
barred removing enslaved children under ten from their mothers.24 The state’s Governor
explained the underlying reasoning, and while he was in no sense an abolitionist, his ideas were
consistent with the critique that both enslaved people and anti slavery activists had long leveled.
The new law left slaveholders an out if keeping families together was impractical and the
Governor urged a stricter law: “The Code very properly provides that slave children of tender
years shall, at judicial and some other sales, be offered with their mothers…. These provisions,
in my judgment, should be absolute, at least as it respects mothers, and children of ten years of
age and under, and husband and wife, where the latter relation is admitted by the owner of the
slaves. These relations which moral duty requires us to respect, and it can be no violation of
policy to confirm municipal law to good morals. It is universally conceded that slaves are
reasonable beings – with the moral feelings, it is true, often obtuse, but susceptible of
improvement. The husband and wife generally cherish affection for each other, and the mutual
attachment of mother and child is usually strong. The mother is not always wise counselor, but
she must be presumed to be the most constant and sincere the child has. Let, then, the latter enjoy
this parental oversight during childhood, that it may be the better prepared by good principles
and industrious habits act its part afterwards.” Proslavery thought in some cases adapted to the

23
Scott v. Dobson, 1 Har. and McH. 160 (Md., 1852).)
24

The Code of Alabama (Brittan and De Wolf, 1852), 392.

19

view that separating young children from parents went too far, even in a system that openly
sanctioned the holding of persons as property.”25

Criticism of how slavery separated families was reflected in Congress’s debates as it
contemplated the abolition of slavery. Republican Senator James Harlan of Iowa spoke in
support of the 13th Amendment, explaining that the failure to abolish slavery would leave in
place unnecessary evils. First, Harlan decried how slavery had abrogated the “conjugal relations
of enslaved people.” He then went on to make plain how slavery had tragically severed the
relations between family and child: “Another incident is the abolition practically of the parental
relation, robbing the offspring of the care and attention of his parents, severing a relation which
is universally cited as the emblem of the relation sustained by the creator to the human family.
And yet, according to the matured judgment of these slave States, this guardianship of the parent
over his own children must be abrogated to secure the perpetuity of slavery.”26

Legacies

The legacy of separating families during slavery extended well into the 20th century. Enslaved
people themselves left poignant records that reveal the immediate cost and the long term
consequences of separating children from parents under slavery. Their stories, many of them told

25

Journal of the Fourth Biennial Session of the Senate of the State of Alabama. Session of 1853-

54 (Montgomery, AL: Birttan & Blue, 1854).
26

Congressional Globe. 38th Congress, 1st Session (1864).

20

years after slavery was abolished, are a testament to how vital family was to enslaved people and
about how their experience of loss was not ever set aside or forgotten.

First hand accounts of former slaves, were collected by the Federal Writer’s Project of the Works
Progress Administration in the 1930s. The “WPA narratives,” as they are commonly termed,
were produced by anthropologists, folklorists, and historians traveling the country to record the
life stories of former slaves. This set of 2000 interviews conducted across 17 states, paints a
vivid picture of life for children under slavery. Very elderly when the interviews were taken, the
men and women studied had been young people in the years just prior to emancipation. They
invariably tell stories of losing family members to sale, trade, and the vagaries of the market in
persons. We learn that even many decades later, late in life, former slaves recalled and mourned
the irretrievable loss of family members. These losses were still being felt well into the 20th
century.27

No evidence is more arresting than that of the advertisements that former slaves placed in
newspapers following emancipation. There, in columns with titles such as “Information
Wanted,” freed people searched across time and space hoping to be reunited with loved ones
from whom they had been separated

“The Atlanta Constitution. August 19, 1917. Mr. and Mrs. Johnnie Dillard, of Lynchburg, Va.,
wish to find their nine children, Mollie, Daniel, John, Tommy, Malinda, Jimmie, Mauncy and

Heather Andrea Williams, Help Me to Find My People: The African American Search for

27

Family Lost in Slavery (Chapel Hill, NC: University of North Carolina Press, 2012).

21

Margaret Jane (all colored), who when last heard of were sold by negro traders. Write
information to Mamie Stuart, rear of 355 Walnut Street, Atlanta, Ga. Will pay all expenses.”

These ads continued to be published into the early 20th century, a half century after slavery had
been abolished. Mothers searched for sons, fathers for daughters, children for parent and for
siblings. Husband searched for wives. Slavery may have most often been indifferent to the
kinship bonds of slaves, and slavery certainly ensured that those bonds would be strained. Still,
the thousands of ads placed by former slaves in search of loved ones make plain that in many
cases such bonds were not broken.28

Conclusion

The separation of enslaved children from their parents was a regular and even commonplace
dimension of slavery in the United States. By sale or gift, estate division or to satisfy a debt,
enslaved families lived under the ever-present threat they would be separated. Fugitive slaves
testified to the experience of being separated from loved ones, and abolitionists held the
destruction of the enslaved family up as one of the institution’s most egregious practices. By the
1850s, even pro-slavery lawmakers recognized that separating young children from mothers was
contrary to both morality and policy, and put modest curbs against the practice in place. With
slavery’s abolition in 1865, a new era opened up, a half-century during which family members

Heather Andrea Williams, Help Me to Find My People: The African American Search for

28

Family Lost in Slavery (Chapel Hill, NC: University of North Carolina Press, 2012).

separated by slavery searched for one another. The legacy of separating enslaved families was
thus felt into the 20st century

22

Exhibit 50

Exhibit 51

1
2
3
4
5
6

7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

8

9

STATE OF WASHINGTON, STATE OF
CALIFORNIA, et al.

10
11
12

NO. 2:18-cv-00939
DECLARATION OF SHADI
HOUSITYAR IN SUPPORT
OF PLAINTIFFS' MOTION
FOR EXPEDITED
DISCOVERY

Plaintiffs,
V.
THE UNITED STATES OF AMERICA,
et al.,

13
Defendants.
14
15

1, Shadi Houshyar, declare as follows:

16

1 am over the age of 18 and make this declaration based upon my personal experience and my

17

expertise.

18

1. I recently joined Families USA as Director of Early Childhood and Child Welfare

19

Initiatives. I have over a dozen years of experience working in the nonprofit sector on federal

20

and state child welfare and early childhood policies with a primary focus on childhood trauma,

21

toxic stress, and adverse childhood experiences (ACES). Before coming to Families USA,1

22

worked at the Washington, D.C.-based Center for the Study of Social Policy (CSSP), an

23

organization that promotes policy solutions and provides technical assistance that allows

24

policymakers and community-based organizations to improve outcomes for vulnerable

25

children and families. At CSSP, I led a project focused on preventing and mitigating the effects

26

of toxic stress on young children and their families while building and sustaining partnerships

DECLARATION OF SHADI HOUSITYAR
IN SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

I

ATTORNEY GENERAL of CALIFORNIA

I Street
sa~r mento, CA
91 6-445-9555 81~
6 445 9555

I

with national leaders in the early childhood arena. Previously, I spent nearly a decade as Vice

2

President of Child Welfare Policy at First Focus, where I led federal child welfare policy

3

efforts, including advocacy on child abuse and neglect prevention, foster care, and health and

4

behavioral health policies affecting children and their families. I also was founding director of

5

First Focus's State Policy and Advocacy Reform Center, a national resource center for state-

6

based advocates aimed at improving outcomes for children and families involved with the

7

child welfare system by building the capacity of and connections between state child welfare

8

advocates. I received my Ph.D., M.Phil., and M.S. degrees in Developmental Psychology from

9

Yale University and my Bachelor of Science degree in Psychology from Kalamazoo College.

10

2. Founded in 1981, Families USA Foundation is a nonprofit, nonpartisan, 501(c)(3)

11

organization that is dedicated to the achievement of high-quality, comprehensive, and

12

affordable health care for all Americans. We advance our mission through public policy

13

analysis, advocacy, and collaboration with partners to promote a patient- and community-

14

centered health system. We work closely with more than 8,000 consumer leaders and more

15

than 16,000 grassroots activists in all 50 states. We work closely with other national health

16

care patient and consumer organizations on Medicaid and private insurance coverage,

17

community health, and health equity issues. As part of our work, we talk directly with

18

thousands of individual consumers about their experiences with the health care system. We

19

help connect these individuals with opportunities to share their experiences publicly and help

20

to seek improvements in health care.

21
22
23

3. Families USA is committed to the belief that separating children from their parents is
harmful to children, traumatic for families, and runs counter to our basic American values.
4. The process of separation is itself traumatic. Children forcibly separated from their

24

parents are placed in a Customs and Border Protection (CBP) facility before being transferred

25

to the care of the Office of Refugee Resettlement (ORR) within the U.S. Department of Health

26 1 and Human Services.

DECLARATION OF SHADI HOUSIIYAR
IN SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

2

ATTORNEY GENERAL OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

5. I am aware of reports of unsafe and poor conditions at CBP facilities, including concrete
A

floors, fenced enclosures, brutally cold temperatures in holding cells and sheets of foil used as
blankets. I am also aware that CBP's policy is to hold children in its custody for less than 72

4

hours, but that nearly 300 children in a recent study—half under the age of 12—spent more
than 72 hours.

6

6. Once transferred to ORR, children await placement with a parent, relative, or family

7

friend. I am aware that ORR has reported that children spend an average of 56 days in its

8

shelters. ORR is not a child welfare agency and does not have the necessary experience to care

9

for the thousands of children, and now, a growing number of young children, it houses in a

10

network of 100 facilities in 14 states. I am aware of reports stating that ORR shelters are

11

operating at 95% capacity, housing as many as 11,200 children, and that babies and the

12

youngest children are being sent to separate "tender age" shelters that are not equipped to

13

adequately care for their needs. These shelters represent a return to the long-discredited

14

practice of forcibly institutionalizing the very young with devastating consequences for their

15

short and long-term health and wellbeing.

16

7. Research into early childhood adversity has shown that trauma suffered while young

17

(adverse childhood experiences or ACES) can have serious and lasting consequences for later

18

health outcomes. Robust connections have been shown between ACES and increased morbidity

19

and mortality as an adult.' ACES in early childhood have been linked to poor physical health

20

outcomes and below-average language and math skills and behavior problems in

21

kindergarten.3 Children who have suffered ACES are also more likely to suffer from mental

22
23
24
25
26

I Felitti VJ, Anda RF, Nordenberg D, Williamson DF, Spitz AM, Edwards V, Koss MP, Marks JS,
"Relationship of childhood abuse and household dysfunction to many of the leading causes of death in adults. The
Adverse Childhood Experiences (ACE) Study," American Journal of Preventive ILtedicine 14, May 1998.
Available at https://www,ncbi,nlm,nih.gov/pubmecL/9635069.
2 Flaherty EG, Thompson R, Litrownik AJ, et al. Effect of early childhood adversity on child health.Arch Pediatr
Adolesc Med. 2006;160(12):1232-1238pmid:17146020
3 Jimenez ME, Wade R Jr, Lin Y, Morrow LM, and Reichman NE, "Adverse Experiences in Early
Childhood and Kindergarten Outcomes," Pediatrics 137:2, February 2016. Available at

http/, pediatrics.aappublications.ort/content; early/2016/01 /13/peds.2015-1839.

DECLARATION OF SHADI HOUS14YAR
IN SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

ATTORNEY GENERAL OF CALIFORNIA
13001 Street
Sacramento, CA 95814
916-445-9555

health problems, chronic medical conditions, and poor social development.4 These traumas
2

have been shown to have intergenerational effects, harming the children of those who suffered

3

ACEs.5

4

8. Frequent exposures to strong, frequent, and/or prolonged adversity without adequate

5

adult support can cause "toxic stress" that leads to physiological effects on a child's

6

neuroendocrine and immune systems, stress regulatory system, and brain development.

7

Children suffering from separation from a parent may show signs similar to those of posttraumatic stress disorder, including loss of appetite, trouble sleeping, and regressive behaviors.

9

9. Research also indicates that children are resilient, and can overcome adverse experiences

10

with adequate adult support and a nurturing family environment. The absence of this stable

11

environment can have lasting consequences for the brain's recovery. Family separations result

12

in a double trauma where the initial forced separation is coupled with the ongoing absence of

13

the child's primary resource of support or buffer for coping with the separation.

14

10. Federal and state child welfare policy conform to the finding that children do best in

15

family environments, and that separation of a child from his or her parents should be done only

16

in extreme cases, not as a standing matter of policy. Early childhood separation in a chaotic

17

and unfamiliar environment can cause significant distress and is traumatic for children.

18

11. Reports of poor conditions at family detention facilities are common with visitors

19

describing prison-like conditions with cement floors for sleeping; open toilets; lights on 24

20

hours a day; inadequate food and water; and limited medical, dental, and mental health

21

services. Reports by pediatric and mental health advocates following visits to family detention

22

centers in 2015 and 2016 revealed discrepancies between ICE standards and the actual services

23

4

24

Kerker BD, Zhang J, Nadeem E, Stein REK, Hurlburt MS, Heneghan A, Landsverk J, Horwitz SM,
"Adverse Childhood Experiences and Mental Health, Chronic Medical Conditions, and Development in Young
Children," Academic Pediatrics 15:5, September-October 2015. Available at

25

littps://www.academicpedsjnl.tiet/article/S 1876-2859(15)00173-4/abstract.

26

5

L&Scherban F, Wang X, Boyle-Steed KH, Pachter LM, "Intergenerational Associations of Parent
Adverse Childhood Experiences and Child Health Outcomes," Pediatrics 141:6, June 2018. Available at
http://pediatrics.aappubtications.org/content/ I41/6/e20174274. ]on g.

DECLARATION OF SHADI HOUSITYAR
IN SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

ATTORNEY GENERAL OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

provided to families, including reports of inadequate or inappropriate immunizations, delayed
2

access to medical care, inadequate education services, and limited mental health services.6
12. The prison-like conditions in detention, including constant surveillance can be

4

confusing and intimidating for children. Children may feel unsafe in detention which could be
a trigger and re-traumatizing for children who have experienced past trauma.

6

13. The stress of detention can harm a child's developing brain and is associated with

7

psychological distress and short-term symptoms including eating difficulties and somatic

8

complaints, sleep problems, depression and anxiety, and long-term health consequences

9

including developmental delays, post-traumatic stress disorder, anxiety, depression, suicidal

10

ideation and other behavioral problems.7 8 9 Children can experience significant distress and

11

toxic stress in detention conditions.

12

14. Research indicates that a child's wellbeing is closely linked to his or her parent's

13

stability and that a parent's ability to act as a buffer from toxic stress greatly affects early

14

development.10 Detention, even for brief periods of time, can also have adverse consequences

15

for the health and wellbeing of parents.11 Detention can exacerbate existing mental health

16

conditions for parents and compromise a parent's ability — under stress — to respond to the

17
18
19
20
21
22
23
24
25
26

American Immigration Council, American Immigration Lawyers Association, Catholic Legal Immigration Network
Refugee and Immigrant Center for Education and Legal Services . Letter to Department of Homeland Security Office of
Civil Rights and Civil Liberties re: ICE'S continued failure to provide adequate medical care to mothers and children
detained at the South Texas Family Residential Center. Available at: wNvw.aila.org/File/DownloadEinbeddedFile!66149.
Linton, JM, Marsha Griffin, M., Shapiro, AJ. Detention of Immigrant Children. [Policy Statement].
PEDIATRICS, Volume 139, Number 4, April 2017.
s Lorek, A., Ehntholt, K., Nesbitt, A., Wey, E., Githinji, C., Rossor, E., Wickramasinghe, R., The mental and
physical health difficulties of children held within a British immigration detention center: a pilot study, Child
Abuse Negl. 2009 Sep;33(9):573-85.
9 Keller, As, Rosenfeld, B, Trinh-Shevrin, C., Meserve, C., Sachs, E., Leviss, J.A., Singer, E., Smith, H.,
Wilkinson, J., Kim, G., Allden, K., Ford, D. Mental health of detained asylum seekers. The Lancet, Volume 362,
No. 9397, p1721-1723, 22 November 2003.
10 Shonkoff, JP, Fisher, PA. Rethinking evidence-based practice and two-generation programs to create the future
of early childhood policy. Developmental Psychopathology, 2013, 25: 1635-1653.
t t International Detention Coalition (2012). Captured Childhood: Introducing a new model to ensure the rights and
liberty of refugee, asylum seeker and irregular migrant children affected by migration detention. The report is
available online at https://idcoatition.org/-,vp-content/uploads/2012/03/1DC-Captured-Childhood-Report-Chap5.pdf.

DECLARATION OF SHADI HOUSITYAR
IN SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

5

ATTORNEY GENERAL OF CALIFORNIA
13001 Street
Sacramento, CA 95814
916-44s-9sss

I

needs of a child and to support a child's healthy development. Research suggests that longer

2

periods in detention further compromise the capacity of parents to care for their children.

3

15. Based on my professional experience and background, available research and

4

testimonials of both families and experts, I can say with certainty that both detention and

5

family separation - even for short periods of time - are distressing, traumatic and damaging to

6

the health and wellbeing of children and parents.

7
I declare under penalty of perjury under the laws of the State of California and the United
8
States of America that the foregoing is true and correct.
9
Executed on this 27 day of June, 2018 in Washington, DC.
10
11
12
13
Shadi Houshyar
Director of Early Childhood and Child
Welfare Initiatives, Families USA

14
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26

DECLARATION OF SHADI HOUSIIYAR
IN SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

(

ATTORNEY GENERAL OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

Exhibit 52

Exhibit 53

1
2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

8
9

STATE OF WASHINGTON, STATE OF
CALIFORNIA, et al.

10
11
12

NO. 2:18-CV-00939
DECLARATION OF MAYRA E.
ALVAREZ IN SUPPORT OF
PLAINTIFFS’ MOTION FOR
EXPEDITED DISCOVERY

Plaintiffs,
v.
UNITED STATES OF AMERICA, et al.,

13

Defendants.

14
I, Mayra E. Alvarez, declare as follows:
15
1.

I am over the age of 18 and make this declaration based upon my expertise and

16
personal experiences.
17
2.

I am the President of The Children’s Partnership (TCP), a nonprofit children’s

18
advocacy organization committed to giving every all children, no matter their background, the
19
resources and opportunities they need. The work of TCP is dedicated to improving the lives of
20
underserved children where they live, learn, and play with breakthrough solutions at the
21
intersection of research, policy, and community engagement. For nearly 25 years, we have
22
worked to champion policies and offer resources to provide all children with the opportunities
23
they need to thrive. TCP is a leading voice for children and a critical resource for communities
24
across California and the nation. We aim to close the opportunity gap confronting too many
25
children, especially children of color and those living in poverty, by improving health coverage
26
DECLARATION OF MAYRA E.
ALVAREZ IN SUPPORT OF
PLAINTIFFS’ MOTION FOR
EXPEDITED DISCOVERY

1

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1
2
3
4
5
6
7
8
9
10
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and care and expanding technology tools and opportunities. Our unique approach includes
engaging communities, collaborating with strategic partners, leading with innovative expertise,
and working on research-driven policies.
3.

I have a decade of experience in public health and health care policy and

community relations. Before coming to TCP, I held several assignments at the U.S.
Department of Health and Human Services (HHS). I served as Director of the State Exchange
Group for the Center for Consumer Information and Insurance Oversight at the Centers for
Medicare and Medicaid Services at the HHS. Prior to this, I served as the Associate Director
for the HHS Office of Minority Health (OMH), where I led the coordination of OMH’s work
related to the Affordable Care Act, community health workers, and language access, and also
served as the Project Director of OMH’s Center for Linguistic and Cultural Competency in
Health Care. Previously, I served as Director of Public Health Policy in the Office of Health
Reform at HHS where I had primary oversight responsibility for coordinated and timely
implementation of the public health, prevention, and health care workforce policy provisions in
the Affordable Care Act. I have served as a bilingual spokesperson on the Affordable Care Act
and other health issues for national and regional broadcast, print and online media,
including New York Times, Washington Post, Wall Street Journal, Women’s Health,
Cosmopolitan, Glamour, National Public Radio, Univision, Telemundo, CNN en Español, and
various state and local outlets. I received my graduate degree from the School of Public Health
at the University of North Carolina at Chapel Hill and my undergraduate degree from the
University of California at Berkeley. New harsh immigration policies and anti-immigrant
rhetoric have instilled a deep and growing fear inside many communities, threatening the
health, security, and well-being of children in immigrant families. Research suggests that
immigration enforcement activities—or the threats associated with immigration enforcement—

25
26
DECLARATION OF MAYRA E.
ALVAREZ IN SUPPORT OF
PLAINTIFFS’ MOTION FOR
EXPEDITED DISCOVERY

2

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1
2

negatively impact family processes, developmental trajectories, and the social and emotional
development of children. 1

3
4
5
6
7
8
9
10

4.

of an immigrant family. Approximately 88 percent of these children were born in the US while
the other 12 percent were born in a different country. 2 In California, half of all children—4.5
million—are part of an immigrant family. Approximately 92 percent of these children were
born in the US while the other 8 percent were born in a different country. 3 The current antiimmigrant climate and related policy changes have far-reaching negative impacts, impacting
citizens and noncitizen children alike, many living in fear as to what may happen if their parent
is deported or detained.

11
12
13
14
15
16
17
18
19

Eighteen million children in the U.S.—about a quarter of all children—are part

5.

Most recently, the troubling “zero tolerance” policy, which imposes criminal

penalties meant to deter immigrant families from coming to our country seeking asylum,
provides another example of the federal administration’s attack on children. Thousands of
children, some as young as a few months old, have been separated from their parents at the
border because of this new policy. The zero tolerance policy, announced in April by U.S.
Attorney General Jeff Sessions, calls for the Department of Homeland Security to separate any
child crossing the U.S.-Mexico border between ports of entry from the adults with them before
those adults are prosecuted. Once separated from their parent, the conditions at the
immigration detention centers are nothing a child should experience.

20
21
22
23
24
25
26

“U.S. Citizen Children Impacted by Immigration Enforcement.” American Immigration Council. June 04, 2018.
Accessed June 29, 2018. https://www.americanimmigrationcouncil.org/research/us-citizen-children-impactedimmigration-enforcement.
2
Zong, Jie, Jeanne Batalova, and Jeffrey Hallock. Frequently Requested Statistics on Immigrants and
Immigration in the United States. Report. February 27, 2018. Accessed June 29, 2018. https://www.migration
policy.org/article/frequently-requested-statistics-immigrants-and-immigration-united-states#Children.
3
“Foreign-Born Population, by Age Group (Regions of 65,000 Residents or More).” Kidsdata.org. Accessed June
29, 2018. https://www.kidsdata.org/topic/346/immigration250/table#fmt=464&loc=2&tf=79&ch=938,789,935,
936,937&sortColumnId=0&sortType=asc.
OFFICE OF THE ATTORNEY GENERAL
DECLARATION OF MAYRA E.
3
STATE OF CALIFORNIA
ALVAREZ IN SUPPORT OF
1300 I Street
PLAINTIFFS’ MOTION FOR
Sacramento, CA 94815
916-445-9555
EXPEDITED DISCOVERY
1

1
2
3
4
5
6
7

6.

anxiety, and withdrawal resulting in psychological distress, academic difficulties, and
disruptions in their development.4 In the short term, there are changes to bodily functions.
Research overwhelmingly suggests that the biological effects of stress negatively affects a
child’s ability to concentrate, remember things, and control and focus their own thinking. 5 In
the long term, such trauma and high levels of stress places children at risk of heart disease,
diabetes, and cardiovascular disease.6

8
9
10
11
12
13

7.

16
17

Experts have expressed children that are separated from their families and

placed in detention facilities may experience “toxic stress,” which is defined as a prolonged
exposure to highly stressful situations. 7 Toxic stress can disrupt a child’s brain architecture and
inhibit the development of children’s brains overall. 8 It can also keep them from developing
language and social, emotional bonds, and gross motor skills, and the development that they
could possibly have. 9

14
15

Separating children from their family increases symptoms of depression,

8.

For the children directly impacted by the separations and the millions of

children in immigrant families across the country, the damage is done. TCP conducted a survey
of health providers in California and found that nearly 90 percent of providers reported an
increase of children in immigrant families experiencing anxiety and fear, which are symptoms

18
19

“Statement of APA President Regarding Executive Order Rescinding Immigrant Family Separation Policy.”
Monitor on Psychology. June 20, 2018. Accessed June 29, 2018. http://www.apa.org/news/press/releases/
2018/06/family-separation-policy.aspx.
5
Thompson, Ross A. "Stress and Child Development." The Future of Children 24, no. 1 (2014): 41-59. Accessed
June 29, 2018. doi:10.1353/foc.2014.0004.
6
“Stress Has Lasting Effect on Child's Development.” February 15, 2012. Accessed June 29, 2018.
http://www.urbanchildinstitute.org/articles/editorials/stress-has-lasting-effect-on-childs-development.
7National Scientific Council on the Developing Child. (2005/2014). Excessive Stress Disrupts the Architecture of
the Developing Brain: Working Paper 3. Updated Edition. Accessed June 29, 2018. http://www.developingchild.
harvard.edu
8
Ibid.
9
Wise, Justin. “American Academy of Pediatrics President: Trump Family Separation Policy Is 'child Abuse'.”
June 18, 2018. Accessed June 29, 2018. http://thehill.com/latino/392790-american-academy-of-pediatricspresident-trumps-family-separation-policy-is-child.
4

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26

DECLARATION OF MAYRA E.
ALVAREZ IN SUPPORT OF
PLAINTIFFS’ MOTION FOR
EXPEDITED DISCOVERY

4

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 94815
916-445-9555

1
2
3
4
5
6

of trauma, related to their heightened awareness of the possibility of detention and
deportation.10 Over 70 percent reported an increase in children experiencing symptoms of
depression, such as feelings of sadness, sleeping problems, loss or gain of appetite, loss of
interest in activities they used to enjoy, and almost half stated that children in immigrant
families are increasingly being diagnosed with mental health conditions such as anxiety and
depression.

7
8
9
10
11
12
13
14

9.

Separation,” signed June 20, 2018 by President Trump, does not resolve this crisis. First, it
does nothing to address the trauma experienced by more than 2,000 children already separated
from their parents. Second, it implies that imprisoning whole families is an acceptable path
forward when we know family detention has repeatedly been found to be unsuitable for
children.11 The inhumane conditions that these children face while in detention centers—
caged, as well as physically and emotionally neglected—are devoid of compassion and
decency. This policy simply trades one source of childhood trauma for another.

15
16
17
18

Executive Order 13841, “Affording Congress an Opportunity to Address Family

10.

Detention negatively impacts the health of parents and children. As the Kaiser

Family Foundation noted in a recent publication on family separation, “global studies show
significant effects for children held in detention, including depression, post-traumatic stress,
suicidal thoughts and behaviors, developmental delays, and behavioral issues.”12 Rather than

19
20

“Healthy Mind, Healthy Future.” The Children's Partnership. Accessed June 29, 2018. http://www.childrens
partnership.org/priorities/healthy-mind-healthy-future/. (The percentages reflected in the one pager represent
surveyed providers agreement with each statement (n=151).
11
Locking Up Family Values, Again. Lutheran Immigration & Refugee Service and the Women’s Refugee
Commission. Report. October 2014. Accessed June 29, 2018. https://www.speakcdn.com/assets/2474/
lirswrc_lockingupfamilyvaluesagain_report_141114.pdf.
12
“Key Health Implications of Separation of Families at the Border (as of June 27, 2018).” June 27, 2018.
Accessed June 29, 2018. https://www.kff.org/disparities-policy/fact-sheet/key-health-implications-of-separationof-families-at-the-border/?utm_campaign=KFF-2018-DisparitiesPolicy&utm_source=hs_email&utm_medium=email&utm_content=64117341&_hsenc=p2ANqtz-iChgZOuKLvw1iOk06CZJWR3zL1-BGy5oA0_mWVPvhD33P7EXTOD_CyYrParWknG3XovNMGiMJVdHJobywh0PiBU5pFgjI_wGSmMQkFLGgRpZlX8&_hsmi=64
117341.
OFFICE OF THE ATTORNEY GENERAL
DECLARATION OF MAYRA E.
5
STATE OF CALIFORNIA
ALVAREZ IN SUPPORT OF
1300 I Street
PLAINTIFFS’ MOTION FOR
Sacramento, CA 94815
916-445-9555
EXPEDITED DISCOVERY
10

21
22
23
24
25
26

1
2
3
4
5
6
7

jailing families who are in deportation proceedings, the government should employ alternatives
to detention proven to be more effective while also limiting the long-term trauma to children
and their families. The Kaiser Family Foundation report also found that detaining families and
children is costlier than utilizing alternative programs, such as community-based supervision
and monitoring programs. 13 These alternatives can be based on an individualized assessment of
each family in order to support the well-being of children and ensure court appearance and
compliance with any final court orders.14

8
9

11.

In conclusion, separating children from their families or detaining children in

family prisons is not in the public health interest of the country or its residents.

10
11
12

I declare under penalty of perjury under the laws of the State of California and the
United States of America that the foregoing is true and correct.

13

Executed on this twenty-ninth day of June, 2018 in Los Angeles, CA.

14
15
16
Mayra E. Alvarez
President
The Children’s Partnership

17
18
19
20
21
22
23
24
25
26

“Key Health Implications of Separation of Families at the Border (as of June 27, 2018).” June 27, 2018.
Accessed June 29, 2018. https://www.kff.org/disparities-policy/fact-sheet/key-health-implications-of-separationof-families-at-the-border/?utm_campaign=KFF-2018-DisparitiesPolicy&utm_source=hs_email&utm_medium=email&utm_content=64117341&_hsenc=p2ANqtz-iChgZOuKLvw1iOk06CZJWR3zL1-BGy5oA0_mWVPvhD33P7EXTOD_CyYrParWknG3XovNMGiMJVdHJobywh0PiBU5pFgjI_wGSmMQkFLGgRpZlX8&_hsmi=64
117341.
14
Locking Up Family Values, Again. Lutheran Immigration & Refugee Service and the Women’s Refugee
Commission. Report. October 2014. Accessed June 29, 2018. https://www.speakcdn.com/assets/2474/
lirswrc_lockingupfamilyvaluesagain_report_141114.pdf.
OFFICE OF THE ATTORNEY GENERAL
DECLARATION OF MAYRA E.
6
STATE OF CALIFORNIA
ALVAREZ IN SUPPORT OF
1300 I Street
PLAINTIFFS’ MOTION FOR
Sacramento, CA 94815
916-445-9555
EXPEDITED DISCOVERY
13

Exhibit 54

1
2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

8
9

STATE OF WASHINGTON,
Plaintiff,

10

DECLARATION OF DR. JOSEPH
GALLEGOS IN SUPPORT OF
MOTION FOR A PRELIMINARY
INJUNCTION

v.

11
12

NO.

DONALD TRUMP in his official capacity
as President of the United States, et al.,

13

Defendants.

14
15

I, Joseph Gallegos, declare as follows:

16

1.

I am over the age of 18 and have personal knowledge of all the facts stated

2.

I have a doctorate in social work from the University of Denver, a master’s

17

herein.

18
19

degree in social work from Portland State University (“PSU”), and a B.S. in psychology from

20

PSU.

21

3.

I am currently a member of the Oregon Commission on Hispanic Affairs. From

22

2013-207, I was a member of the Oregon House of Representatives, representing the Hillsboro

23

area in Washington County, Oregon, an area that has a Latino population of over 20 percent.

24
25

4.

My background is that I was born in San Antonio, Texas. My parents moved to

Portland during WWII to work in shipyards. After the war, the family transitioned to summer

26
DECLARATION OF DR. JOSEPH
GALLEGOS IN SUPPORT OF MOTION
FOR A PRELIMINARY INJUNCTION

1

Oregon Department of Justice
100 SW Market St
Portland, OR 97201
Tel: [phone] / Fax: [phone]Error!
AutoText entry not defined.

1

farm-work—living in migrant worker camps throughout the Willamette valley and finishing

2

the season picking hops in Yakima valley. At 17, I spent my last summer working in the

3

fields. I spent the next ten years working in the Portland shipyards while completing my Viet

4

Nam era military duty with one year in the regular US Air Force and three years with the

5

Oregon Air National Guard. While working in the shipyard, I also attended night school at

6

Portland Community College and then PSU. At PSU, I earned a Bachelor of Science degree in

7

psychology with a minor in sociology and a certificate in social work. I went directly into the

8

MSW program at Portland state where my practicum experiences included an internship at the

9

JD Long Juvenile Detention Center; Family Counseling (with Latino and Native American

10

families) in NW Portland and community organizing with SE Impact; and as a Teaching

11

Assistant with a student clinical unit at the Salem mental hospital and finally as an instructor

12

during my final semester teaching a course on “Chicano Mental Health” to first-year MSW

13

students.

14

5.

In my professional opinion, experience and understanding, the federal

15

government’s family separation policy has created significant trauma within Oregon’s

16

immigrant community (and nationwide). My local area in Washington County, Oregon has

17

experienced a large number of immigration-related family separations when parents are taken

18

from their children, and the same is very probably occurring with the parents and children who

19

have been subject to the federal government’s latest policy. This often leads to a toxic stress

20

reaction on the part of both children and parents. Toxic stress is cumulative and permanent and

21

affects an individual both physiologically and psychologically.

22

6.

Toxic stress from family separations often causes illness in children, causes

23

them to miss school or to act out at school. It often affects their academic performance. In

24

Oregon, almost 25 percent of the K-12 school population is Latino, so the effect is felt

25
26
DECLARATION OF DR. JOSEPH
GALLEGOS IN SUPPORT OF MOTION
FOR A PRELIMINARY INJUNCTION

2

Oregon Department of Justice
100 SW Market St
Portland, OR 97201
Tel: [phone] / Fax: [phone]Error!
AutoText entry not defined.

Exhibit 55

Exhibit 56

1
2

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

3
4

STATE OF WASHINGTON,
Plaintiff,

5
6

v.

NO.
DECLARATION OF MARTA V.
MARTINEZ IN SUPPORT OF
PLAINTIFFS’ MOTION FOR
PRELIMINARY INJUNCTION

DONALD TRUMP in his official capacity as

7 President of the United States, et al.,
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

Defendants.
I, Marta V. Martínez, declare as follows:
1.

I am over the age of 18 and have personal knowledge of all the facts stated herein.

2.

I am the Founder of the Coalition of Advocates for Student Opportunities in
Rhode Island.

3.

Through my work with members of Rhode Island’s immigrant community who

are seeking higher education opportunities, I have observed the negative
impact that the family separation policy has had on Rhode Island’s young people.
4.

The family separation policy has caused these children to suffer trauma that will

negatively impact their ability to function and succeed in the classroom, and
thereby impair their ability to seek higher education opportunities.
I declare under penalty of perjury under the laws of the State of Rhode Island and the United
States of America that the foregoing is true and correct.
DATED this 29th day of June, 2018 at Providence, Rhode Island.

23
Marta V. Martínez
Founder
Coalition of Advocates for Student
Opportunities in Rhode Island

24
25
26

DECLARATION OF IN SUPPORT OF
PLAINTIFFS’ MOTION FOR
PRELIMINARY INJUNCTION

1

Error! AutoText entry not defined.

Exhibit 57

1
2
3
4
5
6
7
8
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

9
10
11

STATE OF WASHINGTON,
Plaintiff,

12
v.

13
14
15

NO.

DECLARATION OF LAURA S.
BROWN, PH.D., A.B.P.P., IN
SUPPORT OF THE STATE OF
WASHINGTON

DONALD TRUMP in his official
capacity as President of the United States,
et al.,
Defendants.

16
17

I, Laura S. Brown, declare as follows:
18
1.

I am over the age of 18 and have personal knowledge of all of the facts stated

I.

Background and Qualifications

2.

I am a licensed clinical and forensic psychologist in the State of Washington

19
herein.
20
21
22
and hold a Diplomate in Clinical Psychology from the American Board of Professional
23
Psychology. I earned my Bachelors of Arts in Psychology from Case Western Reserve
24
University (1972), my Master of Arts in Clinical Psychology (1975) and my Doctor of
25
Philosophy in Clinical Psychology (1977) from Southern Illinois University.
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

1

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
3.

I have held academic positions for over 30 years, including the following:

2
Courtesy Clinical Professor, Department of Psychiatry and Behavioral Sciences, University
3
of Washington (2015-present); Clinical Assistant Professor, Smith College School for Social
4
Work (2011-2012); Adjunct Professor of Clinical Psychology, Washington School of
5
Professional Psychology (2006-2009); Professor of Psychology, Washington School of
6
Professional Psychology (2001-2006);

Clinical Professor of Psychology, University of

7
Washington (1980-1997); Acting Assistant Professor of Psychology, University of
8
Washington (1978-1980); Assistant Professor of Psychology, Southern Illinois University at
9
Carbondale (1977-1978).
10
4.

For nearly 40 years, since 1979, I have maintained a private practice of

11
psychotherapy, expert consultation, and forensic psychology.

I also supervised clinical

12
psychology and social work graduate students, as the Director and Founder of the Fremont
13
Community Therapy Project, a clinic for low-income individuals, between 2006 and 2015.
14
5.

One of my areas of expertise, and a focus of my clinical, forensic, and

15
academic work, is the assessment and treatment of the psychological and psychosocial effects
16
of trauma exposure. My work includes substantial psychological treatment, supervision of
17
treatment, and expert evaluation of adults with psychological conditions arising from
18
childhood traumatization (e.g. child abuse and neglect, parent-child separation, sexual abuse
19
20
21
22
23
24
25

and violence, abuse of authority and institutional betrayal) as well as adults experiencing
harm from recent traumatic events (e.g. domestic violence, rape and other sexual violence,
hostile work environment and harassment at work or at school, abuse in the foster care
system). I have evaluated and treated persons who, as children, were removed from their
parents’ home as part of child dependency proceedings and suffered abuse in the foster care
system, as well as immigrant and refugee women fleeing violence who were seeking asylum
or visas to remain in the United States.
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

2

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
6.

I am an active member and leader in a number of professional organizations

2
devoted to trauma and trauma recovery, including the American Psychological Association
3
Division of Trauma Psychology, of which I am a former President, the International Society
4
for Traumatic Stress Studies, and the International Society for the Study of Trauma and
5
Dissociation. I helped to shape and develop best practices and guidelines for the treatment of
6
Post Traumatic Stress Disorder (PTSD) as a member of the Guidelines Panel of the American
7
Psychological Association that developed Clinical practice guidelines for the treatment of
8
PTSD in Adults (February 2017). I have been appointed and served as co-editor of special
9
issues of two peer-reviewed journals on treatment of PTSD.
10
7.

My academic work includes professional editorial board service on 16

11
different professional journals since 1980, including the following devoted to trauma: Journal
12
of Traumatic Stress; Psychological Trauma: Theory, Research, Practice, Policy; and the
13
Journal of Trauma and Dissociation, for which I am the Associate Editor for Clinical Issues.
14
I have authored 14 books, and over 150 articles and chapters in professional journals or
15
books, many of which deal with issues of trauma, including the following:
16
Ellis, A., Simiola, V., Brown, L.S., Courtois, C.A. & Cook, J. M. (2018). Effect of evidence17
based treatment relationships on treatment outcome for adults with trauma: A systematic
18
review. Journal of Trauma and Dissociation, 19, pp. 185-213;
19
20
21
22
23
24

Brown, L. S. (2017). Feminist And Multicultural Perspectives In Trauma Psychology. In S.
Gold, C. Dalenberg & J. Cook (Eds). APA Handbook Of Trauma Psychology (pp. 501-526).
Washington DC: American Psychological Association;
Brown, L.S. (2013). Treating The Effects Of Psychological Trauma. In G. Koocher, J.C.
Norcross, and B. Greene (Eds). Psychologists’ Desk Reference (Third Ed.)(pp. 289-293).
New York NY: Oxford University Press;
25
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

3

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
Brown, L.S. (2009). Cultural Competence In The Treatment Of Complex Trauma. In C.
2
Courtois & J. Ford (Eds.) Treating Complex Traumatic Stress Disorders: An Evidence-Based
3
Guide. New York NY: Guilford Press; and
4
the text, Cultural Competence In Trauma Treatment: Beyond The Flashback, published in
5
2008 by the American Psychological Association.
6
In addition, I was chosen by the American Psychological Association to be the therapist
7
demonstrating trauma treatment for the APA Psychotherapy Video Series in the videos titled
8
Treating Women Survivors Of Abuse and Treating Men Survivors Of Abuse.
9
8.

I have been recognized with over 30 professional honors, awards, and

10
fellowships throughout my career, including the Sarah Haley Award for Clinical Excellence
11
from the International Society for Traumatic Stress Studies, “Fellow” status from the
12
International Society for the Study of Trauma and Dissociation, and the Lifetime
13
Achievement Award of the Division of Trauma Psychology of the APA. I have also received
14
the Social Justice and Distinguished Psychologist Awards of the Washington State
15
Psychological Association, and the award for Distinguished Professional Contributions to
16
Public Service from the American Psychological Association.
17
9.

I have been qualified as an expert on the topic of psychological trauma in

18
federal courts as well as in state courts in Washington, Oregon, Alaska, California, and
19
20
21
22
23
24
25

Illinois. A true and correct copy of my full C.V. is attached as Exhibit A.
10.

The following opinions and testimony are based upon my education and

experience, and the research and scholarship in the field of trauma psychology, and are
extended on a more probable than not basis to a reasonable degree of psychological certainty.
In forming my opinions, I am also guided by the leadership of my professional organization,
the American Psychological Association, and embrace and incorporate by reference herein
the APA’s policy statement against forcible family separation, as set forth in Exhibit B, as
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

4

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
well as the letter written by APA’s President, Dr. Jessica Henderson Daniel to the U.S.
2
Departments of Justice and Homeland Security expressing her professional opinion on this
3
matter, as set forth in Exhibit C. The references in this declaration are in short form; the
4
complete citations are included at the end of the declaration.
5
II.

Forcible Family Separation Causes Short Term and Long Term Damage

11.

As set forth in greater detail below, the forcible separation of children from

6
7
their good-enough and loving parents, as the United States government is currently doing to
8
immigrant families on the southern border, hereinafter “Family Separation,” is likely to cause
9
immediate, acute, harm as well as reasonably foreseeable long-term damage and harm to
10
both the parents and the children (Rojas-Flores, Clements, Koo, & London, 2017).
11
Psychological harms are also accruing now to the citizens and legal residents of Washington
12
and the United States as a result of these actions by the Federal government.
13
A.

Trauma and Its Effects on Psychological and Physical Health

12.

Traumatic stressors include a range of experiences that threaten the safety or

14
15
life of humans (American Psychiatric Association, 2013, Dalenberg, Straus & Carlson,
16
2017). Family Separation is, by and of itself, a disruption to the bonds of attachment between
17
good-enough parents and their children and constitutes a traumatic stressor. Grief and
18
bereavement can also be traumatic when the circumstances of the loss are unusually painful
19
20
21
22
23
24
25

and out of control of the persons experiencing loss, as is the case for the parents and children
subject to Family Separation. (Pearlman, Wortman, Feuer, Farber & Rando, 2014). Extensive
research conducted over the past fifty years documents short and long-term effects on
physical and mental health of one-time and repeated trauma exposures in childhood and
adulthood (Gold, Cook, & Dalenberg, 2017). Trauma is a biopsychosocial as well as
spiritual/existential challenge to human beings, and affects its targets on all of those variables
(Brown, 2008).
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

5

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
13.

The likely effects and consequences of traumatic stress and trauma exposure,

2
like Family Separation, include the following:

depressed mood, anxiety, panic, terror,

3
intrusive thoughts, social withdrawal, substance abuse, suicidality, increased risk of acting4
out behaviors, self-harm, complicated grief, problematic relationships, difficulties in
5
parenting, health problems, hopelessness, helplessness (Gold, Cook & Dalenberg, 2017).
6
These problems can be long-lasting and at times are disabling and debilitating.
7
14.

If it cannot be prevented, traumatic stress can be effectively treated. The

8
sooner that treatment is offered, the more likely a person is to recover to their prior level of
9
functioning. Post-traumatic symptoms that persist over time are less amenable to even the
10
most effective of treatments and may become disabling. A number of effective treatments are
11
now available for traumatized people. These include, treatments for children-Trauma12
Focused CBT (TF-CBT) and Eye Movement Desensitization Reprocessing (EMDR) – and
13
for adults - EMDR, Prolonged Exposure (PE) and Cognitive Processing Therapy (CPT).
14
EMDR, PE and CPT are utilized by the Veterans’ Administration, for example, in the
15
treatment of combat veterans with PTSD. These treatments have been developed for
16
individuals experiencing a one-time trauma exposure, and are not known to be as effective
17
with people having repeated trauma exposures (American Psychological Association,
18
Guideline Development Panel for the Treatment of PTSD in Adults (2017 February). Clinical
19
20
21
22
23
24
25

practice guideline for the treatment of Posttraumatic Stress Disorder (PTSD) in adults.
Retrieved from: http://www.apa.org/about/offices/directorates/guidelines/ptsd.pdf.
15.

Under the right conditions, and with the right supports, people can make

substantial recovery from trauma exposures. In addition to appropriate psychotherapeutic
treatments, a number of other important psychosocial factors improve the likelihood of a
person’s recovery to their prior adequate-to-good psychological functional capacities. These
factors include the availability of social and familial support, religion and faith, and an
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

6

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
optimistic temperament. Children are particularly dependent upon the family structure, and
2
on parental love, care, and attachment, to cope with traumatic stress. Normally, parents serve
3
as a “buffer” and protective force between youth and outside stressors. Under the Family
4
Separation policy, then good-enough parents are forcibly separated, and made unavailable to
5
their children, children are doubly harmed: they experience the acute stress of the separation
6
and also are undermined in their ability to handle and recover from that and other traumas in
7
their lives. Alternatively, when good-enough parents are available, their presence is a
8
powerful protective and mitigating factor assisting children in being both resilient in the face
9
of trauma and recovering from trauma when they have been affected by it (Bolton, Jordan,
10
Lubin & Litz, 2017).
11
16.

Trauma of human origin has long been identified as worse for its targets than

12
are natural disasters. This is because human agency or neglect in causing or allowing trauma
13
to occur undermines our necessary human capacities to trust in one another. We rely, as
14
human beings, on other humans keeping implicit social contracts to care for and protect one
15
another, based in evolutionary requirements for humans to relate to one another in order to
16
survive (Figley, Ellis, Reuther & Gold, 2017).
17
17.

People also rely on powerful institutions, which stand as proxies for our

18
relationships to the larger society, to protect us when we come to them for help in our time of
19
20
21
22
23
24
25

need. When those institutions betray trust, either by failing to protect or by putting people in
the way of more harm, then people suffer from Institutional Betrayal. (Smith & Freyd,
2014). Institutional betrayal is by and of itself a form of trauma. When combined with other
traumatic stressors, it increases the severity of distress felt by the traumatized person and
complicates the process of recovery from trauma. When people witness or observe an
institution betraying other people, their own trust in that institution is affected and they may
experience trauma as well.
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

7

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
18.

Until very recently, most people around the world have perceived the U.S. as a

2
beacon of hope and safety, a potential place of refuge should their country of origin become
3
too dangerous. The words of The New Colossus, the poem engraved within the Statue of
4
Liberty, speak to this image of the U.S. People flee here for safety because this is a country
5
of laws and constitutional protections, of equality of opportunity and care for the vulnerable,
6
of access to legal redress when injustice has been done. The families impacted by Family
7
Separation, many of whom report that they are seeking asylum in the U. S., a country in
8
which they placed their faith and trust, are in my opinion likely experiencing institutional
9
betrayal at the hands of a government that they had hoped would protect them and at least
10
would operate consistently with the rule of law. This institutional betrayal adds a layer of
11
severity and complexity to the trauma of forced Family Separation.
12
B. Effects of Forced Family Separation on Children
13
19.

Family Separation is a traumatic loss for the children who are separated from

14
their parent, as a result of which they are likely to experience a range of problematic
15
emotions, including terror, fear, sadness and grief, confusion, and distrust. Even when a
16
parent has been abusive to a child, separating the child from the parent is perceived as painful
17
by the child; when the parent is loving and caring, and offers secure attachment, a forced and
18
sudden separation is a profound trauma and loss for that child. Family Separation is likely to
19
20
21
22
23
24
25

cause immediate and extreme psychological harm, including post-traumatic symptoms such
as nightmares, and other manifestations of anxiety and depression, all of which are likely to
increase in severity the longer the separation lasts and lead to the potential development of
problematic coping strategies in both the near and long term.

It is likely that Family

Separation will cause permanent harm to many of the children who are forcibly separated
from good-enough and loving parents, impairing their psychological, mental, social and
physical development well into their lives, and resulting in long-lasting psychological injury
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

8

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
and conditions, including PTSD, and other trauma-related disorders. See the well2
documented

literature

on

Adverse

Childhood

Experiences

(ACES)

3
(https://www.samhsa.gov/capt/practicing-effective-prevention/prevention-behavioral4

health/adverse-childhood-experiences, doi June 16th, 2018).

5
20.

While the separation of a child from a good enough primary adult caregiver is

6
traumatic in any event, many factors present in the Federal government’s current Family
7
Separation policy increase the traumatic nature of these separations. These include: the lack
8
of information available to the children about why they are being separated from their
9
parents; the suddenness of the separation and lack of opportunity to say goodbye; the lack of
10
an opportunity to plan for and discuss the separation with their parents; the effect of the
11
child’s developmental stage on their capacities to make sense of what is occurring, leading to
12
self-blame, particularly on the part of much younger children; fear about what is happening
13
to the parent, and, given the circumstances that have led some of these families to leave their
14
country of origin and seek asylum, fear that the parent may have been taken away to be killed
15
or disappeared (Rojas-Flores, Clements, Koo, & London, 2017).
16
21.

For the children and families who are attempting to escape endemic and

17
sometimes government-sanctioned violence in their countries of origin, and those who have
18
been exposed to high levels of violence and trauma prior to this new traumatic event, the
19
20
21
22
23
24
25

impact of the Family Separation is even more severe (Suárez-Orozco, Bang, & Kim, 2010).
22.

Taking children from their good-enough parents creates additional risks that

arise during the process of placing children into non-family care. These children are now
being kept in temporary holding spaces, institutional settings, or foster homes of strangers.
Even the very best of institutions and foster homes cannot match the love and care given by a
protective parent; in some instances, sadly, institutions and foster homes become places in
which already-vulnerable children are exposed to physical, emotional, and sexual abuse or
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

9

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
neglect. The psychological cost to the children subjected to Family Separation thus can grow
2
exponentially.
3
23. Studies of other children similarly separated from their families in institutional or
4
foster homes reveal that they suffer attachment loss and traumatic bereavement, leading to
5
the development of a wide range of physical and psychological symptoms (Wilt, Maltby &
6
Cook, 2017, Evans-Campbell, Pearson, Walters & Campbell, 2012). Children subject to
7
Family Separation are likely to experience deterioration of their mental condition and sense
8
of well being, and develop psychologically abnormal conditions with diagnoses including:
9
anxiety, depression, and PTSD. Many of these children are likely to manifest short-term
10
symptoms of this trauma, including crying, difficulty sleeping, difficulty eating,
11
aggressiveness/acting out, regression (e.g., losing language abilities or toilet training), or
12
withdrawal from others. Others may appear stoic, strong, hardened, and brave – especially
13
in circumstances where they have lost trust in adults, or are surrounded by strangers who may
14
not speak their language, and thus feel unsafe to expose their vulnerability. It is likely that
15
this sub-group of Family Separation children are experiencing dissociation, an involuntary
16
psychological defense against overwhelming and intolerable terror in a situation from which
17
there is no escape (Steele, Boon, & Van der Hart, 2017). Dissociation at the time of trauma is
18
a predictor of more persistent and severe post-traumatic symptoms later in life. All children
19
20
21
22
23
24
25

subject to Family Separation are likely to be experiencing trauma and have had damage done
to their psychological well being, regardless of the coping mechanism they use to address it.
Longitudinal research on traumatized children (Putnam, 1997, Widom, 1999, Widom,
Horan, & Brzustowicz, 2014) has shown that for many such children, trauma has a “sleeper
effect,” with symptoms going underground and not appearing until later in life.
24.

Children who are separated from good enough parents during critical periods

of child development experience attachment loss at a period that is likely to result in lasting
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

10

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
damage to their relationships with their parents, to their social development and their
2
capacity to develop trusting relationships, to their behavioral development, and to their
3
physical health. The harm to the children is likely to be greater if the separation is prolonged.
4
Our best data about the effects of involuntary separation from parents comes from observing
5
the trajectory of American Indian (Evans-Campbell, Pearson, Walters & Campbell, 2012),
6
Canadian First Nations (Wilt, Maltby & Cook, 2017), and Australian Aboriginal children
7
(Aboriginal Legal Services of Western Australia, 1995) who were taken forcibly from their
8
loving families and placed into institutional care. In these populations of people who were
9
forcibly separated by a government from loving families and cultures, the rates of a variety of
10
physical and mental illnesses are very high and higher than in the general population. There
11
is documented excess occurrence of depression, anxiety, substance abuse disorders and other
12
compulsive acting-out disorders, PTSD and suicidality. These populations of people also
13
have much higher rates of illness and premature death than the general population. They are
14
more likely to serve time in prison, more likely to be homeless, and less likely to complete
15
their education. The populations of indigenous people who have experienced this kind of
16
government-caused forcible separation from good enough parents are large enough that these
17
data are robust and can likely be generalized to our understanding of other groups of children
18
similarly treated.
19
20
21
22
23
24
25

25.

In the present Family Separation situation, similar to what happened to the

indigenous peoples of the U.S., Canada, and Australia, the children are being forcibly
separated from parents, many of whom are loving and protective, and many of whom report
that they were willing to risk much to flee an unsafe situation and get their children to safety.
Even if and when these children are reunited with their parents, the children’s sense of safety
and capacity to trust in their parents has now been undermined; this experience is likely to
cause long-term damage and undermine their trust in those parents’ ability to be able to
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

11

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
protect them in the future (Chaudry, 2011). In my experience, many adults in treatment for
2
the long-term effects of childhood trauma still struggle to make emotional sense of decisions
3
and actions of their parents even when they can intellectually comprehend them. These adults
4
still experience pain and suffering from those decisions. For the children, all of this is simply
5
inexplicable fear and loss, and is often a source of anger against the parent who they believe
6
has failed them. It is common for the child to turn its anger on the nearest person, and the
7
previously most trusted person - the parent –and not the U.S. government.
8
26.

The impact of the trauma from Family Separation is worsened by the presence

9
of institutional betrayal (Smith & Freyd, 2015). In this case, it is the Federal government that
10
has decided to separate these families. This policy has psychological consequences; it
11
undermines trust and overall sense of well being, and creates a sense in those directly
12
affected and those who are observing it, of being at risk, rather than protected, by
13
government and institutions. We can see this phenomenon in the populations of indigenous
14
adults who were forcibly separated as children from loving families by governments. U.S.
15
resident and citizen children who become aware of the Family Separation policy through the
16
news media are also likely to suffer psychological harm, especially those who previously
17
immigrated to the United States or those who share an ethnic identity with the children
18
subjected to forcible separation from their parents via the process of insidious traumatization
19
20
21
22
23
24
25

(Root, 1992), in which trauma occurring to those who resemble us or remind us of ourselves
can become traumatizing to the observer.
27.

Forcible separation of a child from a parent, through incarceration or detention

of that parent, constitutes an Adverse Childhood Experience (ACE).

As such, Family

Separation constitutes an ACE. Children who experience two or more ACES are more likely
to experience long-term psychological and behavioral problems, such as depression, anxiety,
and substance abuse, as well as chronic physical conditions including heart disease,
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

12

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
pregnancy loss, and early death. ACES are a well-documented phenomenon that has been
2
publicized

by the

United

States

Department

of Health and

Human

Services

3
(https://www.samhsa.gov/capt/practicing-effective-prevention/prevention-behavioral4
health/adverse-childhood-experiences doi June 16 2018). As a result of Family Separation,
5
the Federal government is causing harm, and aggravating pre-existing vulnerabilities of those
6
who may already be at risk, by adding at least one ACE (separation from a parent, parental
7
incarceration) to the lives of the children involved. It is also removing the most potent and
8
effective protective factor for children at risk, the presence of a protective good enough
9
parent.
10
11
12
13
14
15
16
17

C. Effects of Family Separation on Parents
28.

Parents who arrive together with their children at the U.S. border, and then are

separated from their children by the U.S. government, are likely to experience immediate and
acute psychological harm and injury as a result of that sudden forced separation. A parent’s
foremost duty is to care and protect their child. This duty of care for children is hard-wired
into our DNA by evolution (Schore, 2003). Because humans are born unable to care for
themselves, and thus require care from a parent for many years, it is a survival necessity for
parents to care for and protect their children (Siegel, 2012). When a child is forcibly and
18
suddenly taken from a parent, the parent is likely to experience that separation as a traumatic
19
20
21
22
23
24
25

loss,leading to feelings of fear, worry, and terror about their child’s safety and well-being,
and to shame and a sense of failure due to this out-of-control inability to care and protect
their child. They are also likely to experience continuing sadness and grief at the separation.
In addition, in the current circumstance of Family Separation, many parents are being
separated from their children suddenly without the chance to prepare the child or even say
goodbye, without knowing where they or their children will be taken, without any guarantee
of reunification, and often without contact with their children or with long gaps in that
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

13

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
contact. For those parents who come to the border reporting that they have already suffered
2
trauma through violence exposures in their countries of origin, and for those reporting that
3
they have fled to the U.S. in the hope of protecting their children and saving their children’s
4
lives, these forcible separations are a painful and terrifying betrayal by a government.
5
29.

These parents are likely to experience deterioration of their mental and

6
physical health in the aftermath of the forcible separation from their children with symptoms
7
including: anxiety, depression, PTSD, and other trauma-related disorders. Often they will
8
show short term symptoms of this harm, including depressed mood, nightmares, intrusive
9
thoughts, hypervigilence, suicidality, disordered eating, self-harm, substance abuse, and
10
emotional and social withdrawal. As discussed in the section on children’s trauma responses,
11
some of these parents may appear stoic and strong in the face of this loss. As with their
12
children, however, that may be evidence that the trauma is so great that the parent has
13
dissociated from the pain. This dissociation can, in turn, predict greater symptom severity
14
over time.
15
30.

In some cases, parental trauma from separation from their children will

16
become unbearable because their available coping mechanisms may be overwhelmed by the
17
sudden loss of the important role of parent and protector of the child. In such cases, it is not
18
unreasonable to expect some parents to attempt to take their own lives out of terror and
19
20
21
22
23
24
25

despair. I am aware of media reports of at least two suicides of parents forcibly separated
from their children at the U.S. border. These separations have, in effect, permanently
destroyed these parents’ hope that they might some day raise their children in relative safety.
31.

There is long-term damage to the adults who experience trauma.

These

parents have experienced a profound betrayal by the government of the U.S. Their children
have been “disappeared” by the Federal government. In Latin America, children who have
been disappeared by a government have often been killed; thus, the governmental
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

14

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
disappearance of a child carries with it a particular form of terror for parents from Latin
2
America. This forcible separation can undermine the families even once they are reunited, as
3
both parent and child will be suffering the effects of the separation. The parents will be
4
impaired in their capacities to parent at a time when the children, also suffering, will be more
5
than ever in need of their parents’ love and care. Research on children of mothers with
6
depression, which may characterize many of these parents, indicates that their children are at
7
higher risk for a range of psychological disorders and behavioral problems. These problems
8
affect children’s school functioning, and can lead to conflict and disruption of relationships
9
within families (Canadian Paediatric Society, 2004). It is reasonable to extrapolate from this
10
robust body of knowledge about depressed parents in general to the parents suffering Family
11
Separation, whose depressed mood will thus affect their children’s functioning.
12
32.

Because of the harms done to psychological and physical well-being by this

13
forcible separation from their children, and the concurrent loss of positive coping strategies
14
inherently required for being a parent, these parents are likely to have increased needs for
15
both mental health and medical treatment. I can predict this given the known biological and
16
psychological consequences of prolonged traumatic stress, of which this forcible separation
17
is an example. These parents will need access to trauma-informed psychotherapy. They are
18
likely to suffer from a number of somatic complaints that are often expressions of post19
20
21
22
23
24
25

traumatic symptoms within their culture of origin, including increased pain of unknown
physical origin, headaches, and gastrointestinal distress. Because prolonged stress leads to
systemic physical inflammation, these parents are also at higher risk over the lifespan to
develop cardiovascular disease, cancer, and auto-immune diseases, given that systemic
inflammation has been implicated in all of these disorders. The health and mental health
burdens imposed by this forced separation on an already vulnerable population of parents
will be large and long-lasting.
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

15

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
D. Effects of Family Separation on Others
2
33.

This Family Separation policy is also causing, and will continue to cause,

3
harm to the emotional well-being of current legal residents and citizens of Washington State.
4
Some people will have their own prior traumas of forced separation from parents re5
activated, leading to a resurgence in symptoms. Populations at risk in this way include
6
indigenous people sent to government schools, survivors of the Holocaust who were
7
separated from their parents, and many former foster children. These individuals’ mental
8
health is being placed at risk by the policy of forced separation of children and parents at the
9
U.S. border. Their physical well-being is also likely to be adversely affected, as the medical
10
consequences of psychosocial stress and trauma will likely be increased for them.
11
34.

This policy is also likely to be frightening to other immigrants and refugees

12
currently living in Washington State. This apparent sudden change to how the United States
13
treats families coming to its borders is likely to evoke feelings of insecurity and instability in
14
them, and create a sense of institutional betrayal. These immigrant and refugee parents may
15
begin to fear that they, too, may be forcibly separated from their children, particularly if the
16
parents’ legal status is ambiguous in any way. The apparent unpredictability and fast17
changing nature of US policy on this matter undermines faith and trust in the Federal
18
government, and creates fear, anxiety, and possible reactivation of prior post-traumatic
19
20
21
22
23
24
25

symptoms.
35.

Finally, these policies affect many other citizens of Washington State who are

not immigrants, refugees, or persons who have experienced forcible parent-child separation.
Most parents can imagine how they might feel were a government to forcibly remove their
child from their care. Children who are exposed to this news are being made aware that their
relationships with their parents may not be entirely secure, and that a government can decide
to pull children away from parents who are good enough. These other citizens of our state
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

16

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
and of the U.S. are at risk of emotional harm because they have been made into often2
helpless bystanders to a scenario that ti7ghtens and upsets them. Helplessness and feelings of
3
disempowerrnent, and governmental actions that reduce trust, undermine people's well-being.
4
III. Conclusion
5
6

36. The Family Separation policy of the Federal government requiring the separation
of certain families who enter the U.S. causes serious and severe harm to the mental health

7
and well-being of the children and parents who are subjected to it. This policy also causes
8
harm to current legal residents of the United States, including citizens, legal permanent
9
residents and immigrants, refugees; and asylum seekers. The costs of being directly. or
10

indirectly subjected to this trauma are likely to be high, not only to the persons directly

11
affected, but also to the State of Washington and the U.S. society, both now and over time.
12
I declare under penalty of perjury under the laws of the State of Washington and the
13

United States of America that the foregoing is true and correct.
14
DATED this /jq _day of June, 2018 at

q"

, Washington.

15
16 1
17 1
au a . Brown, Ph.D., A.B.P.P.

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24
25
26

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

17

ATTORNEY GENERAL of WASTUNGTON
800 Fier Avenue. suite 2000
scattie, WA 98104-3188
[phone]

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4
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9
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Declaration References
Aboriginal Legal Services of Western Australia (1995). Telling our story. Perth Western
Australia: Author.
American Psychiatric Association (2013). Diagnostic and statistical manual of mental
disorders (Fifth Ed.). Washington DC: American Psychiatric Press.
Bolton, E. E., Jordan, A. H., Lubin, R.E., & Litz, B. T. (2017). Prevention of post traumatic
stress disorder. In S. Gold, C. Dalenberg, & J. Cook (Eds). APA handbook of trauma
psychology, Vol II: Trauma practice. Washington DC: American Psychological Association.
Brown, L.S. (2008). Cultural competence in trauma treatment: Beyond the flashback.
Washington DC: American Psychological Association.
Canadian Paediatric Society (2004). Maternal depression and child development. Paediatric
Child Health, 9, 575-583.
Chaudry, A. (2011). Children in the aftermath of immigration enforcement. The Journal of the
History of Childhood and Youth, 4, 137-154.
Dalenberg, C., Straus, E., and Carlson, E.B. (2017). Defining trauma. In S. Gold, J. Cook, &
C. Dalenberg (Eds). APA handbook of trauma psychology, Vol I: Foundations in knowledge.
Washington DC: American Psychological Association.
Evans-Campbell, T., Walters, K.I., Pearson, C.R. & Campbell, C.D. (2012). Indian boarding
school experience, substance use, and mental health among urban two-spirit American
Indian/Alaska Natives. American Journal of Drug Abuse, 38, pp 421-427.
Figley, C., Ellis, A., Reuther, B. & Gold, S. (2017) The study of trauma: A historical
overview. In S. Gold, J. Cook, & C. Dalenberg (Eds). APA handbook of trauma psychology,
Vol I: Foundations in knowledge. Washington DC: American Psychological Association.
Gold, S., Cook, J., & Dalenberg, C.A (2017) APA handbook of trauma psychology, Vol I:
Foundations in knowledge. Washington DC: American Psychological Association.
Gold, S., Dalenberg, C.A., & Cook, J. (2017) APA handbook of trauma psychology, Vol II:
Trauma practice. Washington DC: American Psychological Association.
Pearlman, L.A. Wortman, C. B., Feuer, C.A., Farber, C. H & Rando, T.A. (2014). Treating
traumatic bereavement: A practitioners guide. New York NY: The Guilford Press.
Putnam, F. W. (1997). Dissociation in children and adolescents: A developmental perspective.
New York NY: The Guilford Press.
Rojas-Flores, L., Clements, M., Koo, J. London, J. (2017). Trauma and psychological distress
in Latino citizen children following parental detention and deportation. Psychological Trauma:
Theory, Research, Practice, and Policy, 9, 352-361.

DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

18

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

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7
8
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Root, M. P. P. (1992). Reconstructing the impact of trauma on personality. In L. S. Brown &
M. Ballou (Eds.), Personality and psychopathology: Feminist reappraisals (pp. 229-265). New
York: The Guilford Press.
Schore, A. N. (2003). Affect regulation and disorders of the self. New York NY: W.W. Norton.
Siegel, D. (2012). Pocket guide to interpersonal neurobiology New York NY: W. W> Norton.
Smith, C. P. & Freyd, J.J. (2015). Institutional betrayal. American Psychologist, 69, 575-587.
Steele, K., Boon, S., & Van der Hart, O. (2017). Treating trauma-related dissociation. New
York NY: W. W. Norton.
Suárez-Orozco, C., Bang, H.J. & Kim, H.Y (2010). I felt like my heart was staying behind:
Psychological implications of family separations and reunifications for immigrant youth.
Journal of Adolescent Research 26, 222-257.
Widom, C. S. (1999). Posttraumatic stress disorder in abused and neglected children grown
up. American Journal of Psychiatry, 156, 1223-1229.
Widom, C. S., Horan, J., & Brzustowicz, L. (2015). Childhood maltreatment predicts allostatic
load in adulthood. Child Abuse & Neglect. 47, 59–69.
Wilk, P., Maltby, & Cooke, M. (2017). Residential schools and the effects on Indigenous health
and well-being in Canada—a scoping review. Public Health Reviews 38, 1-23.
Laura S. Brown, Ph.D., A.B.P.P.

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DECLARATION OF LAURA S. BROWN,
PH.D., A.B.P.P., IN SUPPORT OF THE
STATE OF WASHINGTON

19

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

Exhibit A

CURRICULUM VITAE
LAURA S. BROWN, PH.D., ABPP
March 2018
3429 Fremont Place North #319, Seattle WA 98103
[phone] V/[phone] F
Email: [e-mail]
www.drlaurabrown.com
Diplomate in Clinical Psychology, American Board of Professional Psychology
Washington Psychology License #0615
EDUCATION
B.A., cum laude, Case Western Reserve University, Cleveland, Ohio. May, 1972. Psychology major.
M.A., Southern Illinois University, Carbondale, Illinois. May, 1975. Clinical Psychology.
Ph.D., Southern Illinois University, Carbondale, Illinois. August, 1977. Clinical Psychology.
HONORARY DEGREE

Doctor of Humane Letters, Honoris Causa, Massachusetts School of Professional Psychology, 1998.
PROFESSIONAL AFFILIATIONS
American Psychological Association: Fellow, 1987. Affiliated with Divisions 9, 12, 29, 35, 42, 43, 44, 45, 46, 56
Association for Psychological Science: Fellow, 1992
Washington State Psychological Association
Association for Women in Psychology
International Society for Traumatic Stress Studies
American Board of Professional Psychology
International Society for the Study of Trauma and Dissociation, Fellow, 2014
National Academies of Practice
CURRENT POSITIONS
Private practice of psychotherapy, consultation and forensic psychology, 1979-present
Courtesy Clinical Professor, Dept of Psychiatry and Behavioral Sciences, University of Washington, 2015- present
PROFESSIONAL EDITORSHIPS
Editorial Board, Frontiers in the Psychotherapy of Trauma and Dissociation, 2017-present
Associate Editor for Clinical Issues, Journal of Trauma and Dissociation,, 2004-present
Editorial Board, Psychological Trauma: Theory, Research, Practice, Policy, 2009-present
Editorial Board, Psychotherapy: Theory, Research, Practice, Training, 2003-2014.
Editorial Board, Psychology, Public Policy and the Law, 2001-2008.
Editorial Board, Journal of Clinical Psychology, 2002-2016.
Editorial Board, Ethics and Behavior, 1995-present.
Consulting Editor, Journal of Traumatic Stress, 1990-1996
Editor, Sage Series on Counseling Women, 1994-1998
Editorial Board, Cultural Diversity and Ethnic Minority Psychology, 1994-2003
Book Review Editor and Editorial Board Member, Women and Therapy, 1989-1994
Consulting Editor, Professional Psychology, 1987-1994. Editorial reviewer, 1995-present
Consulting editor, Psychology of Women Quarterly, 1980-1988. Editorial reviewer, 1988-present
Editorial Board, Counseling and Values, 1983-1987.
Consulting Editor, Journal of Lesbian and Gay Psychotherapy, 1987-1991.
Guest reviewer, Violence and Victims, Sex Roles, Psychological Reports, Journal of Interpersonal Violence, American
Psychologist, Feminism and Psychology.

1

PAST POSITIONS
Director and Founder, Fremont Community Therapy Project, 2006-2015
Clinical Assistant Professor, Smith College School for Social Work, 2011-12
Adjunct Professor of Clinical Psychology, Washington School of Professional Psychology, 2006-2009
Professor of psychology, Washington School of Professional Psychology, 2001-2006
Consulting Psychologist, Survivor II: The Australian Outback, 2000.
Clinical Professor of psychology, University of Washington, Seattle, WA, 1980-1997
Host, Dr. Laura Brown Show, KVI Radio, Seattle, WA 1981-1982
Acting assistant professor of psychology, University of Washington, Seattle, WA, 1978-1980
Assistant professor of psychology, Southern Illinois University at Carbondale, 1977-1978.
Psychology Intern, Veteran's Administration Medical Center, Seattle, WA 1976- 1977.
Teaching and research assistant, Dept. of Psychology, Southern Illinois University at Carbondale, 1973-1976.
HONORS
o USPHS Predoctoral Fellow, 1973-1976
o Fellow, American Psychological Association, Divisions 9, 12, 29, 35, 42, 43, 44, 45, 56
o Fellow, Association for Psychological Science
o Fellow, Western Psychological Association
o Fellow, International Society for the Study of Traumla and Dis sociation
o Distinguished Publication Award, Association for Women in Psychology, 1987, 1995.
o Distinguished Contributions Award, American Psychological Association Committee on Lesbian and Gay
Concerns, 1989.
o Distinguished Psychologist Award, Washington State Psychological Association, 1989
o Distinguished Professional Contributions Award, APA Division 44, 1990
o Leadership Citation, American Psychological Association Committee on Women in Psychology, 1990
o Invited Participant, American Psychological Association Second Century Assembly
o Cleveland Heights-University Heights High School Alumni Hall of Fame, 1995.
o American Psychological Association Award for Distinguished Professional Contributions to Public Service,
1995.
o International Society for Traumatic Stress Studies Sarah Haley Memorial Award for Clinical Excellence, 1997
o Distinguished Practitioner, National Academy of Pracice in Psychology, Elected 1998
o Heritage Award for Practice, Division of Psychology of Women of the APA, 1998
o Visiting Fellow, British Psychological Society, 2001
o Raymond Fowler Award for Promotion of Student Professional Development, American Psychological
Association of Graduate Students, 2003
o Distinguished Contributions Award, Society for the Psychology of Women Section on Lesbian and Bisexual
Women’s Issues, 2004
o Carolyn Wood Sherif Memorial Award, Society for the Psychology of Women, 2004.
o Psychotherapy With Women Award, Society for the Psychology of Women, 2008.
o Lifetime Award for Distinguished Contributions to Diversity in Practice, Society for Clinical Psychology,
2009.
o Distinguished Psychologist Award, Washington State Psychological Association, 2009
o Presidential Citation, American Psychological Association, 2011
o Outstanding Mentor Award, Division of Psychologists in Independent Practice, 2012
o Elizabeth Hurlock Beckman Award, 2012
o Award for Distinguished Contributions to Teaching and Mentoring, APA Division of Psychotherapy, 2013
o Carolyn Attneave Diversity Award, Society for Family Psychology, 2013
o Washington State Psychological Association Social Issues Award, 2014.
o Lifetime Achievement Award, Division of Trauma Psychology of the APA, 2015.
o Society for Counseling Psychology Section for the Advancement of Women Foremother of the Year, 2018.
PUBLICATIONS: Books
Brown, L.S. (2018). Feminist therapy (2nd Edition). Washington DC: American Psychological Association.

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Brown, L.S. (2016). Not the price of admission: Healthy relationships after childhood trauma. Seattle WA:
Createspace.
Brown, L. S. (2016). Essentials of the feminist psychotherapy model of psychotherapy supervision. Washington DC:
American Psychological Association.
Brown, L.S. (2012) Your turn for care: Surviving the aging and death of the adults who harmed you. Seattle WA:
Createspace.
Brown, L.S. (2009). Feminist therapy. Washington DC: American Psychological Association.
Brown, L.S. (2008) Cultural competence in trauma therapy: Beyond the flashback. Washington DC: American
Psychological Association.
Quina, K. & Brown, L.S (Eds.) (2007). Trauma and dissociation in convicted offenders: Issues of gender, science, and
treatment. New York: The Haworth Press.
Brown, L.S. (Ed.) (2006). Relational perspectives on trauma treatment. New York: The Haworth Press.
Ballou, M & Brown, L.S. (Eds.) (2002). Rethinking Mental Health and Disorder: Feminist Perspectives. New York:
Guilford.
Pope.,K.S. & Brown, L.S. (1996). Recovered memories of abuse: Assessment, therapy, forensics. Washington DC:
American Psychological Association
Brown, L.S. (1994). Subversive dialogues: Theory in feminist therapy. New York: Basic Books.
Brown, L.S. and Ballou, M. (Eds) (1992). Personality and psychopathology: Feminist reappraisals. New York:
Guilford Publications.
Brown, L.S. and Root, M.P.P. (Eds.) (1990). Diversity and complexity in feminist therapy. New York: The Haworth
Press.
Brown, L.S. and Rothblum, E.D. (Eds) (1989) Overcoming fat oppression. New York: The Haworth Press.
PUBLICATIONS: GUIDELINES
American Psychological Association, Guideline Development Panel for the Treatment of PTSD in Adults (2017
February). Clinical practice guideline for the treatment of Posttraumatic Stress Disorder (PTSD) in adults.
Retrieved from:http://www.apa.org/about/offices/directorates/guidelines/ptsd.pdf. Member of Guidelines Panel
PUBLICATIONS: Articles and Chapters in Professional Journals or Books
Brown, L. S. (in press). Root, Maria Primitiva Paz. In B. J. Carducci (Editor-in-Chief) & J. S. Mio & R. E. Riggio (Vol.
Eds.), The Wiley-Blackwell encyclopedia of personality and individual differences: Vol. IV. Clinical, applied,
and cross-cultural research. Hoboken, NJ: John Wiley & Sons.
Ellis, A., Simiola, V., Brown, L.S., Courtois, C.A. & Cook, J. M. (2018). Effect of evidence-based treatment
relationships on treatment outcome for adults with trauma: A systematic review. Journal of Trauma and
Dissociation, 19, pp. 185-213.
Brown, L.S. (2017). Feminist therapy. In K. Nadal (Ed.). The SAGE encyclopedia of psychology and gender (pp. 565569). Thousand Oaks CA: SAGE Publications.

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Brown, L. S. (2017). Feminist and multicultural perspectives in trauma psychology. In S. Gold, C. Dalenberg & J. Cook
(Eds). APA handbook of trauma psychology (pp. 501-526). Washington DC: American Psychological
Association.
Comas-Diaz, L. & Brown, L.S. (2016). Multicultural theories. In J. Norcross (Ed). APA handbook of clinical
psychology (pp. 241-273). Washington DC: American Psychological Association.
Brown, L.S. (2014). First do no harm: Is it any longer safe to write case reports? Journal of Interpersonal Violence, 29,
1-7.
Brown, L.S. (2014). Looking outside the (voice) box. Journal of Lesbian Studies, 18, 43-49.
Brown, L.S. (2013). Feminist therapy process. In G. Vandenbos, E. Meidenbauer & J. Frank-McNeil (Eds).
Psychotherapy theories and techniques: A reader (pp. 181-186). Washington DC: American Psychological
Association.
Brown, L.S. (2013). Feminist therapy. In G. Vandenbos, E. Meidenbauer & J. Frank-McNeil (Eds). Psychotherapy
theories and techniques: A reader (pp. 173-180). Washington DC: American Psychological Association.
Brown, L.S.(2013). Treating women in psychotherapy. In G. Koocher, J.C. Norcross, and B. Greene (Eds).
Psychologists’ Desk Reference (Third Ed).(pp. 229-233). New York NY: Oxford University Press.
Brown, L.S.(2013). Treating the effects of psychological trauma. In G. Koocher, J.C. Norcross, and B. Greene (Eds).
Psychologists’ Desk Reference (Third Ed).(pp. 289-293). New York NY: Oxford University Press.
Brown, L. S. (2012). On not quitting my day job. In M. Hoyt (Ed). Therapist stories of inspiration, passion and
renewal: What’s love got to do with it? (pp. 36-45). New York NY: Routledge.
Brown, L. S. (2012). Compassion amidst oppression: Increasing cultural competence for managing difficult dialogues
in therapy. In M. Goldfried, A. Wolf & J.C. Muran (Eds). Transforming negative reactions to clients: From
frustration to compassion (pp. 139-158). Washington DC: American Psychological Association.
Brown, L.S. (2012). Feminist therapy as a path to friendship with women. In L. Comas-Diaz and M. Bakur Weiner
(Eds). Women psychotherapists: Journeys in healing. (pp). New York NY: Jason Aaronson.
DePrince, A.P, Brown, L.S., Cheit, R.E., Freyd, J.J., Gold, S.N., Pezdek, K. & Quina, K. (2012). Motivated forgetting
and misremembering: Perspectives from Betrayal Trauma Theory. In Belli, R. F. (Ed.), True and False
Recovered Memories: Toward a Reconciliation of the Debate (Nebraska Symposium on Motivation 58) (pp
193-243). New York: Springer.
Brown, L.S. (2011). A look back at “New Voices, New Visions:” The view from here. Psychology of Women
Quarterly, 35, 671-75.
Brown, L.S. (2011). Guidelines for Treating Dissociative Identity Disorder in Adults, Third Revision: A tour de force
for the dissociation field. Journal of Trauma and Dissociation.
Brown, L.S. & Pantalone, D. (2011). Lesbian, gay, bisexual, and transgender issues in trauma psychology: A topic
comes out of the closet. Traumatology, 17 1-3.
Brown, L.S. (2011). Everyone I know knows everyone I know: Boundary overlap in the life of one lesbian
psychotherapist. In. G.A. Koocher & W. B. Johnson (Eds.) Ethical conundrums, quandaries and
predicatments in mental health practice: A casebook from the files of experts (pp 17-24). New York NY:
Oxford University Press.

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Brown, L.S. (2010). Working with diverse clients in psychotherapy. In J.C. Norcross, G. Vandenbos & D. Freedheim
(Eds.). History of psychotherapy: Continuity and change (Second Ed) pp. 475-484. New York NY: Oxford
University Press.
Brown, L.S. (2010). The Jewish non-sheep as lesbian feminist therapist. In B.Greene & D. Brodbar (Eds.). A minyan of
women: Family dynamics, Jewish identity and psychotherapy practice (pp. 183-188). London: Routledge.
Brown, L.S. (2010). Women’s experiences of depression: Visible clearly only through the feminist lens. In D. C. Jack
& A. Ali (Eds.), Cultural perspectives on women’s depression: Self-silencing, psychological distress and
recovery(pp. 333-342). New York: Oxford University Press.
Brown, L.S. (2009). Cultural competence: A new way of looking at integration in psychotherapy. Journal of
Psychotherapy Integration, 19, 340-353
Brown, L. S. (2009). True drama or true trauma? Forensic trauma assessment and the challenge of detecting
malingering. In P. F. Dell & J. A. O’Neil (Eds.), Dissociation and the dissociative disorders: DSM-V and
beyond (pp. 585-594). New York: Routledge.
Brown, L.S. (2009). Cultural competence in the treatment of complex trauma. In C. Courtois & J. Ford (Eds.) Treating
complex traumatic stress disorders: An evidence-based guide. New York NY: Guilford Press.
Brown, L.S. (2008). Commentary on the major contribution. The Counseling Psychologist, 36, 639 - 644.
Brown, L.S. & Freyd, J. J. (2008). PTSD Criterion A and betrayal trauma: A modest proposal for a new look at what
constitutes a danger to self. Trauma Psychology Newsletter, 3(1), pp. 11-15.
Brown, L.S. (2008). Feminist therapy. In J.L Lebow (Ed.) Twenty-First Century Psychotherapies (pp. 277-308).
Hoboken, NJ: John Wiley and Sons.
Brown, L.S. & Bryan, T.C. (2007). Feminist therapy and self-inflicted violence. Journal of Clinical Psychology: In
Session, 63, 1121-1133.
Brown, L.S. (2007). Empathy, genuineness—and the dynamics of power: A feminist responds to Rogers.
Psychotherapy: Theory, Research, Practice, Training, 44, 257-259.
Brown, L.S. (2007). Feminist therapy as a meaning-making practice: Where there is no power, where is the meaning?
In. K. Schneider, (Ed.) Existential-integrative psychotherapy: Guideposts to the core of practice. (pp. 130140). New York: Routledge.
Cole, K, Sarlund-Heinrich, P., & Brown, L.S. (2007). Developing and assessing effectiveness of a time-limited therapy
group for incarcerated women survivors of childhood sexual abuse. Journal of Trauma and Dissociation.
Zimberoff, A. K & Brown, L.S. (2006). Book review: “Only the goyim beat their wives, right?” Psychology of Women
Quarterly, 30(4), 422-424.
Brown, L.S. (2006) Still subversive after all these years: The relevance of feminist therapy in the age of evidence-based
practice. Psychology of Women Quarterly, 30, 15-24.
Brown, L.S., Riepe, L.E. & Coffey, R.L. (2005). Beyond color and culture: Feminist contributions to paradigms of
human difference. In M. Hill and M. Ballou (Eds.) The foundation and future of feminist therapy. New York:
Haworth.
Brown, L.S. (2005). Don’t be a sheep: How this eldest daughter became a feminist therapist. In Session/Journal of
Clinical Psychology, 8 949-964.

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Brown, L.S. (2005). The neglect of lesbian, gay, bisexual and transgendered clients. In J.C. Norcross, L. Beutler & R
Levant (Eds.) Evidence-based practice in mental health (pp. 346-352). Washington DC: APA Books.
Brown, L.S. (2005). Outwit, out-last, out-flirt? The women of reality tv. In E.Cole and J.H. Daniel (Eds.). Featuring
females: Feminist analyses of media (pp. 71-84). Washington DC: American Psychological Association.
Brown, L.S. (2005). Feminist therapy with psychotherapists. In J. Geller, R Orlinsky & J. Norcross (Eds). The
psychotherapist’s own psychotherapy: Patient and clinician perspectives. (pp. 265-581) New York: Oxford
University Press.
Brown, L.S. (2004). Feminist paradigms of trauma treatment. Psychotherapy: Theory Research Practice Training, 41
464-471.
Brown, L.S. (2004) Recovering from therapy abuse. In J. Kottler & J. Carlson, (Eds.) Their finest house: Master
therapists share their greatest success stories. Boston: Allyn & Bacon.
Brown, L.S. & Mueller, F. A. (2004). Guidelines for psychotherapy with women. . In G.P. Koocher, J.C. Norcross, and
S.S. Hill (Eds.) Psychologists’ Desk Reference, Second Edition. New York: Oxford University Press.
Mueller, F. A. & Brown, L.S. (2004). Essential readings on psychotherapy with women: A resource list. In G.P.
Koocher, J.C. Norcross, and S.S. Hill (Eds. ) CD-ROM Supplement to the Psychologists' Desk Reference.
New York: Oxford University Press.
Brown, L.S. (2004). Memories of childhood abuse: Recovered, discovered, and otherwise. In B.J. Cling (Ed).
Sexualized violence against women and children: A psychology and law perspective. (pp. 188-212). New
York: Guilford.
Brown, L.S. (2004 ). Lesbian and gay headed families: What are the legal issues? Family Law Briefs.
Brown, L.S. (2003). Not that crazy. Ethics and Behavior, 13. 405-407.
Brown, L.S. (2003). Sexuality, Lies, and Loss: Lesbian, Gay, and Bisexual Perspectives on Trauma. Journal of Trauma
Practice,2, pp. 55-68.
Brown, L.S. (2003). Women and trauma. In J.H. Daniels, A. Banks & L. Slater (Eds). The women’s handbook of
mental health. Boston: Beacon Press.
Brown, L.S. (2003). The three-year-old who was an alcoholic. In J.A. Kottler & J. Carlson, (Eds.) The mummy at the
dining room table: Eminent therapists reveal their most unusual cases. New York: Wiley.
Brown, L.S. (2003). “Relationships more enduring”: Implications of the Troxel decision for lesbian and gay families.
Family Court Review, 41, pp. 60-66.
Brown, L.S. (2002). The argument against prescribing. In M.T. Sammons, R.U. Paige & R.F. Levant (Eds).
Prescriptive authority for psychologists: A history and guide. Washington DC: American Psychological
Association.
Brown, L.S. (2002). Feminist therapy and EMDR: A theory meets a practice. In F. Shapiro (Ed.).EMDR as an
integrative psychotherapy approach: Experts of diverse orientations explore the paradigm prism (pp. 263288). Washington DC: American Psychological Association.
Schneider, M. S., Brown, L.S. & Glassgold, J. (2002). Implementing the resolution on appropriate therapeutic
responses to sexual orientation: A guide for the perplexed. Professional Psychology: Research and Practice.
Pp. 265-274.

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Brown, L.S. (2002). Delayed recall of trauma. In T. Patterson (Ed.) Comprehensive handbook of psychotherapy:
Cognitive/Behavioral approaches. (pp. 73-90) New York: Wiley.
Brown, L.S. (2002). The recovered memory debate: Where do we stand now? In J. Zeig (Ed) Brief therapy: Lasting
impressions. Phoenix AZ: Milton Erickson Foundation.
Brown, L. S. (2001). Feelings in context: Countertransference and the real world in feminist therapy. In
Session/Journal of Clinical Psychology, 57, 1005-1012.
Brown, L.S. (2000). Feminist therapy. In C.R. Snyder and R. Ingram (Eds). Handbook of psychological change:
Psychotherapy process and practices for the 21st Century. New York: Wiley and Sons.
Brown, L.S. (2000). Discomforts of the powerless: Feminist constructions of distress. In J. D. Raskin & R.A. Neimeyer
(Eds.) Constructions of disorder. (pp. 297-308) Washington DC: American Psychological Association.
Brown, L.S. (2000). The controversy over delayed recall for trauma: Historical, scientific and political issues. In A.
Shalev, R. Yehuda, and A. C. McFarlane (Eds). International handbook of human response to trauma. (pp.
195-210).New York: Plenum.
Brown, L.S. (1999). Feminist Ethical Considerations in Forensic Practice. In M. Brabeck (Ed.) Practicing feminist
ethics in psychology (pp. 75-100) Washington DC: American Psychological Association.
Brown, L.S. (1999). Dangerousness, impotence, silence and invisiblity: Heterosexism in the construction of women’s
sexuality. In C. B. Travis & J. W. White (Eds.) Sexuality, society, and feminism (pp. 273-298). Washington
DC: American Psychological Association.
Brown, L.S. (1999). Psychological evaluations in white collar crime cases: Trauma, dissociation and gender. In
Psychological Expert Testimony and Criminal Justice. Washington DC: American Psychological Association.
Alpert, J.L., Brown, L.S. & Courtois, C. (1999). Nonissues, real issues and bias: Comments on C. Brooks Brenneis’
Commentary. Psychoanalytic Psychology, 16, 94-102
Gold, S.N. & Brown, L.S. (1999). Assessing survivors of sexual abuse. In Adult Survivors of Sexual Abuse. In R.T.
Ammerman & M. Hersen, (Eds.). Assessment of family violence: A clinical and legal sourcebook (2nd
Edition). (pp. 390-412). New York: Wiley.
Brown, L.S. (1999). Reclaiming the sacred in psychotherapy. Voices: The art and science of psychotherapy, 35, 7-18.
Brown, L.S. (1999). All you need is a little respect: What makes feminist therapy effective. Psychotherapy Bulletin, 34,
22-27.
Brown, L.S. (1999). Review of Trauma and memory: Clinical and legal controversies. Psychiatric Services, 50, 119120.
Brown, L.S. (1998). The prices of resisting silence. Ethics and Behavior, 8., 189-193.
Brown, L.S. (1998). Sacred space or sacred cows, Or, it’s never fun being prophetic. American Psychologist , 53. 488490.
Brown, L.S. (1998). Psychotherapy With Clients Recovering Memories of Childhood Trauma. In G. P. Koocher, J.C.
Norcross, & S.S. Hill III (Eds.) The psychologist’s desk reference. Cambridge MA: Oxford University Press.
Brown, L.S. (1997). Recovered memories of abuse: Research and clinical update. Clinician’s Research Digest,
Supplemental Bulletin #17.

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Brabeck, M. & Brown, L.S. (1997). Feminist theory and psychological practice. In J. Worell & N. Johnson, (Eds.)
Shaping the future of feminist psychology: Education, research and practice. (pp. 15-36) Washington DC:
American Psychological Association.
Gold, S.N. & Brown, L.S. (1997) . Therapeutic responses to delayed recall: Beyond recovered memory.
Psychotherapy: Theory, Research, Practice, Training, 32 182-191.
Brown, L.S. (1997). Review of Women, madness and medicine. Contemporary Psychology, 42, 608-609.
Brown, L.S. (1997). Remediation, amends or denial? Professional Psychology: Research and Practice, 28.
297-299.
Brown, L.S. (1997). The private practice of subversion: Psychology as tikkun olam. American Psychologist, 52, 449462.
Brown, L.S. & Burman, E. (1997). Why feminists should be concerned with the memory debate. Feminism and
Psychology,7. pp 7-16
Brown, L.S. (1997). Ethics in psychology: Cui bono? In D. Fox & I. Prilleltensky (Eds.) The handbook of critical
psychology. (pp. 51-67). Thousand Oaks: Sage Publications
Brown, L.S. (1996). Politics of incest, politics of memory: Therapy as if politics mattered. Women and Therapy,19, 518.
Brown, L.S. (1996). Preventing heterosexism and bias in psychotherapy. In E.D. Rothblum & L.A. Bond (Eds.)
Preventing heterosexism and homophobia. (pp. 36-58). Thousand Oaks: Sage Publications
Alpert, J. L., Brown, L.S. & Courtois, C. A. (1996). Symptomatic clients and memories of childhood abuse: What the
trauma and child sexual abuse literature tells us. In J. L. Alpert, L.S. Brown, S.J. Ceci, C. A. Courtois, E.F.
Loftus & P. Ornstein, Final report of the Working Group on investigation of memories of childhood abuse.
Washington DC: American Psychological Association.
Brown, L.S. (1996). On the construction of truth and falsity: Whose memory, whose history. In K. Pezdek & W. Banks
(Eds.) The recovered memory/false memory debate. (pp. 341-354) New York: Academic Press.
Brown, L..S. (1996). Ethical issues in mental health treatment of sexual minority patients. In T. Stein and R. Cabaj
(eds.). Textbook of homosexuality and mental health. Washington DC: American Psychiatric Press.
Brown, L.S. (1995).Notes of a feminist therapy “foredaughter.” Women and Therapy, 17. pp. 87-96.
Brown, L.S. (1995). Your therapy client as plaintiff: Clinical and legal issues for the treating therapist. In J.L. Alpert
(Ed).Sexual abuse recalled: Treating trauma in the era of the recovered memory debate. (pp. 337-362)
Northvale NJ: Jason Aronson
Brown, L.S. (1995). Cultural diversity and feminist therapy: Theory and practice. In H. Landrine (Ed.) Bringing
cultural diversity to feminist psychology. (pp 143-162). Washington DC: American Psychological Association.
Brown, L.S. (1995). Working with same-sex couples: An introduction. In. N.S. Jacobson and A Gurman (Eds), Clinical
handbook of couples therapy, Second Edition. New York: Guilford.
Brown, L.S. (1995). Not outside the range: One feminist perspective on psychic trauma, II. In. C. Caruth (Ed.) Trauma:
Explorations in memory. Baltimore: Johns Hopkins University Press.
Brown, L.S. (1995). Antiracism as an ethical norm in feminist therapy. In J. Adelman and G. Enguidanos (Eds) Racism
in the lives of women. New York: Haworth Press, pp 137-148.

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Brown, L.S. (1995). Lesbian identities: Concepts and issues. In a. D’Augelli & C. Patterson (Eds.) Lesbian, gay and
bisexual identities over the lifespan. (pp. 3-23) New York: Oxford University Press .
Brown, L.S. (1995). Toward not forgetting: The science and politics of memory. The Counseling Psychologist,23. 31014.
Brown, L.S. (1994). Memory and psychotherapy: A commentary. Consciouness and Cognition ,4.
Brown, L. S. (1994.) Concrete boundaries and the problem of literal-mindedness. Ethics and Behavior,4.
Brown, L.S. (1994). Boundaries in feminist therapy: A theoretical formulation. Women and Therapy, 13, 29-36.
Brown, L.S. (1993). The Boston Marriage in the therapy office. In E.D. Rothblum and K.Brehony (Eds). The Boston
Marriage today. Amherst: U. of Massachusetts Press.
Brown, L.S. (1993). Anti-domination training as a central component of diversity in clinical psychology education. The
Clinical Psychologist, 46, pp. 83-87.
Brown, L.S. (1992). Until the revolution comes: Towards a lesbian feminist psychotherapy. Feminism and Psychology,
2, 239-254.
Brown, L.S. (1992). Psychological assessment in cases of sexual harassment. In Proceedings of the Sex and Power in
the Workplace Conference. Seattle WA: Author.
Brown, L.S. & Brodsky,A.M. (1992) The future of feminist therapy. Psychotherapy: Theory, Research, Practice,
Training,29,pp.51-57
Brown, L.S. (1992) A feminist critique of the personality disorders. Chapter in L. S.Brown & M. Ballou (Eds.)
Theories of personality and psychopathology: Feminist reappraisals (pp. 206-228). New York: Guilford
Publications.
Brown, L.S. (1991). The meaning of a multicultural perspective in the development of psychotherapy theories.
Systeemteoretisch Bulletin 9, 230- 251.
Brown, L.S. (1991). Multicultural theories: Perspectives for practice. Systeemteoretich Bulletin, 9, 252-268.
Brown, L.S. (1991) Ethical issues in feminist therapy: Selected topics. Psychology of Women Quarterly, 15, p. 323-336.
Brown, L.S. (1991). Comment on the Delusional Dominating Personality Disorder diagnosis. Canadian Psychology,
32.
Brown, L.S. (1991) Not outside the range: One feminist perspective on psychic trauma. American Imago, 48, 119-133.
Brown, L.S. (1991) Anti-racism as an ethical imperative: An example from feminist therapy. Ethics and Behavior, 1,
113-127.
Morgan, K.S. & Brown, L.S. (1991) Lesbian career development, work behavior and vocational counseling. The
Counseling Psychologist, 19, 273-291.
Brown, L.S. (1991). Commentary on the special issue. The Counseling Psychology, 19, 235-238.
Brown, L.S. (1991). Plus ca change, or, who writes the scripts for these guys anyways. Feminism and Psychology, 1,
89-92.
Brown, L.S. (1991). Therapy with an infertile lesbian client. Chapter in C. Silverstein (Ed.) Gays, lesbians, and their
therapists: Studies in psychotherapy. (pp,15-30) New York: W.W. Norton.

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Brown, L.S. (1991) How is this feminist different from all other feminists? From Pirke Avot to the feminist therapy
ethics code. Women and Therapy,10, 14- 22.
Brown, L.S. (1990) Victimization as a risk factor for depression in women Proceedings of the Task Force on Women
and Depression. Washington DC: American Psychological Association.
Brown, L.S. (1990) What women therapists have in common. Chapter in D. Cantor (Ed.) Women as therapists: A multitheoretical casebook. New York: Springer Publishing Co.
Brown, L.S. (1990) Structuring the business of feminist therapy responsibly. Chapter in H. Lerman and N. Porter (Eds.)
Feminist ethics in psychotherapy. New York: Springer Publishing Company.
Brown, L.S. (1990) Confronting ethically problematic behaviors in feminist therapist colleagues. Chapter in H. Lerman
and N. Porter (Eds). Feminist ethics in psychotherapy. New York: Springer Publishing Company.
Brown, L.S. (1990) Feminist therapy and psychodiagnosis: Beyond DSM and ICD. Proceedings of the First
International Congress of Mental Health Care for Women. Amsterdam, The Netherlands: Stichting De Maan.
Brown, L.S. (1990) The meaning of a multicultural perspective for theory development in feminist therapy. In
Brown,L.S. and Root, M.P.P. (Eds) Diversity and complexity in feminist therapy. New York: The Haworth
Press.
Brown, L.S. and Walker, L.E.A. (1990) Feminist therapy perspectives on self- disclosure. Chapter in G. Stricker and
M. Fisher (Eds.) Self-disclosure in the therapeutic relationship.( pp. 135-156). New York: Plenum.
Brown, L.S. (1990) Listening to the inner soundtrack: A therapist's personal journey. Imagination, Cognition, and
Personality, 9, pp. 131-139.
Brown, L.S. (1990) Taking account of gender in the clinical assessment interview. Professional Psychology: Research
and Practice, 21, 12-17.
Brown, L.S. (1989) New voices, new visions: Toward a lesbian/gay paradigm for psychology. Psychology of Women
Quarterly, 13, pp. 445-458. Reprinted in M. Gergen & S. Davis (Eds.) Toward a new psychology of gender: A
reader. New York: Routledge. Reprinted in B. M. Clinchy & J.K. Norem (Eds.) The gender and psychology
reader. New York: NYU Press.
Gonsiorek, J.C. and Brown, L.S. (1989) Post therapy sexual relationships with clients. In G. Schoener et al (Eds).
Psychotherapists' sexual involvement with clients: Intervention and prevention. Minneapolis: Walk-In
Counseling Center.
Brown, L.S. (1989) Fat oppression and feminist therapy. Women and Therapy, 8, pp. 19-30.
Brown, L. S. (1989). Ask the board: Case consultation on a lesbian couple. Journal of Gay and Lesbian Psychotherapy,
1.
Brown, L.S. (1989). Commentary on "Impact of contemporary ideology and AIDS upon the counseling of gay clients."
Counseling and Values, 33, pp. 132-134.
Brown, L.S. (1988) Beyond thou shalt not: thinking about ethics in the lesbian therapy community. Women and
Therapy, 8, pp. 13-26.
Brown, L.S., Dewolfe, D., and Larson, E.R. (1988). Sex therapy and education with lesbian and bisexual women: A
model for intervention. Chapter in C. Gelauff (Ed). Lust, last, keuze: Denken over lesbisch bestaan.
Perspectieven voor vrouwenhelpverlening. (PP. 74-99). Amsterdam: Schorer/An Dekker.

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Brown, L.S. (1988) Lesbians, gay men and their families: Common clinical issues. Journal of Gay and Lesbian
Psychotherapy, 1.
Brown, L.S. (1988) Feminist therapies with lesbians and gay men. Chapter in M.A. Douglas and L.E. A. Walker
(Eds) Feminist Therapies: Integration of Feminist and Therapeutic Systems. Norwood NJ: Ablex Publishing.
Brown, L.S. (1988). Lesbians and family. National Women's Studies Association Journal, 1, pp. 109-114.
Brown, L.S. (1988) Harmful effects of post-termination romantic and sexual relationships between therapists and their
former clients. Psychotherapy: Theory, Research, Practice, Training. 25, pp. 249-255.
Brown, L.S. (1987) The potential for misdiagnosis in the DSM-III-R. Psychiatric Times, 4, pp. 1, 27-28.
Brown, L.S. (1987) Lesbians, weight, and eating: New analysis and perspectives. In Boston Lesbian Psychologies
Collective (Eds) Lesbian Psychologies. Chicago: University of Illinois Press. Reprinted as: Lesben, Gewicht
und Essen, in J .Loulan, M. Nichols, & M. Streit, (Eds), Lesben, leibe, leidenschaft. Berlin: OrlandaFrauenverlag.
Brown, L.S. (1986) Gender role analysis: A neglected issue in assessment and diagnosis. Psychotherapy: Theory,
Research, Practice, Training, 23 pp. 243-248.
Brown, L.S. (1986) Review of Women therapists working with women: New theory and process of feminist therapy.
Psychotherapy: Theory, Research, Practice, Training, 23, pp. 326-327.
Brown, L. S. (1986) From alienation to connection: Feminist therapy with Post-traumatic stress disorder. Women and
Therapy. 5, pp. 13-26.
Brown, L.S. (1986) Confronting internalized homophobia in sex therapy with lesbians. Journal of Homosexuality, 12 ,
pp. 99-108.
Brown, L.S. and Zimmer, D. (1986) An introduction to therapy issues with lesbian and gay male couples. In N.
Jacobson and A. Gurman (Eds) The Clinical Handbook of Marital Therapy, New York: Guilford Press.
Brown, L. S. (1985) Power, responsibility, boundaries: Ethical issues for the lesbian-feminist therapist. Lesbian Ethics,
1, pp. 30-45.
Brown, L.S. (1985) Women, weight and power: Feminist theoretical and therapeutic issues. Women and Therapy, 4,
pp. 61-72.
Brown, L.S. (1985) Ethics and business practice in feminist therapy. In L.B.Rosewater and L.E.A.Walker (Eds)
Handbook of Feminist Therapy. New York:Springer Publishing Co.
Brown, L.S. (1984) The lesbian-feminist therapist in private practice and her community. Psychotherapy In Private
Practice, 2, pp. 9-16
Brown, L.S. (1984) Finding new language: Beyond analytic verbal shorthand in feminist therapy. Women and
Therapy, 3, pp. 73-80.
Brown, L.S. (1984) The implications of media psychology for mental health policy. In L.E.A.Walker (Ed) Women and
Mental Health Policy, New York:Sage.
Brown, L.S. (1982) Choosing a therapist. In G. Hongladarom, R. McCorkle, and N.F.Woods (Eds) The Complete
Book of Women's Health. New York: Prentice-Hall, 1982.
Brown, L.S. and Liss-Levinson, N. (1981) Feminist Therapy. In R. Corsini (Ed) The Handbook of Innovative
Psychotherapies. New York:Wiley and Sons.

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Brown, L.S. and Ostrow, F.A. (1979) The development of an assertiveness training program on an alcoholism unit.
International Journal of the Addictions, 15, pp. 323-327.
O'Leary, M.R., Chaney, E, Brown, L.S., and Schuckit, M. (1978. Use of the Goldberg Indices with alcoholics: A
cautionary note. Journal of Consulting and Clinical Psychology.
Brown, L.S. (1978) Do users have more fun: A study of the relationship between contraceptive behavior, sexual
assertiveness and patterns of causal attribution. Dissertation Abstracts International, pp. 5002-5003B.
Rader, G. E., Bekker, L. D, Brown, L. S. & Richardt, C. (1978). Psychological correlates of unwanted pregnancy.
Journal of Abnormal Psychology, 87, 373-376.
Liss-Levinson,N, Coleman, E., and Brown, L.S. (1977) A program of sexual assertiveness training for women. Chapter
in Assertiveness Training. Brooks/Cole Publishing . Also published in The Counseling Psychologist, 1976.
PROFESSIONAL TRAINING VIDEOTAPES
Brown, L.S. (1994). Feminist therapy. American Psychological Association Psychotherapy Videotape Series.
Brown, L. S. (1999) Feminist couples therapy. International Association of Marriage and Family Counseling
Distinguished Presenter Videotape Series.
Brown, L.S. (2005). Treating women survivors of trauma and abuse. American Psychological Association
Psychotherapy Videotape Series
Brown, L.S. (2006) Treating male survivors of trauma and abuse. American Psychological Association Psychotherapy
Videotape Series.
Brown, L.S. (2009). Feminist therapy over time. American Psychological Association Psychotherapy Videotape Series.
Brown, L. S. (2011). Cultural competence in trauma treatment. American Psychological Association Continuing
Education On-Line Video Series.
Brown, L.S. (2016). The feminist approach to therapy supervision. American Psychological Association
Psychotherapy Supervision Videotape Series.
ON-LINE TRAINING COURSES
Brown, L.S. (2015). C ultural competence in trauma treatment. APA On-Line Continuing Education Interactive
Classroom Program, http://apa.bizvision.com/category/interactive-classroom-trauma.
Brown, L.S. (2015). Becoming a Trauma-Aware Therapist: Definitions and Assessment.
http://www.continuingedcourses.net
Brown, L.S. (2015). Treating Trauma: Basic Skills and Specific Treatments. http://www.continuingedcourses.net
PROFESSIONAL PRESENTATIONS
Brown, L.S. (2018, February). Women trauma and psychotherapy: New insights. Invited keynote address at the
conference, Women’s Health and Mental Health, Ben Gurion University of the Negev, Beersheva Israel.
Brown, L.S. (2018, February). Feminist perspectives on the treatment of trauma. Invited workshop, at the conference,
Women’s Health and Mental Health, Ben Gurion University of the Negev, Beersheva Israel.

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Brown, L.S. (2017, October). Cultural competence in trauma practice. Professional development workshop presented
for the Washington State Society for Clinical Social Work, Seattle WA.
Brown, L.S. (2017, August). How can we engender healthy relationships in survivors of complex trauma? Keynote
address, EMDR International Association Conference, Bellevue WA.
Brown, L.S. (2017, April). Panel member in M.B. Donner, (Chair). When referral is not an option. Plenary panel,
California Psychological Association Annual Meeting, San Francisco CA.
Brown, L.S. (2017, April). Feminist therapy supervision. In H. Levenson (Chair), Supervision Revealed: Master
Supervisors of Various Orientations Show/Discuss Their Supervision Session Videos. Symposium presented at
the California Psychological Association Annual Meeting, San Francisco CA.
Brown, L.S. (2017, April). Ethical and cultural competence in treating trauma survivors: Beyond diagnostic
categories. Pre-Meeting Institute presented at the California Psychological Association Annual Meeting, San
Francisco CA.
Brown, L.S. (2016, September). Cultural competence in the 21st Century. Invited Keynote Address, Tennessee
Association of Mental Health Organizations Annual Conference, Nashville TN.
Brown, L. S. (2016, August). How can I care for the person who harmed me? Abuse survivors as filial caregivers. In C.
Goodheart (Chair) Trauma and Caregiving: Complicated Situations and Solutions. Symposium presented at
the Annual Convention of the American Psychological Association, Denver CO.
Brown, L. S. (2016, August). Belief, patience, connection: Relationship above and beyond evidence in trauma
treatment in S. Gold (Chair). Beyond do no harm: The relationship in trauma treatment. Symposium
presented at the Annual Convention of the American Psychological Association, Denver CO
Brown, L. S. (2016, August). Participant, in C. Courtois (Chair). Ethics and self-care: Challenges in treating trauma.
Discussion program presented at the Annual Convention of the American Psychological Association, Denver
CO
Brown, L. S. (2016, August). Participant, Establishing a Clinical Practice in Trauma Psychology. Discussion Program
presented at the Annual Convention of the American Psychological Association, Denver CO
Brown, L. S. (2016, August). Participant, in J. Cook (Chair) A past-presidential panel on getting the word out on
trauma. Panel presented at the Annual Convention of the American Psychological Association, Denver CO
Brown, L. S. (2016, August). Discussant, in S. Gold (Chair). Forensic practice with vulnerable populations: The
victim-victimizer-victim cycle. Symposium presented at the Annual Convention of the American Psychological
Association, Denver CO.
Brown, L.S. & Slaughter, S. L (2016, June). What feminist psychotherapy supervision looks like. In H. Levenson & A.
G. Inman, Chairs, Master Supervisors and Their Supervisees Show/Discuss Their APA Supervision Videos.
Invited Pre-conference Workshop, Society for the Exploration of Psychotherapy Integration, Dublin, Ireland.
Brown, L. S. (2016, April). Assessing trauma in the forensic context. Invited address, Division of Independent Practice
Forensic Conference, Pasadena, CA.
Brown, L.S. (2016, March). Cultural competence in trauma treatment. Invited Advanced Workshop, New South Wales
Service for the Treatment and Rehabilition of Torture and Trauma Survivors, Sydney NSW Australia.
Brown, L.S. (2016, March). Complex childhood trauma and relationships: Helping survivors to stop paying the price
of admission. Invited lecture, Queensland Univerity of Technology, Brisbane, QLS Australia.

13

Brown, L.S. (2015, August). Feminist therapy with complex trauma: Accompanying a survivor on her hobbit journey.
In B. Greene (Chair). Frodo and Sam enter Mordor: The feminist therapy alliance in complex trauma.
Symposium presented at the 123rd Annual Convention of the American Psychological Association, Toronto
Ontario Canada.
Brown, L.S. (2015, August). Relational and countertransferential issues in work with complex trauma. In L. Rocchio
(Chair). Ethical and relational issues in complex trauma treatment in independent practice. Symposium
presented at the 123rd Annual Convention of the American Psychological Association, Toronto Ontario
Canada.
Brown, L.S. (2015, August). Discussant. In S. Gold (Chair). A contextual approach to treating dissociation.
Symposium presented at the 123rd Annual Convention of the American Psychological Association, Toronto
Ontario Canada.
Brown, L. S. (2015, January). Therapist self-care as a social justice ethic. In B. Greene (Chair), No easy answers:
Ethics and social justice practice. Symposium presented at the National Multicultural Conference and Summit,
Atlanta GA.
Brown, L.S. (2014, October). The therapist as person, the person as therapist: The interweave between the two in my
development. Invited lecture, Annual Meeting of the Seattle Psychotherapy Cooperative, Seattle WA.
Brown, L.S. (2014, August). Empowerment as an ingredient of effective psychotherapy. In R.K. Goodyear (Chair),
How does psychotherapy work?Looking to theory and evidence to identify change mechanisms. Symposium
presented at the 122nd Annual Convention of the American Psychological Association, Washington DC
Brown, L.S. (2014, August). On not quitting the day job. In M. Hoyt, Chair, Psychotherapist tales of inspiration,
passion and renewal. Symposium presented at the 122nd Annual Convention of the American Psychological
Association, Washington DC
Brown, L.S. (2014, August). What empowerment looks like. In J. Magnavita (Chair), Psychotherapy revealed: A
glimpse of eminent psychotherapists in session. Symposium presented at the 122nd Annual Convention of the
American Psychological Association, Washington DC
Brown, L.S., Gold, S.N, and Rocchio, L. (2014, August). The basics of forensic trauma practice. Workshop presented
at the 122nd Annual Convention of the American Psychological Association, Washington DC.
Brown, L.S. (2014, April). How to publish: The editor’s perspective. In J. Till (Chair). How to publish. Symposium
presented at the 94th Annual Convention of the Western Psychological Association, Portland OR.
Brown, L.S. (2014, April). With power tools: Lesbian feminists enter marriage. 20th Annual Andrea Carson Coley
Memorial Lecture, Institute for Women’s Studies, University of Georgia, Athens GA.
Brown, L. S. (2014, April). Developing cultural competence: Intersections of therapists’ and clients’ lives. Invited
keynote address, Our Alaska Lives Conference, Anchorage AK.
Brown, L.S. (2014, April). Their turn for care: Supporting clients dealing with the aging and death of abusive elders.
Invited workshop, Our Alaska Lives Conference, Anchorage AK.
Brown, L.S. (2013, November). Their turn for care: Assisting survivors in dealing with the aging and death of family
member perpetrators. Workshop presented at the 20th Annual Conference of the International Society for the
Study of Trauma and Dissociation, Baltimore, MD.
Brown, L.S. & Steele, K. (2013, November). Eek, there’s dissociation in my office! Supervision and consultation with
therapists new to complex trauma and dissociation Workshop presented at the 20th Annual Conference of the
International Society for the Study of Trauma and Dissociation, Baltimore, MD.

14

Golston, J., Brown, L.S., Courtois, C.A. & Kinsler, P. (2013, November). Ethics and trauma, working under pressure:
A relational perspective. Workshop presented at the 20th Annual Conference of the International Society for
the Study of Trauma and Dissociation, Baltimore, MD
Brown, L.S. (2013, August). Breathing in power: Bringing the body back in feminist practice. In B. Greene (Chair),
Embodied paths toward the future of feminist psychology. Symposium presented at the Annual Conference of
the American Psychological Association, Honolulu HI.
Brown, L.S. (2013, August). Feminist therapy: What empowerment looks like. In J. Magnavita, (Chair), Psychotherapy
revealed: A glimpse of eminent psychotherapists at work. Symposium presented at the Annual Conference of
the American Psychological Association, Honolulu HI.
Brown, L.S. (2013, April). Cultural competence in trauma therapy: A social justice perspective. Workshop presented at
the West Coast Children’s Clinic, Oakland CA.
Brown, L.S. (2013, April). Supervisory challenges in trauma work: Boundaries, self-care, and reenactments.
Workshop presented at the West Coast Children’s Clinic, Oakland CA.
Brown, L.S. (2013, February). Twentyfirst Century cultural competence. Cultural competence in trauma treatment.
Workshop presented at the New School for Social Research, New York NY.
Brown, L. S. (2013, February). Cultural competence in trauma treatment. Workshop presented for the Institute for
Contemporary Psychotherapy, New York NY.
Brown, L.S. (2012, October). Cultural competence in trauma treatment. Workshop presented for the Nashville
Psychotherapy Institute, Nashville TN.
Brown, L.S. (2012, October). Increasing cultural competence through mindful self-awareness. Workshop presented to
the Executive Board of the Divison of Psychotherapy of the American Psychological Association, Washington
DC.
Brown, L.S. (2012, September). Vicarious traumatization and self-care. In-service workshop conducted for the staff of
Western State Hospital, Steilacoom WA.
Brown, L.S. (2012, August). Becoming a culturally competent trauma therapist. In J. Cook (Chair). Working with adult
trauma survivors: What every practitioner should know. Continuing Education Workshop presented at the
120th Annual Convention of the American Psychological Association, Orlando FL.
Brown, L.S. (2012, August). Becoming a culturally competent trauma therapist. In J. Cook (Chair). Working with adult
trauma survivors: What every practitioner should know. Continuing Education Workshop presented at the
120th Annual Convention of the American Psychological Association, Orlando FL.
Brown, L.S. (2012, August). Discussant in C. Dalenberg (Chair). Ethics of case studies, Symposium presented at the
120th Annual Convention of the American Psychological Association, Orlando FL.
Brown, L.S. (2012, August). We’re all women or we’re not: Gender and cultural competence. In L. Comas-Diaz
(Chair), Cultural competence in independent practice, Symposium presented at the 120th Annual Convention
of the American Psychological Association, Orlando FL.
Brown, L.S. (2012, August). Feminist supervision: Empowerment all around. In C.E. Watkins (Chair). Seasoned
psychotherapy supervisors’ visions of supervision: Abiding practice convictions. Symposium presented at the
120th Annual Convention of the American Psychological Association, Orlando FL.
Brown, L.S. (2012, July). Cultural competence in trauma treatment: Self-care for the therapist. Workshop presented by
the Fremont Community Therapy Project, Seattle WA.

15

Brown, L.S. (2012, June). Cultural competence in trauma. Trauma Talks Conference, Toronto Ontario Canada.
Brown, L.S. (2012, May). Cultural competence as the integrating variable: Training the next generation of therapists.
Invited keynote address, Society for the Exploration of Psychotherapy Integration, Evanston IL.
Brown, L.S. (2012, February). Ethical and cultural competence in work with trauma survivors. Invited continuing
education workshop, Washington State University, Pullman WA.
Brown, L. S. (2012, April). Swimming in murky ethical waters: Self-care and social justices as guides to safer shores.
Invited continuing education workshop, Georgia Society for Clinical Social Work, Atlanta GA.
Brown, L.S. (2012, February). Ethical and cultural competence in work with trauma survivors. Invited continuing
education workshop, University of North Texas/Texas Women’s University, Denton TX.
Brown, L. S. (2011, September). Feminist perspectives on work with trauma survivors. Invited Continuing Education
Workshop presented at the Mariposa Center, Orange CA.
Brown, L.S. (2011, August). Trauma and myths of masculinities. Invited keynote address, Society for the Psychological
Study of Men and Masculinity, 119th Conference of the American Psychological Association, Washington DC.
Brown, L. S. (2011, August). You will so be empowered: Feminist therapy with a reluctant participant. In J. Magnativa
(Chair). Eminent psychotherapists revealed: Audiovisual presentation of principles of psychotherapy.
Symposium presented at the 119th Conference of the American Psychological Association, Washington DC.
Brown, L. S. (2011, August). Teaching and supervising feminist therapy in the 21st Century. In C. Watkins (Chair),
Teaching and supervising psychotherapies in the 21st Century: Pressing needs, impressing possibilities.
Symposium presented at the 119th Conference of the American Psychological Association, Washington DC.
Brown, L.S. (2011, August). Forensic trauma practice. Continuing Education Workshop sponsored by the Division of
Trauma Psychology, 119th Conference of the American Psychological Association, Washington DC.
Brown, L.S. (2011, August). Cultural competence in trauma practice. Continuing Education Workshop sponsored by
the Division of Trauma Psychology, 119th Conference of the American Psychological Association,
Washington DC.
Brown, L.S. (2011, June). Feminist perspectives on trauma treatment. Invited workshop, Adler Graduate School of
Professional Psychology, Chicago IL.
Brown, L.S. (2011, January). Speaker, A minyan of women, Discussion program presented at the Sixth National
Multicultural Conference and Summit of the APA, Seattle WA.
Brown, L.S. (2011, January). Panel member and discussant, Is multicultural psychology ascientific? Program presented
at the Sixth National Multicultural Conference and Summit of the APA, Seattle WA.
Brown, L.S. (2010, August). Can we create social justice: Toward an ethic of justice for trauma psychology. Division
of Trauma Psychology Presidential Address, presented at the 118th Annual Convention of the American
Psychological Association, San Diego CA.
Brown, L.S. (2010, May). Establishing and rebutting emotional distress damage claims: The forensic mental health
expert’s perspective. Invited speaker, 43rd Annual Pacific Coast Labor and Employment Law Conference,
Seattle WA.
Brown, L.S. (2010, April). Real men don’t get terrified: Working with male survivors of trauma. Invited keynote
address at a conference, Counseling Men in Difficult Times. California State University, Fullerton CA.

16

Brown, L.S. (2010, February. The Fremont Community Therapy Project: Creating our feminist vision. In L.S. Brown
(Chair) Creating a feminist therapy community training clinic. Symposium presented at the Annual
Conference of the Association for Women in Psychology, Portland OR.
Brown, L.S. (2010, February). Preventing vicatious traumatization through supervision. In E. Zurbriggen (Chair).
Vicarious traumatization in the clinic, classroom, and laboratory: Caring for ourselves and each other.
Symposium presented at the Annual Conference of the Association for Women in Psychology, Portland OR.
Brown, L.S. (2009, August). Re-centering margins and marginalizing centers. In B. Greene (Chair). From margins to
center---Feminist psychology discourse and socialjJustice in the Sherif tradition . Symposium presented at the
117th Annual Convention of the American Psychological Association, Toronto Ontario.
Brown, L.S. (2009, August). Assessment and climbing on rocks: Psychologist meets reality TV. In S. Ladani (Chair).
Vive la difference: Lessons from psychologists in unusual careers. Symposium presented at the 117th Annual
Convention of the American Psychological Association, Toronto Ontario.
Brown, L.S. (2009, May). Cultural Competence: A New Way of Thinking about Integration in Therapy. Invited
Keynote Address, Society for the Exploration of Psychology Integration Annual Meeting, Seattle WA.
Brown, L.S. (2009, May). Cultural competence for the 21st Century. Invited Workshop, Society for the Exploration of
Psychology Integration Annual Meeting, Seattle WA.
Brown, L.S. (2009, May). Transferential and countertransferetial issues in work with lesbian and bisexual women
clients. Invited Workshop, Center for Women’s Health Promotion, Ben Gurion University, Beer Sheva Israel.
Brown, L.S. (2009, May). New approaches to working with women and trauma. Invited Address, , Center for Women’s
Health Promotion, Ben Gurion University, Beer Sheva Israel.
Brown, L.S. (2009, May). Feminist therapy theory. Invited Workshop, Center for Women’s Health Promotion, Ben
Gurion University, Beer Sheva Israel.
Brown, L.S. (2009, May). Feminist psychotherapy supervision. Invited Workshop, Center for Women’s Health
Promotion, Ben Gurion University, Beer Sheva Israel
Brown, L.S. (2009, April). Panelist in discussion program, The Great ethics debate:How many “right” solutions can
there be? Convention of the California Psychological Association, Oakland CA.
Brown, L.S. (2008, October). Enhancing cultural competence in psychotherapy. Invited workshop, Pacific University
Graduate School of Professional Psychology, Hillsboro OR.
Brown, L.S. (2008, October). Cultural competence in trauma therapy: Getting beyond the flashback. Invited workshop,
Womencare Counseling Center, Evanston IL.
Brown, L.S. (2007, November). Betrayal trauma and the ethics of diagnosis. In J. Freyd (Chair), Betrayal trauma: The
ethics of diagnosis and treatment. Symposium presented at the Annual Meeting, International Society for
Traumatic Stress Studies, Baltimore MD.
Brown, L. S. (2007, November). Cultural competence in response to multiple identities in the context of trauma. PreMeeting Institute presented at the Annual Meeting, International Society for Traumatic Stress Studies,
Baltimore MD.
Brown, L.S. (2007, October). Developing cultural competence for the 21st Century. Workshop presented for the
Diversity Interest Group, Center for the Study of Women in Society, University of Oregon, Eugene OR.
Brown, L.S. (2007, October). Treating Bajorans: Epistemologies of cultural competence in trauma treatment. Invited
colloquium lecture, Dept. of Psychology University of Oregon, Eugene OR.

17

Brown, L.S. (2007, August). Finding my center: Martial arts on the way to Tikkun Olam. In J.C. Norcross (Chair)
Psychotherapist self-care: Leaving it at the office. Symposium presented at the 115th Annual Convention of the
American Psychological Association, San Francisco CA.
Brown, L. S. (2007, August). Re-centering at the margin: Creating a continuously multicultural feminist therapy. In E.
N Williams (Chair). International perspectives on feminist multicultural psychotherapy: Content and
connection. Symposium presented at the 115th Annual Convention of the American Psychological Association,
San Francisco CA.
Brown, L.S. (2007, August). Discussant. In S. Gold, Chair, Prostitution, trafficking, sexual compulsivity, and trauma.
Symposium presented at the 115th Annual Convention of the American Psychological Association, San
Francisco CA.
Ford, L.N., Brown, L.S., Kerr, D. M, and Schwartz, L. (2007, August). Qualitative study of previously infertile mothers
and their experiences. Poster presented at the 115th Annual Convention of the American Psychological
Association, San Francisco CA.
Brown, L.S. (2007, March). Feminist therapy paradigms for working with complex trauma. Workshop presented at the
Annual Conference of the Association for Women in Psychology, San Francisco CA.
Brown, L.S. (2006, December). More Than A Flashback: Existential and Multicultural Issues in Trauma Treatment.
Invited Keynote Address, Annual Conference of the British Columbia Association of Specialized Victim
Assistance and Counseling Programs. Vancouver BC Canada.
Brown, L.S. (2006, December). Which self am I for: Intersecting identities in feminist trauma practice. Invited
workshop Annual Conference of the British Columbia Association of Specialized Victim Assistance and
Counseling Programs. Vancouver BC Canada
Brown, L.S. (2006, November). Culturally competent trauma practice. Invited workshop, Convention of the Minnesota
Counseling Association, St. Cloud MN.
Brown, L.S. (2006, November). Is it a girl? The importance of gender in psychotherapy. Keynote workshop,
Convention of the Minnesota Counseling Association, St. Cloud MN.
Brown, L.S. (2006, August). Swimming as a feminist. Invited presentation, 114th Annual Convention of the American
Psychological Association, New Orleans LA.
Brown, L.S. (2006, June). Feminist therapy in the context of multiple and conflicting identities. Invited address, Section
on Psychology and Women, Conference of the Canadian Psychological Association, Calgary, Alberta.
Brown, L.S. (2006, May). Feminist therapy with difficult and challenging clients. Invited workshop presented for the
Chinese Guidance and Couseling Association, Taipei, Taiwan.
Brown, L.S. (2006, May). Working with trauma survivors. Invited workshop presented at the National Dongwa
University, Dongwa, Taiwan.
Brown, L.S. (2006, May). Feminist therapy perspectives on trauma treatment. Invited workshop presented at the
National Changua University of Education, Changua Taiwan.
Brown, L.S. (2006, May). Working with lesbian, gay and bisexual clients. Invited workshop presented at the National
Changua University of Education, Changua Taiwan.
Brown, L.S. (2006, March). If I’m not for myself-but which self? Living in multiple identities. Invited keynote address,
Annual Conference of the Association for Women in Psychology, Ann Arbor MI.

18

Brown, L.S. (2005, August). Still subversive after all these years. Carolyn Wood Sherif Memorial Award Invited
Address, 113th Annual Convention of the American Psychological Asssociation, Washington DC.
Brown, L.S. & Garnets, L. (2005, August). So these two Jewish lesbians walk into an AWP conference. Section on
Lesbian Issues Invited Address, 113th Annual Convention of the American Psychological Asssociation,
Washington DC.
Brown, L.S. (2005, August). Discussant. In L.S. Brown, Chair, Ethical and pedagogical issues in assigned student selfdisclosures. Symposium presented at the 113th Annual Convention of the American Psychological
Asssociation, Washington DC.
Brown, L.S., Antuna, C. & Underwood, B. (2004, November). Infusing multicultural competence into trauma work.
Workshop presented at the Annual Conference of the International Society for Traumatic Stress Studies, New
Orleans LA.
Brown, L.S. (2004, November). Contextual issues in the assessment of complex trauma. In S. Gold (Chair), Contextual
issues in complex trauma: Assessment and treatment. Symposium presented at at the Annual Conference of the
International Society for Traumatic Stress Studies, New Orleans LA.
Brown, L.S. (2004, August). Teaching about trauma in the professional school setting. In L.S. Brown, (Chair) Telling
the truth about trauma in psychology training. Symposium presented at the 112th Annual Convention of the
American Psychological Association, Honolulu Hawai’i.
Brown, L.S. (2004, August). Discussant. In. B. Greene (Chair). A minyan of women. Symposium presented at the 112th
Annual Convention of the American Psychological Association, Honolulu Hawai’i
Brown, L.S. (2004, May). Diversity and Clinical Psychology. Colloquium presented at the Dept. of Psychology,
University of Oregon, Eugene OR.
Brown, L.S. (2004, May). Self-care and the therapist. Lecture presented at the Dept. of Psychology, Univerfsity of
Oregon, Eugene OR.
Brown, L.S. (2004, April). Trauma memory and treatment: Therapy in a minefield. Workshop presented at Kansas
Wesleyan University, Salina KS.
Brown, L.S. (2004, March). Feminist contributions to women’s mental health. Plenary Address presented at the Second
International Congress on Women’s Mental Health, Washington DC.
Brown, L.S. (2003, October). True trauma or true drama: Forensic trauma assessment and the challenge of malingering.
In. L.S. Brown (Chair), Trauma assessment: Challenges and contexts. Symposium presented at the 19th
Annual Meeting of the International Society for Traumatic Stress Studies, Chicago IL.
Courtois, C.A., Turkus, J. & Brown, L.S. (2003, October). Risk management in trauma treatment. Workshop presented
at the 19th Annual Meeting of the International Society for Traumatic Stress Studies, Chicago IL.
Brown, L. S. (2003, August). “And my people shall be your people: A Jewish alliance journey.” In J. Mio (Chair).
Diversity in allied behavior: From the general to the specific, Symposium presented at the 111th Convention of
the American Psychological Association, Toronto Ontario Canada.
Brown, L. S. (2003, August). When feminist and mainstream ethics collide. In L. Knauss, (Chair). Feminist EthicsPractice and Perspective. Symposium presented at the 111th Convention of the American Psychological
Association, Toronto Ontario Canada.
Brown, L. S. (2003, August). From practice to classroom: Creating the next generation. In L. S. Brown and D.
Haldeman (Chairs). Privately out of the closet: Lives and work of LGB therapists. Symposium presented at the
111th Convention of the American Psychological Association, Toronto Ontario Canada.

19

Brown, L. S. (2003, August). Advances in practice. In E. Cole, (Chair). Thirty years of passion and progress- APA
Committee on Women in Psychology. Symposium presented at the 111th Convention of the American
Psychological Association, Toronto Ontario Canada.
Brown, L.S. (2003, May). Deconstructing diagnosis: Thinking beyond the DSM. Invited keynote workshop, Annual
Convention of the Oregon Psychological Association, Eugene OR.
Brown, L.S. (2003, May). Diversity: Yours, mine and ours. Workshop presented at the Annual Convention of the
Oregon Psychological Association, Eugene OR.
Brown, L.S. (2003, February). Deconstructing diagnosis: How to think diagnostically. Workshop presented for the
Portland Chapter, Association for Women in Psychology, Portland OR.
Brown, L.S. (2003, January). Panel member in S. Dworkin (Chair). From Moshe Rabenu to Go Down Moses: A
Jewish-African American dialogue. Third National Multicultural Conference and Summit, Los Angeles CA.
Brown, L.S. (2002, November). Forensic assessment of complex post-traumatic states in civil litigation. In L.S. Brown
(Chair). Contextual issues in complex trauma. Symposium presented at the Eighteenth Annual Meeting,
International Society for Traumatic Stress Studies, Baltimore MD.
Brown, L.S. (2002, August). Can trauma be queer too? LGB issues in the study of trauma, loss, and grief. Invited
lecture presented at the 110th Annual Convention of the American Psychological Association, Chicago IL.
Brown, L.,S. (2002, August) My “family” in psychology”: The people who have taught me. In M. Hoyt (Chair)
Honoring our teachers: Eminent psychologists describe who influenced them and how. Symposium presented
at the 110th Annual Convention of the American Psychological Association, Chicago IL.
Brown, L.S. (2002, August). “Don’t be a sheep”: How this oldest daughter became a feminist therapist. In J. Norcross,
(Chair).Why I (really) became a psychotherapist: Five psychologists speak. Symposium presented at the 110th
Annual Convention of the American Psychological Association, Chicago IL.
Brown, L.S. (2001, August). How I embody feminist therapy. In J. Norcross (Chair) How do eminent therapist embody
their theory of psychotherapy. Symposium presented at the 109th Convention of the American Psychological
Association, San Francisco CA.
Brown, L.S. (2001, August). Will the “Real” Mother Please Stand Up?: Implications of the Troxel Decision for Lesbian
and Gay Families. In M. Gottlieb (Chair). Implications of the US Supreme Court Troxel Decision. Symposium
presented at the 109th Convention of the American Psychological Association, San Francisco CA.
Brown, L.S. (2001, March). Increasing competency in psychotherapy with lesbian, gay and bisexual clients. Workshop
presented at Birkbeck College, Unversity of London, London England.
Brown, L.S. (2001, March). A century of psychotherapy with lesbian, gay and bisexual clients: Always patients? In S.
Wilkinson, (Chair), A century of lesbian and gay psychology. Symposium presented at the Centenary Meeting
of the British Psychological Society, Glasgow, Scotland.
Brown, L.S. (2001, March). Lesbian and gay paradigm in psychology: Notes for the second stage. Invited Address
presented at the Centenary Meeting of the British Psychological Society, Glasgow, Scotland.
Brown, L.S. (2001, March). From subversive dialogues to difficult ones: Feminist therapy with highly challenging
clients. In L. Moss (Chair), Advanced Feminist Therapy Institute, Workshop presented at the Annual
Conference of the Association for Women in Psychology, Los Angeles CA.
Brown, L.S. (2001, January). Ethical and professional issues in managing overlapping relationships. Workshop
presented for the Oregon State University Counseling Center, Corvallis OR.

20

Brown, L.S. .(2000, August) Feelings in context: Feminist therapy perspectives on countertransference. In J. Norcross,
(Chair) Six perspectives on countertransference. Symposium presented at the 108th Convention of the
American Psychological Association, Washington DC.
Brown, L.S. (2000, May). Basic concepts in feminist therapy theory. Workshop presented for the University of Florida
Counseling Center, Gainseville FL.
Brown, L.S. (2000, May). Surviving and Thriving in Trauma Work in the 21st Century. Keynote address to the
Gainesville Commission on the Status of Women Annual Conference on Sexual Assault, Gainseville FL.
Brown, L.S. (2000, May). From subversive dialogues to difficult ones: Challenges in feminist therapy practice.
Workshop presented for the Portland Women’s Therapy Project, Portland, OR.
Brown, L.S. (2000, March). Welcome to the Gamma quadrant: Forensic survival strategies for trauma therapists.
Workshop presented for the Women’s and Children’s Center, Boise ID.
Brown, L.S. (2000, January). Trauma, memory, and treatment. Workshop presented for Eastern Washington University
Continuing Professional Education Program, Spokane WA.
Frankel, S., Brown, L.S.& Dalenberg, C. (1999, November). Forensic assessment of Dissociative Identity Disorder.
Workshop presented at the 15th Annual Meeting of the International Society for Traumatic Stress Studies,
Miami FL.
Brown, L.S. (1999, November). Finding hope: Surviving as a trauma therapist. Keynote address and workshop
presented at the Ninth Annual Conference of the Renfrew Center Foundation, Phildelphia PA.
Brown, L.S. (1999, October). Trauma, memory, and feminist perspectives on trauma treatment. Workshop presented
for Joining Together Against Sexual Abuse, Cleveland OH.
Brown, L.S. (1999, October). Forensic concerns for treating therapists. Workshop presented at the Midwest
Conference on Child Sexual Abuse, Madison WI.
Brown, L.S. (1999, October). Trauma, memory and treatment. Workshop presented at the Midwest Conference on
Child Sexual Abuse, Madison WI.
Brown, L.S. (1999, October). Psychological expert testimony in white collar crime cases. In M. Pasano (Chair), White
collar crime, Symposium presented at the APA-ABA Conference on Psychological Expertise and the Criminal
Justice System, Arlington VA.
Brown, L.S. (1999, August). Coping with “retractor” lawsuits: How to reduce risk. Presented at a symposium,
Therapist misconduct in the next millenium: Trends, legal costs and risk management. (R. Folman, Chair).
107th Annual Convention of the American Psychological Association, Boston MA.
Brown, L.S. (1999, August). Participant, roundtable discussion, Feminist therapy experiences and reflections. (M.
Ballou, Chair). 107th Annual Convention of the American Psychological Association, Boston MA.
Brown, L.S. (1999, August). Forensic issues in recovered memory cases: An update. Presented at a symposium,
Delayed recall of trauma: An update on clinical and forensic practice. (C. Courtois, Chair). 107th Annual
Convention of the American Psychological Association, Boston MA.
Brown, L.S. (1999, April). Feminist therapy with a same-sex couple. Invited Distinguished Presenter, Annual Meeting,
International Association of Marriage and Family Counselors, San Diego CA.
Brown, L.S. (1999, April). Forensic issues for trauma therapists. Invited workshop at a conference, Posttraumatic
Stress Disorders Treatment in the Post DSM IV World. US Dept. of Veteran’s Affairs, Seattle WA.

21

Brown, L.S. (1998, November). Adventures in the Gamma Quadrant: Surviving as a trauma specialist in the age of
“false memory” litigation. Plenary lecture presented to the Annual Meeting of the International Society for the
Study of Dissociation, Seattle WA.
Brown, L.S. (1998, November). Forensic concerns for treating therapists. Workshop presented at the Annual Meeting
of the International Society for the Study of Dissociation, Seattle WA.
Brown, L.S. (1998, October). Reclaiming the sacred in psychotherapy practice: The challenge of the new millenium.
Keynote Address at the Annual Institute and Conference, American Academy of Psychotherapists, Austin, TX.
Brown, L.S. (1998, October). Feminist therapy: Not for women only. Workshop presented at the Annual Institute and
Conference, American Academy of Psychotherapists, Austin, TX.
Brown, L.S. (1998, September). Trauma and memory: Cognitive and neuroscience findings as applied to EMDR
practice. Pacific NW EMDR Conference, Seattle WA.
Brown, L.S. (1998, August). The recovered memory debate: Where do we stand now? Invited address, Brief Therapy
Conference of the Milton Erickson Foundation, New York NY.
Brown, L.S. (1998, August). When your client is a plaintiff: Forensic survival strategies for treating therapists.
Workshop presented at the Brief Therapy Conference of the Milton Erickson Foundation, New York NY.
Brown, L.S. (1998, August). Forensic assessment issues in delayed recall cases. In C. Courtois (Chair), Issues in
recovered memory: What’s the state of the art, Symposium presented at the 106th Annual Convention of the
American Psychological Association, San Francisco CA.
Brown, L. S. (1998, August). All you need is a little respect: What makes feminist therapy effective. In J. Norcross
(Chair). Three things that make my therapy effective. Symposium presented at the 106th Annual Convention of
the American Psychological Association, San Francisco CA.
Brown, L. S. (1998, August). Trauma, memory and treatment: A feminist perspective. Continuing education workshop
presented for the Division of Psychotherapy, 106th Annual Convention of the American Psychological
Association, San Francisco CA.
Brown, L.S. (1998, June). Making social justice a life focus. Invited speaker, 1998 Commencement of the
Massachusetts School of Professional Psychology, Boston MA.
Brown, L.S. (1998, April). False memories or false assumptions: A critical look at the memory debates. Visiting
Scholar Lecture, Kenyon College, Gambier OH.
Brown, L.S. (1998, April). Feminist models of ethical decision-making for practice. Workshop presented for the
Interdisciplinary Program in Feminist Practice, University of Michigan, Ann Arbor MI.
Brown, L.S. (1998, March). Therapists in the courtroom: Probably not, maybe? In W. Foote, chair An immodest
proposal: Therapists should not be allowed in the courtroom, Syposium presented at the Biennial Meeting,
American Psychology-Law Society, Redondo Beach CA.
Brown, L.S. (1998, February). Introduction to theory of feminist practice. Workshop presented at Rollins College,
Winter Park FL.
Brown, L.S. (1998, February). Ethical dilemmas in feminist forensic practice. Presented at the Annual Conference,
Division of Psychology of Women, Lexington KY.

22

Brown, L.S., (1998, January). Towards subverting despair: Finding the sacred in psychotherapy practice. Keynote
address presented at the Mid-Winter Meeting of the Georgia Psychological Association, Division E, Young
Harris GA.
Brown, L.S. (1998, January). Who me, spiritual? Recreating meaning in psychotherapy. Workshop presented at the
Mid-Winter Meeting of the Georgia Psychological Association, Division E, Young Harris GA
Brown, L.S. (1997, November). Overcoming fear of politics: How embracing diversity can empower you as a therapist.
Invited keynote address, Women and Power Conference, Arbour Health Systems, Boston MA.
Brown, L.S. (1997, November). Discussant, in M. A. Dutton, (Chair). Alternative hypotheses in feminist forensic
psychology. Symposium presented at the 13th Annual Meeting of the International Society for Traumatic
Stress Studies, Montreal Quebec.
Brown, L.S. (1997, November). Special topics in forensic assessment of trauma: Gender, race, class, and culture. In A.
Pratt (Chair) Psychological trauma: Forensic evaluation and testimony. Invited Workshop presented at the
13th Annual Meeting of the International Society for Traumatic Stress Studies, Montreal Quebec.
Brown, L.S. & Courtois, C. (1997, November). Delayed memory in the clinical setting: Treatment principals and
guidelines. Invited Workshop presented at the 13th Annual Meeting of the International Society for Traumatic
Stress Studies, Montreal Quebec.
Brown, L.S. (1997, October). Trauma, memory and treatment: What’s the state of the art. Workshop presented at the
Nova Southeastern University School of Professional Psychology, Ft. Lauderdale FL.
Brown, L.S. (1997, September). What do gender and sexuality issues have to do with the practice of clinical
psychology? Workshop presented at the San Diego campus, California School of Professional Psychology,
San Diego CA.
Brown, L.S. (1997, August). Discussant, in G. Koocher, Chair, Scientific and political issues in the recovered memory
debate. Symposium presented at the 105th Annual Convention of the American Psychological Association,
Chicago IL
Brown, L.S. (1997, August). Giving away feminist psychology: To whom, and how? Division 35 Presidential Address
presented at the 105th Annual Convention of the American Psychological Association, Chicago IL.
Brown, L.S. (1997, July). Forensic considerations for EMDR practitioners. Invited plenary lecture, Second Annual
Conference of the EMDR International Association, San Francisco CA.
Brown, L.S. (1997, June). Feminist therapy theory and practice. Workshop presented at the Justice Institute,
Vancouver BC.
Brown, L.S. (1997, April). The debate over delayed recall of childhood abuse: What do we know now. Invited lecture
presented at the Annual Meeting of the Western Psychological Association, Seattle WA.
Brown, L.S. & Haldeman, D. (1997, March). Lesbian and gay issues in professional psychology. Workshop presented
at the Midwinter Conference of Divisions 29, 42, 43, St. Petersburg FL.
Brown, L.S. (1997, March). Introduction to Feminist Therapy theory and practice. Workshop presented for the
Psychological Service Center, Pacific University, Forest Grove OR.
Brown, L.S. (1997, January). Ethical and legal concerns for therapists in the recovered memory context. Lecture
presented to the Seattle Counselor Association, Seattle WA.
Brown, L.S. (1996, December). Core concepts in feminist therapy theory. Workshop presented at the Brief Therapy
Conference of the Milton Erickson Foundation, San Francisco CA.

23

Brown, L.S. (1996, December). Feminist therapy perspectives on diagnosis. Workshop presented at the Brief Therapy
Conference of the Milton Erickson Foundation, San Francisco CA.
Brown, L.S. (1996, November). Expert testimony and forensic evaluations. In K.S. Pope (Chair) Recovered memory
controversy: Legal trends, expert testimony and clinical implications. Symposium presented at the 12th
Annual Meeting, International Society for Traumatic Stress Studies, San Francisco CA.
Brown, L.S. (1996, November).Special considerations in forensic evaluations: Multiple vulnerabilities. In. M.A.
Dutton, (Chair), Sexual harassment as trauma: The controversy in a forensic context. Symposium presented at
the 12th Annual Meeting, International Society for Traumatic Stress Studies, San Francisco CA.
Brown, L.S. (1996, November) PTSD in civil litigation: Forensic evaluation and testimony. Chair of workshop
presented at the 12th Annual Meeting, International Society for Traumatic Stress Studies, San Francisco CA.
Brown, L.S. (1996, October). Feminist therapy: Creating the egalitarian relationship. Invited workshop presented at
the American Academy of Psychotherapists Annual Institute and Conference, Atlanta GA.
Brown, L.S. (1996, October). Ethical and legal considerations for feminist practice with recovered memories. Presented
at a symposium, Feminist psychology and the recovered memory debate. Annual Conference of the SE
Regional Chapter, Association for Women in Psychology, Hilton Head SC.
Brown, L.S. (1996, October). The continuing adventure: Inventing and reinventing theory in feminist psychology.
Invited plenary address at the Annual Conference, SE Regional Chapter, Association for Women in
Psychology, Hilton Head SC.
Brown, L.S. (1996, October). The politics of memory: Whose science, whose history. Plenary invited lecture at a
conference Memory: Authorizing the Twentieth Century, University of Colorado, Boulder CO.
Brown, L.S. (1996, August). The private practice of subversion: Psychotherapy as Tikkun Olam. Awards address
presented at the 104th Annual Convention of the American Psychological Association, Toronto Ontario
Canada.
Brown, L.S. (1996, June). Psychotherapy and assessment in the context of sexual harassment. Workshop presented at
the conference of the Florida Psychological Association, West Palm Beach FL.
Brown, L. S. (1996, June). The recovered memory debate: What do we know now. Workshop presented at the
conference of the Florida Psychological Association, West Palm Beach.
Brown, L.S. (1996, June). Strategies for enhancing client empowerment in cases of recovered memory. In W. Freed
(Chair) The recovered memory debate: Scientific and clinical issues. Symposium presented at the Second
International Conference of the ISTSS, Jerusalem Israel.
Brown, L.S. (1996, April). Dissociation as a coping strategy in the face of trauma. Workshop presented at the
Children’s Justice Conference, Bellevue WA.
Brown, L.S. (1996, April). Healing the traumatized woman: Strategies for effective intervention. Workshop presented
at the 11th Regional Conference on Trauma, Dissociation and Related Disorders, Akron OH.
Brown, L.S. (1996, April). An introduction to feminist therapy theory and practice. Workshop presented at Austin
Women’s Psychotherapy Project, Austin TX.
Brown, L.S. (1996, April). False memories or false issues: What’s really happening in therapy? Lecture presented at
Austin Women’s Psychotherapy Project, Austin TX.

24

Brown, L.S. (1996, March). Supporting clients with containment in the memory recovery process. In. S. Gold (Chair)
Alternatives to memory recovery, Symposium presented at the Mid-Winter Convention of the Divisions of
Psychology, Independent Practice, and Family Psychology, Scottsdale AZ.
Brown, L.S. (1996, March). Theory in feminist therapy: Where from here? Invited awards address presented at the 21st
Annual Convention, Association for Women in Psychology, Portland OR.
Brown, L.S. (1996, March). Ethical and legal implications of the delayed memory debate. In K. Quina (Chair). Making
the personal political and theoretical: Feminist perspectives on the delayed memory debate. Symposium
presented at the 21st Annual Convention, Association for Women in Psychology, Portland OR.
Brown, L.S. (1996, February). Heterosexism in the construction of women’s sexuality. Presented at the Mid-Winter
Conference of the Division of Psychology of Women, Knoxville TN.
Brown, L.S. (1995, November). The clinicians’ critique of the memory scientists. In J. Herman (Chair). Clinicians’
report from the APA Working Group on Memories of Abuse. Symposium presented at the annual meetings of
the International Society for Traumatic Stress Studies, Boston MA.
Brown, L.S. (1995, October). Clinical and forensic considerations with the remembering client. Workshop presented at
the Fall Meeting of the Washington State Psychological Association, Tacoma WA.
Brown, L.S. (1995, October). Subversive dialogues: Feminist therapy. Workshop presented at the California Institute of
Integral Studies, San Francisco CA.
Brown, L.S. (1995, September). Evaluating future damages. Presented at a symposium, Violence: Liability and
Damages, Washington State Trial Lawyers Association, Seattle WA.
Brown, L.S. (1995, August). Theory-building as feminist practice. In R. Nutt (Chair) The many faces of feminist
practice, Symposium presented at the 103rd Annual Convention of the American Psychological Association,
New York NY.
Brown, L.S. (1995, August). Feminist issues in evaluation and testimony in recovered memory cases. In. L.S. Brown
(Chair), Feminist forensic psychology: An emerging field of feminist practice. Symposium presented at the
103rd Annual Convention of the American Psychological Association, New York NY.
Brown, L.S. (1995, June). Preventing heterosexism in psychotherapy. Workshop prevented at the Vermont Conference
on Primary Prevention, Burlington VT.
Brown, L.S. (1995, April). Not the Ethics 101 Class: Empowering therapists as ethical decision-makers. CHASTEN
Spring Workshop Series, Toronto Ontario Canada.
Brown, L.S. (1995, April). Sexual harassment: Conceptual issues for forensic practitioners. Presented at the Fifth
Annual University of Miami Law School National Symposium: Mental Health and the Law, Ft. Lauderdale
FL.
Brown, L.S. (1995, February). Working with the treating therapist and expert witness. Presented at a symposium,
Representing victims of sexual abuse, Washington State Trial Lawyers Association, Seattle WA.
Brown, L.S. (1995, February).Forensic issues for the treating therapist of sexual abuse survivors. Lecture presented at a
workshop, Feminist approaches to trauma treatment, Center for Community Counseling, Eugene OR.
Brown, L.S. (1995, February). Standards for practice after Ramona: Issues for forensic practitioners. Invited lecture,
American Academy of Forensic Sciences Annual Meeting, Seattle WA.
Brown, .L.S. (1994, October). The recovered memory debate: Issues for clinicians. Lecture presented at the Fall
Convention, Washington State Psychological Association, Bellevue WA.

25

Brown, L.S. (1994, October). When the therapist is a woman: Responding to same-sex abuse in therapy. Workshop
presented at the Third It’s Never Okay Conference, Toronto Ontario Canada.
Brown, L.S. (1994, October). Mind-rape: Non-sexual abuse and malpractice in therapy. Workshop presented at the
Third It’s Never Okay Conference, Toronto Ontario Canada.
Brown, L.S. (1994, September). Avoiding heterosexism in psychotherapy and counseling. Workshop presented at the
University of Georgia, Athens GA.
Brown, L.S. (1994, September). The lesbian/gay paradigm; Directions for the 21st Century. Inaugural invited lecture,
Andrea Colley Memorial Lecture Series, Women’s Studies Program, University of Georgia, Athens GA
Brown, L.S. (1994, September). The recovered memory controversy; Facts and realities. Lecture presented for the East
Side Sexual Assault Center Consultation, Bellevue WA.
Brown, L.S. (1994, August).. When your patient is the plaintiff: Staying sane as the psychotherapist. In K.S. Pope,
(Chair). When your patient is the plaintiff: A new look. Symposium presented at the 102nd Annual Convention
of the American Psychological Association, Los Angeles CA.
Brown, L..S. (1994, August). Gender issues in lesbian couples. In R.Scrivner (Chair), Gender role as a factor in gay
male and lesbian couples. Symposium presented at the 102nd annual Convention of the American
Psychological Association, Los Angeles CA.
Brown, L.S. (1994, August). The role of the expert witness and treating therapist in sexual harassment cases after
Harris v. Forklift. In J. Goodman (chair), Sexual harassment after Harris v. Forklift. Symposium presented at
the 102nd Annual Convention of the American Psychological Association, Los Angeles CA.
Brown, L.S. (1994, August). The politics of recovered memory. Discussion hour presented at the 102nd Annual
Convention of the American Psychological Association, Los Angles CA.
Brown, L.S. (1994, June). Why you don’t have to be afraid of false memory lawsuits. Presented at a workshop
Avoiding False Memory Syndrome Lawsuits, Seattle WA.
Brown, L.S. (1994, April). New voices, many visions: Theory in feminist therapy. Workshop presented for Tampa Bay
Women Therapists Association and the U. of South Florida, Tampa FL.
Brown, L.S. (1994, April). Feminist therapy and health care reform. Presented at the Northwest Women’s Studies
Conference, Tacoma WA.
Brown, L.S. (1994, March). On being Jewish and feminist. In L. Obler (Chair). Jewish feminists in psychology.
Symposium presented at the conference of the Association for Women in Psychology, Oakland CA.
Brown, L.S. (1994, January). Subversive dialogues: Theoretical perspectives in feminist therapy. Workshop presented
for the Midwinter Meeting of the Georgia Psychological Association, Asheville NC
Brown, L.S. (1994, January). Feminist ethics in psychotherapy: Strategies for decision-making. Workshop presented at
the Midwinter Meeting of the Georgia Psychological Association, Asheville NC
Brown, L.S. (1993, August). Feminist therapy theory: Applications to family psychology. Invited address, Convention
of the American Psychological Association, Toronto Ontario Canada.
Brown, L.S. (1993, August). The case for therapy. In E. Rothblum, (Chair), Can radical lesbian feminism coexist with
psychology? Symposium presented at the Convention of the American Psychological Association, Toronto
Ontario Canada.

26

Brown, L.S. (1993, April). The perils of diagnosis. Keynote Address, Conference on Ending Violence Against Women,
University of Western Ontario, London Ontario Canada.
Brown, L.S. (1993, April). Models of Clinical Supervision. In C. Freeman, (Chair), The supervisory relationship.
Symposium presented at the Spring Meetings of the Washington State Psychological Association, Seattle WA.
Brown, L.S. (1993, March). Dealing with encroaching legalism in the APA Ethics Code. Workshop presented at the
Annual Conference of the Association for Women in Psychology, Atlanta GA.
Brown, L.S.(1993,March). Becoming a diplomate: A workshop for feminist therapists. Presented at the Annual
Conference of the Association for Women in Psychology, Atlanta GA.
Brown, L.S. (1992, October). Shattered expectations as trauma in therapy abuse. Workshop presented at the meetings
of the International Society for Traumatic Stress Studies, Los Angeles CA.
Brown, L.S. (1992, August). Anti-domination training as an essential component of diversity in clinical psychology. In
L. Comas-Diaz, Chair, Achieving diversity in clinical psychology, Symposium presented at the 100th Annual
Convention of the American Psychological Association, Washington DC.
Brown, L.S. (1992, August). Feminist therapy perspectives on the 1992 APA Ethics Code Revision. Discussion hour
presented at the 100th Annual Convention of the American Psychological Association, Washington DC.
Brown, L.S. (1992, August). Identity management issues in the workplace as a quality of life issue. In L. Garnets,
Chair, Quality of life for lesbians and gay men. Symposium presented at the 100th Annual Convention of the
American Psychological Association, Washington DC.
Brown, L.S. (1992, August). How can we make psychology genuinely multicultural? In G. Gottsegen, Chair,
Psychology at Work: Centennial Panel, Symposium presented at the 100th Annual Convention of the
American Psychological Association, Washington DC.
Brown, L.S. (1992, August). Discussant in A. Lawler, Chair, Feminist perspectives on codependency. Symposium
presented at the 100th Annual Convention of the American Psychological Association, Washington DC.
Brown, L.S. (1992, June). Using DSM-III-R with culturally diverse populations. Workshop presented at RIAGG
Amsterdam-Oost, Amsterdam, The Netherlands
Brown, L.S. (1992, June). Trauma "within the range" of usual experience." In L.S. Brown, Chair, Feminist therapy
perspectives on trauma, Symposium presented at the First International Congress of the International Society
for the Study of Traumatic Stress, Amsterdam, The Netherlands.
Brown, L.S. (1992, June). Feminist therapy with lesbian trauma survivors: Clinical considerations for the population. In
L.E.A. Walker, Chair, Feminist therapy with trauma survivors, symposium presented at the First International
Congress of the International Society of the Study of Traumatic Stress, Amsterdam, The Netherlands
Brown, L.S. (1992, February). Women's adult development. Workshop presented at the Third Conference on Women,
Washington State Psychological Association, Seattle, WA.
Brown, L.S. (1991, December). Feminist therapy ethics. Workshop presented for the Feminist Counseling Association
of Western Canada, Vancouver BC Canada.
Brown, L.S. (1991, December). The integration of heart and mind: Becoming adult women. Invited Lecture, American
Psychological Association Centennial Series on Human Development, Washington DC.
Brown, L.S. (1991, November). Boundary dilemmas in feminist psychotherapy. Workshop presented for the Women's
Counseling Referral and Education Centre, Toronto Ontario Canada.

27

Brown, L.S. (1991, August). Discussant, in L.S. Brown, (Chair) Dealing with the continuum of boundary dilemmas in
psychotherapy. Symposium presented at the Convention of the American Psychological Association, San
Francisco CA.
Brown, L.S. (1991, August). The effect of the report process in treatment of therapy abuse survivors. In K. Saakvitne
(Chair), Treating victims of abusive psychotherapies: Clinical, ethical, and countertransference issues.
Symposium presented at the Convention of the American Psychological Association, San Francisco CA.
Brown, L.S. (1991, August). Future directions for the lesbian/gay paradigm for psychology. Invited address,
Convention of the American Psychological Association, San Francisco CA.
Brown, L.S. (1991, May) The importance of a multicultural perspective. Invited address at the Annual Conference of
the Interaktie Akademie,Antwerp, Belgium.
Brown, L.S. (1991, March). New voices, new visions: A lesbian paradigm for the psychology of women. Invited address
presented at the meeting of the Division of Women, Georgia Psychological Association, Atlanta GA.
Brown, L.S. (1990, October) Ethical considerations in the treatment of lesbian and gay male clients. Presentation at the
Fall Meeting of the Washington State Psychological Association, Bellevue WA.
Brown, L.S. (1990, October). Therapy in another mother tongue: Working with the sexual minority client. Keynote
address at a conference, Counseling the Lesbian, Gay and Bisexual Client, Ithaca NY.
Brown, L.S. (1990, August) Anti-racism as an ethical imperative in feminist therapy. In L.S. Brown (Chair) Ethics in
feminist therapy: Next steps. Symposium presented at the Convention of the American Psychological
Association, Boston, MA.
Brown, L.S. (1990, August). Making psychology safe for lesbians and gay men. In A. Smith (Chair) Future directions
in lesbian and gay issues in psychology. Symposium presented at the Convention of the American
Psychological Association, Boston, MA.
Brown, L.S. (1990, August) Sex in a vacuum: Heterosexism in the social construction of women's sexuality. In C.
Travis (Chair) The social construction of women's sexuality. Symposium presented at the Convention of the
American Psychological Association, Boston, MA.
Brown, L.S. (1990, August) The meaning of a non-homophobic psychology. Conversation hour presented at the
Convention of the American Psychological Association, Boston MA.
Brown, L.S. (1990, May) The future of feminist therapy. Presented at the Feminist Practice Conference, UW School of
Social Work, Seattle WA.
Brown, L.S. (1990, March) What are the next steps in feminist therapy ethics? Presented at the Conference of the
Association for Women in Psychology, Tempe AZ.
Brown, L.S. (1990, January) Future issues for feminist psychology. Invited address given at a conference on Women
and Psychology presented by the Colorado Women Psychologists, Denver CO.
Brown, L.S. (1989, August) Victimization as a risk factor for depression in women. In S. Noelen-Hoeksma (Chair)
Special topics in women and depression. Symposium presented at the Convention of the American
Psychological Association, New Orleans, LA.
Brown, L.S. & Gonsiorek, J. (1989, August). Ethical concerns for lesbian and gay male therapists. Conversation hour
presented at the Convention of the American Psychological Association, New Orleans, LA.
Brown, L.S. (1989, March). Working with lesbian and gay clients and their families. Continuing Psychological
Education Workshop presented at a meeting of Colorado Women Psychologists, Denver CO.

28

Brown, L.S. (1988, December). Feminist therapy perspectives on psychodiagnosis: Beyond DSM and ICD. Keynote
address presented at the First International Congress on Mental Health Care for Women, Amsterdam, The
Netherlands.
Brown, L. S. (1988, September) Treating the victims of abusive therapists. Continuing education workshop presented at
a conference on Women and Psychology, Washington State Psychological Association, Tacoma WA.
Brown, L.S. (1988, September) Current issues and developments in feminist therapy. Presented at a conference on
Women and Psychology, Washington State Psychological Association, Tacoma WA.
Brown, L.S. (1988, August) Feminist therapy ethical issues with special populations. In E. Rave (Chair) Feminist
therapy ethics, Symposium presented at the Convention of the American Psychological Association, Atlanta
GA.
Brown, L.S. (1988, August) Taking account of gender and sexuality issues in clinical assessment. In K. Pope (Chair)
Doing valid and useful clinical assessment, Symposium presented at the Convention of the American
Psychological Association, Atlanta GA.
Brown, L.S. (1988, August). New voices, new visions: towards a lesbian/gay paradigm for psychology. Presidential
address presented at the Convention of the American Psychological Association, Atlanta GA.
Brown, L.S. (1988, May) The meaning of a multicultural perspective for theory- building in feminist therapy. Seventh
Advanced Feminist Therapy Institute, Seattle WA.
Brown, L.S. (1987, August) Toward a new conceptual paradigm for the Axis II diagnoses. Presented at a symposium
on DSM-III-R. 95th Convention of the American Psychological Association, New York NY.
Brown, L.S. (1987, August) Beyond "Thou shalt not:" Developing conceptual frameworks for ethical decision-making.
Presented at a symposium, Ethical and boundary dilemmas for lesbian and gay psychotherapists. 95th
Convention of the American Psychological Association, New York NY.
Brown, L.S. (1987, May) Training issues for white feminist therapists working with women of color trainees. Paper
presented at the Sixth Advanced Feminist Therapy Institute, Chicago, IL.
Brown, L.S. (1987, March) Lesbians and gay men as adult members of their families of origin: Basic clinical issues.
Presented at a symposium, Lesbians and Gay Men and Their Families, Midwinter conference of the
Divisions of Psychotherapy, Independent Practice, and Family Psychology, New Orleans, LA.
Brown, L.S. (1987, January) Learning to think about ethics: A guide for the perplexed lesbian feminist therapist.
Invited keynote address, Boundary dilemmas in the client-therapist relationship: A working conference for
lesbian therapists. Los Angeles, CA.
Brown, L.S. (1986, November) What's missing in graduate training in psychology? Presented at a discussion program,
The future of graduate training in psychology, Fall Meeting of the Washington State Psychological
Association, Everett, WA.
Brown, L. S. (1986, August) Negative impacts of post-termination sexual relationships between clients and therapists.
Presented at a symposium, Relationships with patients after termination: Ethical, clinical and legal issues.
Convention of the American Psychological Association, Washington DC.
Brown, L.S. (1986, August) A time to be critical: New directions in lesbian- affirmative psychotherapy. Presented at a
symposium, Advances in Gay- Affirmative Psychotherapy. Convention of the American Psychological
Association, Washington DC.

29

Brown, L.S. (1986, August) Diagnosis and the zeitgeist: The politics of masochism in the DSM-III-R. Presented at a
symposium, The politics of diagnosis, Convention of the American Psychological Association, Washington
DC.
Brown, L.S. (1986, August) Fat oppression and psychotherapy; a new look at the meaning of body size. Presented at a
symposium, Disordered or Displaced: Women in Context. Convention of the American Psychological
Association, Washington DC.
Brown, L.S. (1986, May) Confronting ethically problematic feminist therapists. Paper presented at the Fifth Annual
Advanced Feminist Therapy Institute, Minneapolis, MN.
Brown, L.S. (1985, November) Assessment and diagnosis in feminist therapy. Continuing Education Workshop
presented at the Fall Meeting of the Washington State Psychological Association, Seattle, WA.
Brown, L.S. (1985, August) Sexual issues in the development of lesbian couples. Paper presented at a symposium, A
developmental approach to therapy with lesbian couples. A Convention of the American Psychological
Association, Los Angeles, CA.
Brown, L.S. (1985, August) Employment issues for lesbian and gay male clinicians. Paper presented at a symposium,
Employment concerns of lesbian and gay male psychologists. Convention of the American Psychological
Association, Los Angeles, CA
Brown, L.S. (1985, June) A continuing education model for training in feminist therapy. Paper presented at a
symposium, Three approaches to training in feminist therapy. Conference of the National Women's Studies
Association, Seattle, WA.
Brown, L. S. (1985, April) Ethical and conceptual issues in the development of feminist therapy theory. Paper presented
at the Fourth Advanced Feminist Therapy Institute, Bal Harbour, FL.
Brown, L.S. (1984, October) An introduction to feminist therapy theory. Continuing Education Workshop presented at
the Fall Meeting of the Washington State Psychological Association, Seattle, WA.
Brown, L.S. (1984, May) An Introduction to Feminist Psychology. Lecture presented at the Spring Meeting of the
Washington State Psychological Association, Spokane, WA.
Brown, L.S. (1984, May) Psychology and Social Issues: Creating a Zeitgeist for Knowledge, Fulfilling Ethical
Responsibilities to our Communities. Presented at a symposium, Should WSPA Get Involved in Social Issues?,
Spring Meeting of the Washington State Psychological Association, Spokane, WA.
Brown,L.S. (1984, March) Power and responsibility:Developing ethical guidelines for feminist therapists. Presented at
the Third Advanced Feminist Therapy Institute, Oakland, CA.
Brown, L.S. (1984, March) What psychologists working in the media need to know about women's issues. Presented at
the Mid-Winter Conference of the Division of Psychotherapy/Division of Private Practice, San Diego, CA.
Brown, L.S. (1984, May and 1983, October) An introduction to therapy issues with lesbian and gay male clients.
Continuing education workshop presented at the Fall Meeting, Seattle, WA, and the Spring Meeting, Spokane
WA of the Washington State Psychological Association.
Brown, L.S. (1983, August) Sexual issues in therapy with lesbian clients. Workshop presented at the meeting of the
Association of Lesbian and Gay Psychologists, Anaheim,CA.
Brown, L.S. (1983, August) The lesbian feminist therapist and her community. Paper presented at a symposium, The
Female Therapist in Private Practice. Convention of the American Psychological Association, Anaheim, CA.

30

Brown,L.S. (1983, May) Women, weight, and power. Presented at the Second Advanced Feminist Therapy Institute,
Washington, DC.
Brown, L.S. (1983, March) Finding new language:Beyond analytic verbal shorthand.Presented at a symposium,
Toward developing theory in feminist therapy. Tenth Annual Conference of the Association for Women in
Psychology, Seattle, WA.
Brown, L.S.( 1983, March) "Over"weight and "over"eating:The standards and their impact on women. Presented at a
symposium, The Role and Impact of Food and Body-Image in Women's Lives. Convention of Association for
Women in Psychology, Seattle, WA.
Brown, L.S. (1982, August) Internalized oppression as an issue in sex therapy with lesbians. Presented at a symposium,
Therapy With Lesbians. Convention of the American Psychological Association, Washington, DC.
Brown, L.S. (1982, May) Ethical issues in feminist therapy:What is a feminist ethic? Presented at the First Advanced
Feminist Therapy Institute, Vail,CO.
Brown, L.S., DeWolfe, D, and Larson, E.R. (1979, December) Sex therapy and education with lesbian and bisexual
women. Presented at the Fourth World Congress of Sexology, Mexico City, Mexico.
Brown, L.S. (1979, March) Academicians and service providers: Allies or adversaries? Presented at the Conference of
the Association for Women in Psychology, Dallas, TX.
Brown, L.S. (1979, March) A developmental theory of lesbian sexual identity. Presented at the Conference of the
Association for Women in Psychology, Dallas, TX.
Brown, L.S. (1978, April) Assertiveness training:Issues for physical education instructors. Presented at the Conference
of the American Alliance for Health, Physical Education, and Recreation. Kansas City, MO.
Brown, L.S., May, C., and Landis, S. (1978, March) A sexuality workshop for women loving women. Presented at the
Conference of the Association for Women in Psychology, Pittsburgh, PA.
Brown, L.S. (1978, March) Hoisting scholars by their own petards. Presented at a symposium, Festschrift in Honor of
Joan Evansgardner. Conference of the Association for Women in Psychology, Pittsburgh, PA.
Brown, L.S. (1978, March) Supervisory issues in feminist therapy. Presented at the Conference of the Association for
Women in Psychology, Pittsburgh, PA.
Brown, L.S. (1977, August) Sexual assertiveness and contraceptive behavior:An intriguing connection. Presented at the
Open Symposium on Issues and Research in the Psychology of Women. Convention of the American
Psychological Association, Toronto, Ontario, Canada, August.
Brown, L.S. (1976, August) Teaching a Psychology of Women course as a consciousness-raising technique.Presented
at a symposium, Consciousness- Raising in an Academic Setting. Convention of the American Psychological
Association, Washington, DC.
Brown, L.S. (1976, August) Free Women: Creativity and madness in the fiction of Doris Lessing. Presented at a
symposium, If Shakespeare Had A Sister, Convention of the American Psychological Association,
Washington, DC.
Brown, L.S., May, C., and Sprei, J. (1976, February) Sexual and sensual awareness: A consciousness-raising
experience for women. Presented at the Conference of the Association for Women in Psychology, Knoxville,
TN.
Brown. L.S. (1975, August) Investigating the stereotypic picture of lesbians in the clinical literature. Presented at the
Convention of the American Psychological Association, Chicago IL.

31

Miller, H.R., Liss-Levinson, N., Levinson, W., Gulanick, N, Brown, L.S., Coleman, E., and Sullivan, R. (1975, March)
Social skills training. Workshop presented at the Convention of the American Personnel and Guidance
Association.
Brown, L.S. (1975, January) Recent research on gay women. Presented at the Conference of the Association for
Women in Psychology, Carbondale, IL.
PROFESSIONAL ACTIVITIES
American Psychological Association
Committee on Women in Psychology, 1984-86
Education Directorate Roster of Accreditation Site Visitors, 1984- 1993
Board of Social and Ethical Responsibility in Psychology, 1987-89.
Liaison on diagnostic issues to American Psychiatric Association, 1985-1993.
Policy and Planning Board, 1993-1995.
Working Group on Recovered Memories of Childhood Sexual Abuse, 1993-1995.
Committee on Lesbian, Gay and Bisexual Concerns, 1997-1999.
Ethics Code Revision Task Force, 1997-2001.
Candidate for President, 1997 (Nominated and declined, 1998, 2001, 2005)
Post-Traumatic Stress Disorder Treatment Guidelines Working Group, 2012-present
Washington State Psychological Association
Committee on Lesbian and Gay Concerns,(Co-Chairperson, 1984-1986), 1984- present
Provider Issues Committee, 1987-88
Professional Standards and Ethics Review Committee, 1988-90.
Women's Conference Committee, 1988-90.
President Elect-Elect, 1990.
President-Elect, 1991.
Convention Program Chair, 1991.
Workgroup on prescriptive privileges, 1990-1994.
President, 1992.
Past-President, 1993
State Legislative Advocacy Coordinator, 1993-1994
Webmaster, 2001-2003.
Society for the Psychological Study of Social Issues, Division 9 of APA
Liaison to the APA Committee on Lesbian and Gay Concerns, 1987-1989.
Otto Klineberg International Relations Award Committee, 1991.
Society of Clinical Psychology, Div. 12 of APA
Committee on Diversity, 1991-1998
Publications Committee, 1994-1998
Division of Psychotherapy, Div. 29 of APA
Publications Board, 2007-2013
Website redesign task force chair, 2008
Society for the Psychology of Women, Div. 35 of APA.
Chairperson, Nominations Committee, 1985-86
Chairperson, APA Program Review Committee, 1984-1985.
Chair Lesbian Issues Task Force, 1983-85
Co-Chairperson Committee on Clinical Training and Practice, 1985-88,
Chairperson, Sub-committee on Accreditation Issues,1985-90.
APA Convention Program Reviewer, 1984 and 1986

32

Co-Chair, Task Force on Media and Consumer Issues, 1988-90.
Co-Chair ,Section on Feminist Professional Practice and Training,1989-90.
Newsletter Editor, Section on Feminist Professional Training and Practice, 1990-91.
Task Force on Diversity in Feminist Psychology, 1990-91.
Participant and Theory Group Co-Facilitator, National Conference on Training in Feminist Practice, 1993
President-Elect, 1995-1996.
President, 1996-1997.
Past-President, 1997-1998
Coordinator, Academy of Feminist Practice, 1996-present
Representative to APA Council, 1999-2001
Webmaven, 2004-2005
Representative to APA Council 2007-2009
Representative to Divisions for Social Justice, 2007-2009
Member, Working Group on the 2017 Ethics Code Revision
Division of Independent Practice, Div. 42 of APA
Co-Chair, Continuing Education Committee, 2005-2007
Division of Family Psychology, Div. 43 of APA.
Chairperson, Committee on Lesbian and Gay Issues, 1984-1986
Committee on gender issues, 1986-88.
Committee on diversity, 1995-1997.
Society for the Psychological Study of Lesbian and Gay Issues -Division 44 of APA.
President-Elect, 1986-87
President, 1987-89
Past-President, 1989-1990
Fellows Chair, 1989-91
Nominations Chair, 1989-91
Awards Committee Co-Chair, 1988-1989.
Fellows Chair, 2003-2006
Member, Fellows Committee, 2006-present
Web Editor, 2007-2010
Society for the Psychological Study of Ethnic Minority Issues-Division 45 of APA
Member at Large for Diversity of the Executive Committee, 2003-2006
Division of Media Psychology, Div. 46 of APA
Committee on Lesbian and Gay Issues, Chair, 1995.
Committee on Diversity, 1996-1997.
Division of Trauma Psychology, Div. 56 of APA
Web Editor, 2006-2012
Policy Committee, 2006-2012
Publications Committee, 2006-2012
Practice Committee , 2006-2012
Program Committee, 2006-2012
President- Elect, 2009
President, 2010
Past-President, 2011
Representative to the New Haven Trauma Competencies Conference, 2013.
Feminist Therapy Institute
Steering Committee 1983-1988
Coordinator of Committees 1984-86
Training Committee, 1983-1987

33

Newsletter Editor 1983-1987
Membership/Outreach Committee 1983-1987
Ethics and Accountability Committee 1983-1990
Annual Conference Committee Co-Chair,1987-88
Committee on Diversity Co-Chair, 1987-88
Association for Women in Psychology
Feminist internship roster coordinator, 1973-75
Committee Coordinator 1975-77
Feminist therapy roster coordinator 1977-79
National conference coordinator, 1975, 1983.
American Psychological Foundation
Advisory Board, Wayne Placek Fund, 1993-1995
Advancement Committee, 2010-2012
International Society for Traumatic Stress Studies
Program Committee, 1995
Program Committee, 1997-1998
Program Committee 2007
Diversity Special Interest Group, 2005-present
International Society for the Study of Dissociation
Awards Committee, 1999
Chair, Film and Media Committee, 2003-2004

34

Exhibit B

Statement of APA President Regarding the Traumatic Effects of Separating Immigrant Fa... Page 1 of 1

May 29, 2018

Statement of APA President Regarding the Traumatic
Effects of Separating Immigrant Families
WASHINGTON — Following is the statement of APA President Jessica Henderson Daniel, PhD,
regarding the deleterious impact on the health and well-being of children and families who are
separated as they seek to enter the United States without proper documentation:
“The administration’s policy of separating children from their families as they attempt to cross into the
United States without documentation is not only needless and cruel, it threatens the mental and
physical health of both the children and their caregivers. Psychological research shows that
immigrants experience unique stressors related to the conditions that led them to flee their home
countries in the first place. The longer that children and parents are separated, the greater the
reported symptoms of anxiety and depression for the children. Negative outcomes for children
include psychological distress, academic difficulties and disruptions in their development.
“The American Psychological Association calls on the administration to rescind this policy and keep
immigrant families intact (/advocacy/immigration/index.aspx) . We support practical, humane immigration
policies that consider the needs of immigrants, and particularly immigrant families. We must adopt
policies that take into account what we know about the harmful, long-term psychological effects of
separation on children and their families. This is not an acceptable policy to counter unlawful
immigration.”
The American Psychological Association, in Washington, D.C., is the largest scientific and
professional organization representing psychology in the United States. APA's membership includes
nearly 115,700 researchers, educators, clinicians, consultants and students. Through its divisions in 54
subfields of psychology and affiliations with 60 state, territorial and Canadian provincial associations,
APA works to advance the creation, communication and application of psychological knowledge to
benefit society and improve people's lives.
Find this article at:
http://www.apa.org/news/press/releases/2018/05/separating-immigrant-families.aspx

http://www.apa.org/print-this.aspx

6/21/2018

Exhibit C

June 14, 2018
President Donald Trump
The White House
1600 Pennsylvania Avenue
Washington, DC 20500
Dear President Trump:
On behalf of the American Psychological Association (APA), we are writing to express
our deep concern and strong opposition to the Administration’s new policy of separating
immigrant parents and children who are detained while crossing the border. We
previously wrote to then Secretary of Homeland Security John Kelly on April 5, 2017,
about this matter. Based on empirical evidence of the psychological harm that children
and parents experience when separated, we implore you to reconsider this policy and
commit to the more humane practice of housing families together pending immigration
proceedings to protect them from further trauma.
APA is the leading scientific and professional organization representing psychology in
the United States. Our membership includes researchers, educators, clinicians,
consultants, and students. APA works to advance the creation, communication, and
application of psychological knowledge to benefit society and improve people’s lives.
We have 115,700 members and affiliates across the United States and in many other
countries, many of whom serve immigrant youth and adults in a wide range of settings,
including schools, community centers, hospitals and refugee resettlement centers.
The current policy calls for children to be removed from their parents and placed for an
often indeterminate period of time in the custody of the Office of Refugee Resettlement.
Decades of psychological research have determined that it is in the best interest of the
child and the family to keep families together. Families fleeing their homes to seek
sanctuary in the United States are already under a tremendous amount of stress. 1 Sudden
and unexpected family separation, such as separating families at the border, can add to
that stress, leading to emotional trauma in children. 2 Research also suggests that the
longer that parents and children are separated, the greater the reported symptoms of
anxiety and depression are for children. 3 Adverse childhood experiences, such as parentChaudry, A. (2011). Children in the aftermath of immigration enforcement. The Journal of the History of
Childhood and Youth, 4 (1), 137-154.
2
Dreby, J. (2012). The burden of deportation on children in Mexican immigrant families. Journal of
Marriage and Family,74, 829-845. Doi:10.1111/j.1741-3737.2012.00989x
3
Suárez-Orozco, C., Bang, H.J. & Kim, H.Y (2010). I felt like my heart was staying behind: Psychological
implications of family separations and reunifications for immigrant youth. Journal of Adolescent Research
26(2), 222-257.
1

child separation, are important social determinants of mental disorders. For children,
traumatic events can lead to the development of post-traumatic stress disorder and other
mental health disorders that can cause long lasting effects. 4 Furthermore, immigration
policies, such as separating families at the border, can also adversely impact those
immigrants who are already in the United States. They can suffer from feelings of
stigmatization, social exclusion, anger, and hopelessness, as well as fear for the future. 5
As a tragic example of the current policy’s serious potential for harm, a Honduran man
who was separated from his wife and 3-year-old son after he crossed the border into
Texas recently took his own life while detained in a holding cell, according to the
Customs and Border Protection officials, public records, and media reports. 6 There are
also reports of detained immigrants foregoing legitimate claims for asylum by pleading
guilty to expedite the return of their separated children and reports of parents being
deported while their children, including infants, remain in custody. These incidents serve
to highlight the mental health crisis for many families caused by the Administration’s
policy.
Given these considerations, a change in immigration policy regarding the detention of
immigrant families at the border is desperately needed – from separating parents and
children to housing them together and providing needed physical and mental health
services. As psychologists, we have documented multiple harmful effects of parent-child
separation on children’s emotional and psychological development and well-being and
urge that the current policy of family separation be reversed. Should you have any
questions regarding these comments, please contact Serena Dávila, J.D., with our Public
Interest Directorate at [e-mail] or 202-336-6061.
Sincerely,

Jessica Henderson Daniel, Ph.D., ABPP
President

cc:

4

Arthur C. Evans, Jr., Ph. D.
Chief Executive Officer

U.S. Attorney General Jeff Sessions
U.S. Secretary of Homeland Security Kirstjen Nielsen

Rojas-Flores, L., Clements, M., Koo, J. London, J. (2017). Trauma and Psychological Distress in Latino
Citizen Children Following Parental Detention and Deportation. Psychological Trauma: Theory, Research,
Practice, and Policy, Vol 9, No. 3, 352.
5
Suárez-Orozco, C., (2017). Conferring Disadvantage: Behavioral and Developmental Implications for
Children Growing up in the Shadow of Undocumented Immigration Status. Wolters Kluwer Health, Inc.,
426.
6
Mays J. & Stevens M. (2018, June 10). Honduran Man Kills Himself After Being Separated From Family at
U.S. Border, Reports Say. The New York Times. Retrieved from
https://www.nytimes.com/2018/06/10/us/border-patrol-texas-family-separated-suicide.html.

Exhibit 58

1
2
3
4
5
6
7
8
9
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

10
11
12

STATE OF WASHINGTON,

13

Plaintiff,

14
15
16
17

v.

Defendants.
I, Kathleen M. Roche, declare as follows:

19

1.

20

22
23
24
25

DECLARATION OF KATHLEEN
M. ROCHE IN SUPPORT OF THE
STATE OF WASHINGTON

DONALD TRUMP in his official
capacity as President of the United States,
et al.,

18

21

NO.

I am over the age of 18 and have personal knowledge of all of the facts stated

herein.
I.

Background and Qualifications
2.

I am an Associate Professor at Milken Institute School of Public Health at the

George Washington University in Washington, D.C. I have held this position since 2012.
Milken Institute School of Public Health is one of the most preeminent schools of public health

26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

1

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1

in the United States. It is currently ranked by U.S. News & World Report as the 14th best public

2
health graduate program in the United States.
3
4
5
6
7
8
9
10
11
12
13

3.

I work in the Department of Prevention and Community Health, where I teach

several courses on child development and public health including: Child Development and
Public Health, Social Ecology of Child & Adolescent Health, Social and Behavioral
Approaches to Public Health, Social and Behavioral Science Research Methods, and Data
Management and Analysis.
4.

I hold a Bachelor of Arts in Art History from Emory University (1988), a Master

of Social Work from the University of Georgia School of Social Work (1993), and a Doctor of
Philosophy from the Department of Maternal and Child Health at the Johns Hopkins
Bloomberg School of Public Health (1999).
5.

I have held academic positions for over 10 years. Prior to working at Milken

Institute School of Public Health, I was an Associate Professor at Georgia State University in
14
the Department of Sociology (2010-2012) and an Assistant Professor at Johns Hopkins
15
16
17
18
19
20
21
22
23
24
25

Bloomberg School of Public Health in the Department of Population, Family, and
Reproductive Health (2007-2010).
6.

My academic work includes professional editorial board service. I am a

Consulting Editor or Editorial Board member for seven family and social science journals
including the Journal of Marriage and Family, Journal of Research on Adolescence, Journal
of Family Theory and Review, Journal of Youth and Adolescence, Journal of Family
Psychology, Adolescent Research Review, and Applied Developmental Science. I serve as a
reviewer for 14 additional journals.
7.

I am a Regular Member of the Psychosocial Development, Risk, and Prevention

Study Section at the National Institutes of Health. I am also a member of flagship professional
organizations focused on research with youth, including the Society for Research on

26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

2

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
Adolescence and the Society for Research on Child Development; in addition, for several
2
years, I was a member of the National Council on Family Relations.
3
4
5
6
7
8
9
10
11
12
13

8.

I have held several research positions and affiliations during my career. I was

the Director of Research at the Johns Hopkins Leadership in Adolescent Health Training
Program at the Johns Hopkins School of Medicine. I sit on the Senate Research Committee at
The George Washington University and lead the community-engagement research module of
the Clinical and Translational Science Institute at Children’s Hospital in Washington, DC. I
held several research positions at Johns Hopkins Bloomberg School of Public Health.
9.

I have extensive research experience over the past 24 years. I have been the

Principal Investigator or Co-Investigator in at least 15 studies. Many of these are focused on
immigrant communities, U.S. Latino families, adolescent adjustment, or Latino adolescent
health and well-being.
10.

My research program examines parenting influences on the health and well-

14
being of adolescents facing challenges tied to immigration status, neighborhood disadvantage,
15
16
17
18
19
20
21
22
23
24
25

acculturation to the U.S., and/or discrimination. My research is informed by multiple
disciplines: developmental psychology, urban sociology, family social sciences, and social
epidemiology.
11.

I have a high level of expertise in Latino immigrant families, adolescent health

and well-being, and parents raising adolescents in challenging conditions. I have written over
30 peer-reviewed journal articles, most of which relate to these subjects.
12.

My research examining the impacts of recent immigration actions and news on

the lives of U.S. Latino parents has been featured in national media including the NBC Nightly
News, US News & World Report, and Vox.com.
13.

I have attached a true and complete copy of my curriculum vitae as Exhibit A

to this Declaration.

26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

3

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
II.

Impacts of Immigration Actions and News on the Lives of U.S. Latino Families

2
14.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Together with three colleagues, I recently conducted a study on the impacts of

immigration policy changes and news on U.S. Latino families raising adolescent children. We
published our findings in the Journal of Adolescent Health in March 2018. The article is
entitled Impacts of Immigration Actions and News and the Psychological Distress of U.S.
Latino Parents Raising Adolescents, and it is attached as Exhibit B to this Declaration.
15.

My co-authors in this study were Elizabeth Vaquera, Ph.D (Department of

Sociology and Department of Public Policy & Public Administration, The George Washington
University); Rebecca M.B. White, Ph.D (T. Denny Sanford School of Social and Family
Dynamics, Arizona State University); and Maria Ivonne Rivera, M.P.H. (The Rivera Group,
Washington, D.C.).
16.

Our study is one of the first empirical accounts of how recent immigration

policy changes and news about those changes have impacted U.S. Latino parents—and by
extension their teenage children. The study evaluated parents’ behavioral and emotional
responses to recent immigration actions and news and investigated how these responses are
associated with Latino parents’ psychological distress. It provides some of the first evidence
to date indicating how U.S. Latino parents of adolescents cope, react, and manage emotions in
response to immigration news and actions.
17.

We began our analysis by recruiting 213 Latino (mostly Central American)

parents of adolescents from a suburb of a large mid-Atlantic city. One-third of the parents in
the study were undocumented. The remaining two-thirds were living in the U.S. legally, as
citizens, permanent residents, or under Temporary Protected Status (TPS). Virtually all of the
Latino adolescents whose parents were in this study were U.S. citizens, protected under the
Deferred Action for Childhood Arrivals (DACA) program, or eligible for DACA.

25
26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

4

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
18.

We asked these parents a series of questions to find out how U.S. immigration

2
actions and news had affected them in recent months. In addition, we used a standard
3
4
5
6
7
8
9
10
11
12
13

questionnaire to assess symptoms of depression, anxiety, and other mental health problems.
19.

We collected these surveys in the fall of 2017. Numerous immigration policy

changes took place before, during, and immediately after our collection, including: (1)
expanded eligibility for deportation, (2) the elimination of and/or plans to eliminate TPS, and
(3) an end to DACA.
20.

The results of our study strongly suggest that the recent changes in U.S.

immigration policy have triggered serious psychological distress for many Latino parents,
including those living in the United States legally.
21.

Parents in all residency statuses reported that they “very often” or “almost

always/always” experience adverse emotional and behavioral consequences due to
immigration actions and news (See Table 2 in Exhibit B). These consequences include:

14
difficulty getting or keeping a job; difficulty imagining a better job or more money; worrying
15
16
17
18
19
20
21
22
23
24
25

it will be hard for their child to get a job; warning their child to stay away from authorities;
worrying family members will be separated; changing daily routines; avoiding medical care,
police, and services; feeling that their child was negatively affected; worrying it will be hard
for their child to finish school; feeling that the parent was negatively affected; worrying about
contact with police, authorities; talking to their child about changing their behavior such as
where they hang out; and perceiving that their child was affected at school.
22.

Although TPS parents were more likely than other groups to report concerns

about safety and well-being of the family and children, substantial proportions of
undocumented, permanent resident, and U.S. citizen parents reported these same concerns.
23.

A high proportion of the parents (nearly 66%) reported that they very often or

always worried about family members getting separated because of immigration actions or

26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

5

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
news. This included 88% of undocumented parents, 83.8% of TPS parents, 57.1% of
2
permanent resident parents, and 21.6% of U.S. citizen parents.
3
4
5
6
7
8
9
10
11
12
13

24.

A substantial proportion of the parents (nearly 40%) reported that they

frequently avoided getting medical care, help from police, or support from social services
because of immigration actions and news. This included 42% of undocumented parents, 62.2%
of TPS parents, 34.3% of permanent resident parents, and 21.6% of U.S. citizen parents.
25.

Almost half of all parents in this study reported that recent immigration events

had led them to very often or always warn their teenagers to stay away from authorities (nearly
48%) and to talk to their teenagers about changing their behaviors, such as where they hang
out (nearly 47%).
26.

Almost half of all parents in this study reported that their child had been

negatively affected (44%) or that a parent had been negatively affected by immigration actions
and news (nearly 45.2%).
14
27.
15
16
17
18
19
20
21
22
23
24

Almost half of all parents in this study reported that, as a result of the

immigration actions and news, they were worried that it would be hard for their child to finish
school (46%) and they worried about their child getting a job (46.2%), and a substantial
proportion reported that their child had been affected at school (nearly 37%).
28.

Among parents who are not U.S. citizens, more than half (54.3%) moved to the

United States in order to escape gangs and violence in their country of origin.
29.

Extensive research has described stressors experienced by U.S. Latinos,

including fear of deportation, exploitation by employers, trauma, distrust in public services,
language barriers, racism, and financial strain. (See, e.g., Cavazos-Rehg et al., 2007; Rhodes
et al., 2015; Yoshikawa et al., 2011). These stressors are important predictors of psychological
distress, indicated by anxiety, depression, and somatization.

25
26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

6

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
30.

In our study, we documented substantially higher levels of psychological stress

2
among U.S. Latino parents who do not have citizenship status. High distress characterized
3
4
5
6
7
8
9
10
11
12
13

48.6% of TPS parents; 23.2% of undocumented parents; 27.1% of permanent resident parents;
and 8.1% of U.S. citizen parents.
31.

Parents’ adverse responses to immigration changes were associated with a

significantly higher odds of a parent reporting high psychological distress. Parents who
reported that immigration events caused them to frequently worry about their youth’s
education or future job chances or about family members being separated had at least a 200%
greater odds of reporting high psychological distress.
32.

In several instances, adverse immigration responses were associated with a 5-

to 10-fold greater odds of a parent reporting high psychological distress. The responses
associated with these high odds of psychological distress included a parent having: been
stopped, questioned or harassed by immigration authorities; avoided seeking medical care or
14
assistance from police and government services; talked to their child about changing behaviors
15
16
17
18
19
20
21
22
23
24
25

such as where the child hangs out; felt negatively affected; believed that their children had
been negatively affected; expected that their children would now have a hard time finishing
school; and thought that their children had been affected at school.
33.

Based on our study, we concluded that contemporary immigration actions and

news about those actions likely have had profound and far-reaching adverse impacts on U.S.
Latino parents raising adolescents.
34.

The study shows that the pernicious and harmful impacts of immigration

actions and news may extend to Latino parents across a hierarchy of residency statuses.
Parental worries and behavior modifications tied to immigration actions and news were shown
to exist even among U.S. citizens of Latino origin. Across noncitizen groups, especially those
with TPS, the effects were most prevalent, with parents experiencing concern for family, as

26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

7

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
indicated by parents warning their children to avoid authorities; avoiding medical care, public
2
assistance, or the police; and worrying that their children had been negatively affected at school
3
4
5
6
7
8
9
10
11
12
13

due to immigration actions and news.
35.

Permanent resident parents were no different than undocumented parents with

respect to several adverse responses to immigration actions and news. These two groups of
parents were similar with respect to having frequently talked to their children about changing
behaviors such as where the child hangs out; worried about contact with police and authorities;
felt that the child was negatively affected at school; avoided seeking medical care, help from
the police, and public services; changed daily routines; and, warned children to stay away from
authorities.
36.

Evidence suggesting adverse consequences of immigration actions and news

across residency statuses is consistent with research indicating that immigration policy can be
equally harmful to documented and undocumented Latinos. Our study showed that TPS
14
parents, and in many cases, permanent resident parents, were harmed by immigration events,
15
16
17
18
19
20
21
22
23
24
25

as were undocumented parents.
37.

A substantial proportion of non-U.S. citizen parents frequently engaged in

behaviors designed to avoid the attention of government authorities. These parental responses
align with prior research indicating that Latino immigrants often hesitate contacting police for
fear of mistreatment and/or the deportation of another family member.
38.

Regardless of residency status, our study also found that a proportion of Latino

parents (approximately 15% to 18%) reported that they “very often” or “always” considered
leaving the United States and/or were stopped, harassed, or questioned by immigration
authorities. These findings support the conclusion drawn by University of California Prof.
Enriquez that “sanctions intended for undocumented immigrants seeped into the lives of
individuals who should have been protected by their citizenship status.” (Enriquez, 2015).

26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

8

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
39.

Such high levels of distress among parents raise concerns about immigration

2
impacts on the entire family, including among teenagers. Previous research suggests that a
3
4
5
6
7
8
9
10
11
12
13

parent’s fear, anxiety or depression can spill over to affect the entire family, and especially
teenagers. Studies show that adolescents whose parents are anxious or depressed are at elevated
risk of doing poorly in school, adopting risky behaviors, and developing lifelong health and
mental health problems. (See, e.g., Wheeler et al., 2015; McAdams et al., 2015; Lieb et al.,
2002). Thus, the costs and burdens of psychological distress extend far beyond an affected
individual.
40.

Our research demonstrated that almost two-thirds of parents frequently worried

about family separation and close to half frequently warned their adolescent children to stay
away from authorities, talked to their children about changing behaviors such as where they
hang out, and avoided access to medical care, police, and public assistance. These kinds of
parent behaviors and parents’ psychological distress directly threaten adolescent youth’s safety

14
and mental and physical health
15
16
17
18
19
20
21
22
23
24

41.

The vast majority (75%) of parents in this study had adolescents who were U.S.

citizens. The findings show that even Latino adolescents who are citizens and/or have grown
up in the United States and are here legally, likely experience increased and serious risks to
their health and well-being as a result of immigration actions and news.
42.

Our study demonstrates that immigration threats can have significant and

measurable impacts well beyond the acute harm conferred to the subset of Latinos directly
experiencing the events and impacted by the particular immigration policies and actions. This
likely is because politics, threats of deportation, and anti-immigrant sentiments lead to
widespread fear and anxiety among Latinos, even those not directly affected by the event. This
holds true for Latinos of all residency statuses.

25
26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

9

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

1
III.

The Likely Impacts of the Family Separation Policy

2
43.
3
4
5
6
7
8
9
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The following opinions and testimony about the likely impacts of the family

separation policy are based upon my education, experience, research and scholarship, and my
expertise in Latino immigrant families in the U.S., and are offered on a more probable than not
basis.
44.

As indicated above, in paragraph 23, our study on the impact of immigration

actions and news revealed that 66% of the U.S. Latino parents surveyed reported that they
“very often” or “always” feel worried about family separation. This included 88% of
undocumented parents, 83.8% of TPS parents, 57.1% of permanent resident parents, and
21.6% of U.S. citizen parents.
45.

Notably, our study occurred prior to the U.S. government’s immigration policy

implementing family separation. It is likely that the fears of U.S. Latino parents about family
separation will be more widespread and will have increased substantially as a result of the
14
family separation policy. This is especially true considering the extensive media coverage and
15
16
17
18
19
20
21
22
23
24
25

public debate that the family separation policy has generated.
46.

Our study found that the odds of parents’ high psychological distress are 250%

greater for parents who frequently worry that family members would get separated. As a result
of the family separation policy, and the likely more widespread and increased levels of fear, it
is likely that there is also a significant increase in the number of U.S. Latino parents
experiencing high levels of psychological distress and harm, which impacts them and adversely
impacts their adolescent children.
47.

As our study also reveals, immigration policies that are focused on a small

segment of the population have cascading negative impacts across much larger groups by
virtue of the fear that these policies are shown to instill. It is likely the family separation policy
is causing high levels of psychological distress and harm to those directly impacted with

26

DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

10

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

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Declaration References
Cavazos-Rehg PA, Zayas LH, Spitznagel EL. Legal status, emotional well-being and
subjective health status of Latino immigrants. J Natl Med Assoc 2007;99:1126-1131.
Enriquez LM. Multigenerational punishment: Shared experiences of undocumented
immigration status within mixed-status families. J Marriage Fam 2015;77:939-953.
Lieb R, Isensee B, Hofler M, Pfister H, Wittchen HU. Parental major depression and the risk of
depression and other mental disorders in offspring: A prospective-longitudinal community
study. Arch Gen Psychiatry. 2002;59(4):365-374.
McAdams T, Rijsdijk F, Neiderhiser J, Narusyte J, Shaw D, Natsuaki M,…Eley T. (). The
relationship between parental depressive symptoms and offspring psychopathology: Evidence
from a children-of-twins study and an adoption study. Psychol Med. 2015;45(12), 2583-2594.
Rhodes SD, Mann L, Simán FM, et al. The impact of local immigration enforcement policies
on the health of immigrant Hispanics/Latinos in the United States. Am J Public Health
2015;105:329-337.
Wheeler LA, Updegraff KA, Crouter A. Mexican-Origin Parents’ Work Conditions and
Adolescents’ Adjustment. Journal of family psychology : JFP : journal of the Division of
Family Psychology of the American Psychological Association (Division 43). 2015;29(3):447457. doi:10.1037/fam0000085.
Yoshikawa H, Kalil A. The effects of parental undocumented status on the developmental
contexts of young children in immigrant families. Child Dev Perspect 2011;5:291-297.

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DECLARATION OF KATHLEEN M.
ROCHE IN SUPPORT OF THE STATE
OF WASHINGTON

12

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue. Suite 2000
Seattle, WA 98104-3188
[phone]

Exhibit A

1

Kathleen M. Roche
Personal Data
Work address:
Department of Prevention & Community Health
Milken Institute School of Public Health
The George Washington University
950 New Hampshire Avenue, Suite 300
Washington, DC 20052
[phone] [e-mail]
Education and Training
1988
1993
1999

Bachelor of Arts, Major: Art History, Emory University.
Master of Social Work, The University of Georgia School of Social Work.
Doctor of Philosophy, Department of Maternal and Child Health,
Johns Hopkins Bloomberg School of Public Health.

Professional Experience
07/12 – present Associate Professor
George Washington University,
Department of Prevention & Community Health, Washington, DC
07/10 – 07/12

Associate Professor
Georgia State University, Department of Sociology, Atlanta, GA

07/07 – 06/10

Assistant Professor
Johns Hopkins Bloomberg School of Public Health,
Department of Population, Family, and Reproductive Health, Baltimore, MD
Director of Research, Johns Hopkins Leadership in Adolescent Health
Training Program (Bureau of Maternal & Child Health, P.I: H. Adger),
Johns Hopkins School of Medicine, Baltimore, MD

04/03 – 06/07

Assistant Scientist
Johns Hopkins Bloomberg School of Public Health,
Department of Population and Family Health Sciences, Baltimore, MD

04/99 – 03/03

Research Associate
Johns Hopkins Bloomberg School of Public Health,
Department of Population and Family Health Sciences, Baltimore, MD.

2

10/98 – 03/99

Research Analyst
Johns Hopkins University Center for Adolescent Health Promotion and
Disease Prevention, Baltimore, MD. Research design, implementation, data
analysis, and production of papers/presentations related to study of
neighborhood and family influences on adolescent substance use, delinquency,
and aggression.

Research Grant Participation
Principal Investigator: “Linking Community and Family Characteristics to Adolescent
Adjustment,” NICHD, National Institutes of Health. September 1, 2017 – August 31, 2022.
Total: $2,687,934 (directs: $2,037,529).
• Using eight time points of data for a representative sample of 600 Latino parent-youth
dyads in an emerging immigrant destination, this study will test an integrative theoretical
model specifying the cascade of effects from cultural demands and opportunities in
neighborhoods to adolescent externalizing and internalizing problems.
Co-Investigator: “Clinical and Translational Science Institute at Children’s National,” NIH,
National Center for Advancing Translational Sciences. July 1, 2016 – June 30, 2021. Total:
$22,021,067.
• The primary goal is to provide integrated, cost-effective, investigator-focused resources
that overcome research barriers, promote collaborative research, and provide research
training with a focus on children’s health. With an emphasis on health disparities and
childhood antecedents to adult diseases, CTSI-CN builds upon its pediatric research
strengths in areas such as rare diseases, asthma, and neuro-developmental disabilities to
collaborate with a national network of 1,200 community health centers.
Principal Investigator: “The US Immigrant Political Climate and US Latino Families: A Mixed
Methods Study,” Cross-Disciplinary Research Program, The George Washington University.
July 1, 2017 – June 30, 2018. $35,756.
• Exploratory study to identify impacts of immigration policy changes on US Latino
parents.
Past:
Co-Investigator: “Evaluation of the D.C. Healthy Schools Act of 2010”(Subcontract PI: O.A.
Price). Response to RQ883706, Office of the State Superindendent of Education. October 1,
2015 – September 30, 2016. $81,402.
To evaluate the D.C. Healthy Schools Act of 2010.
Principal Investigator: “Acculturation-Related Parenting Risks for Latino Adolescent Substance
Use,” Springboard Grants Program, Milken Institute School of Public Health, The George
Washington University. July 1, 2014 – June 30, 2015. $50,000.
Pilot study used to inform R01 proposal development for application to NIDA, October
2015.
Co-Investigator “Prevention at Home: A Model for Novel use of Mobile Technologies and

3
Integrated Care Systems to Improve HIV Prevention and Care While Lowering Cost,” Centers
for Medicare and Medicaid Services. PI: F. Speilberg. September 1, 2014 – December 31, 2015.
$23,808,617.
To utilize mobile technologies and optimize the prevention and care continuum for HIV+
individuals in Washington D.C.
Co-Investigator: “Prince Georges County School Health Needs Assessment.” Prince Georges
County Public Schools. June 1, 2014 – August 31, 2014. PI: O. Price. $24,999.
Identify health problems and health care needs of students and staff in Prince Georges county
public schools with the aim of improving school health services.
Co-Investigator: “Managing Chronic Stress in Urban Minority Youth.” American Public Health
Association. June 1, 2014 – September 30, 2014. PI: O. Price. $25,000.
Phase I of project to assist school-based health center providers in more effectively helping
low-income, urban minority youth cope with chronic and multiple daily stressors in an effort
to prevent school dropout. This pilot phase of the project will inform Phase II, which will
follow to expand the scope of work.
Principal Investigator: “Acculturation and youth's longitudinal adjustment in MexicanAmerican families,” HRSA 09-001 (MCH Research Program, Secondary Analysis).
Maternal and Child Health Bureau. February 1, 2010 – January 31, 2012. $100,000
Examines acculturation effects on adolescent mental health and school attainment for 749
Mexican-origin youth of immigrant parents followed over three time points in adolescence
and young adulthood. Using SEM techniques, the study identified 1) bicultural orientations
in multiple acculturation domains and 2) effects of a parent-youth acculturation gap on
parent-youth conflict and youth adjustment. Data derive from the Children of Immigrants
Longitudinal Study.
Principal Investigator: “The Latino Youth and Family Study,” Georgia State University
Research Initiation Grant. July 1, 2011 – June 31, 2012. $10,000.
In this mixed-methods pilot study, focus groups are being conducted with Latino/a immigrant
parents and adolescents to explore themes pertinent to parent-adolescent relationships and
parenting with respect to developmental transitions through adolescence. Subsequent to
these, school-based surveys with 120 adolescents and 30 parents of youth are being used to
test psychometric properties of parenting measures that have been adapted to be culturally
appropriate for Atlanta’s immigrant Latino population. Findings will inform proposal
development on the topic of Latino adolescent health and well being.
Co-Investigator: “Cultural and contextual variability in parenting impacts on adolescent
adjustment”(P.I.: L. Franzini). HRSA 09—001 (MCH Research Program). Maternal and
Child Health Bureau. February 1, 2009 – January 31, 2012. $810,000.
Drawing from theoretical frameworks specific to the development of ethnic minority youth
and to neighborhood effects, the present study aims to identify universal, context-specific,
and culture-specific parenting values, practices and styles associated with health trajectories
from early to late adolescence among low-income, urban Latino and African American
youth. The study builds on Healthy Passages, a cohort study of 5th graders living in an urban
Southwestern city who were interviewed in 5th and 7th grades. The proposed study will

4
collect data in 10th grade to test hypotheses regarding multi-level pathways to adolescent
depressive symptoms, school engagement, and delinquent behaviors.
Co-Principal Investigator: “How parenting modifies neighborhood risks related to low-income
children’s health,” (P.I: T. Leventhal). Maternal and Child Health Bureau, January 1, 2007 –
December 31, 2007 $100,000.
Multi-level analyses of three time points of data on over 2,000 low-income
participants in “Welfare, Children and Families: A Three City Study” will explore
modifying influences of parenting on associations between neighborhood context and
child health and health-related behaviors. Developmental variations in these
associations from early childhood to late adolescence will be considered.
Co-Principal Investigator: “Parental influences on adolescent sexual risk,” (PI: R.
Blum). Office of Population Affairs, April 1, 2005 – March 31, 2007, $357,584
Using data from “The National Longitudinal Study of Adolescent Health,” and
“Welfare, Children and Families: A Three City Study” this proposed study examines
direct and indirect effects of family social processes on youths’ sexual risk behaviors
from early adolescence into emerging adulthood.
Principal Investigator: “The experience of parenting within a Central American
immigrant community,” Faculty Development Award, Department of Population and
Family Health Sciences, Johns Hopkins Bloomberg School of Public Health, December
1, 2005 – December 31, 2006, $20,000.
Through the development of partnerships with community-based organizations,
qualitative data from 30 in-depth interviews and two follow-up focus groups with
mothers of young Central American immigrant adolescents will be collected and
analyzed. The study aims to understand the experience of parenting among Central
American immigrant mothers living in a low-income immigrant community.
Co-Investigator: “Neighborhood and Family Effects on Adolescent Health Behaviors” (P.I.: C.
Alexander), Maternal and Child Health Bureau, 08/30/98 – 07/31/02, $443,670.
To understand how neighborhood and family social contexts influence adolescent
delinquency, aggression, and early sex initiation. The study includes an analysis of national
data (The National Longitudinal Study of Adolescent Health) and the collection and analysis
of qualitative and quantitative data on families living in three Baltimore City neighborhoods
with varying rates of juvenile arrests for violent crimes.
Principal Investigator: Johns Hopkins Center for Adolescent Health Development Award,
“Neighborhood characteristics and social capital: Influences on the association between
parenting and fighting and delinquency among adolescent males,” 1997 – 1998, $10,000.
Using data from the National Longitudinal Study of Adolescent Health, this study examined
how neighborhood attributes and social capital modified associations between parenting and
delinquency and aggression among adolescent males.
Principal Investigator: Doctoral Dissertation Grant, Johns Hopkins University Center for Injury
Research and Policy, 1997 – 1998
Principal Investigator: Doctoral Training Fellowship, Johns Hopkins Bloomberg School of
Public Health, Department of Maternal and Child Health, 1994 – 1998

5

Honors and Awards
Delta Omega, The Public Health Honorary Society, Alpha Chapter.
Child Health Leader, University of Rochester (October 1999, Rochester, NY; October 2001,
Chicago, IL). One of 50 early career academics selected for program linking researchers
with representatives from government, child advocacy, and national foundations to
encourage an interdisciplinary approach to shaping the research and policy agenda for
children’s health and well being (Director: M. Weitzman).
The Donald A. Cornely Scholarship Award - Johns Hopkins Bloomberg School of Public Health,
Department of Maternal and Child Health, 1996 – 1997
Peer Review Publications (*graduate student co-author)
1. Roche, K. M., Vaquera, E., White, R. B. M., & Rivera, M. I. (2018). Impacts of
immigration actions and news and the psychological distress of U.S. Latino parents raising
adolescents. Journal of Adolescent Health, 62, 525 – 531.
2. Roche, K. M., Little, T. D., Ghazarian, S. R., Lambert, S. F., Calzada, E. J. & Schulenberg,
J. (2018). Parenting processes and adolescent adjustment in immigrant Latino families: The
use of residual centering to address the multicollinearity problem. Journal of Latino/a
Psychology, early view available online February 22.
3. Nair, R., Roche, K. M. & White, R. B. M. (2018). Acculturation gap distress among Latino
youth: Prospective links to family processes and youth depressive symptoms, alcohol use,
and academic performance. Journal of Youth & Adolescence, 47, 105-120.
4. Meyer, K.*, Roche, K. M. (2017). Sport-for-development gender equality impacts from
basketball program: Shifts in attitudes and stereotyping in Senegalese youth and coaches.
Journal of Sport for Development, 5, 49 – 57.
5. Roche, K. M., Calzada, E. J., Ghazarian, S. R., Little, T. D., Lambert, S. F. & Schulenberg,
J. (2017). Longitudinal pathways to educational attainment for youth in Mexican and Central
American immigrant families. Journal of Latino/a Psychology, 5, 12 – 26.
6. Bingenheimer, J. B., Roche, K. M., & Blake, S. (2017). Family adult awareness of
adolescents’ premarital romantic and sexual relationships in Ghana. Youth & Society, 49,
341-368.
7. Roche, K. M., Bingenheimer, J. B. & Ghazarian, S. R. (2016). The dynamic interdependence
between family support and depressive symptoms among adolescents in Ghana. International
Journal of Public Health. 61, 487 - 494.
8. Little, T. D., Roche, K. M., Chow, S., Schenck, A. P. & Byam, L. (2016). National Institutes
of Health Pathways to Prevention Workshop: Advancing research to prevent youth suicide.
Annals of Internal Medicine, 165, 795-799.
9. Lambert, S. F., Roche, K. M., Saleem, F. T. & Henry, J. S. (2015). Mother-adolescent
relationship quality as a moderator of associations between racial socialization and
adolescent psychological adjustment. American Journal of Orthopsychiatry, 85, 409 - 420.
10. Roche, K. M., Lambert, S. F., Ghazarian, S. R. & Little, T. D. (2015). Latino youth’s
language brokering across contexts: Associations with parenting and parent-child
relationships in a new immigrant destination area. Journal of Youth and Adolescence, 44, 77
– 89.

6
11. Roche, K. M., Caughy, M. O., Schuster, M. A., Bogart, L. M., Dittus, P. J. & Franzini, L.
(2014). Cultural orientations, parental beliefs and practices, and Latino youth’s autonomy
and independence. Journal of Youth and Adolescence, 43, 1389 – 1403.
12. Roche, K. M., Ghazarian, S. R., Fernandez-Esquer, M. E. (2012). Unpacking acculturation:
Cultural orientations and educational attainment among Mexican-origin youth. Journal of
Youth and Adolescence, 41, 920 – 931.
13. Murray, K. W., Bair-Merritt, M., Roche, K. M. & Cheng, T. (2012). The impact of intimate
partner violence on mothers’ parenting practices for low-income adolescents. Journal of
Family Violence, 27, 573 – 583.
14. Roche, K. M. & Ghazarian, S. R. (2012). The value of family routines for the academic
success of vulnerable adolescents. Journal of Family Issues, 33, 874 – 897.
15. Roche, K. M., Ghazarian, S. R., Little, T, & Leventhal, T. (2010). Understanding links
between punitive discipline and adolescent adjustment: The relevance of context and
reciprocal associations. Journal of Research on Adolescence, 21, 448 – 460.
16. Ghazarian, S. R. & Roche, K. M. (2010). Social support and low-income, urban mothers:
Longitudinal associations with adolescent delinquency. Journal of Youth & Adolescence, 39,
1097 – 1109.
17. Roche, K. M. & Leventhal, T. (2009). Beyond neighborhood poverty: Family management,
neighborhood disorder, and adolescents' early sexual onset. Journal of Family Psychology,
23, 819 – 827.
18. *Ries A. V., Voorhees C. C., Roche K. M., Gittelsohn J., Yan A. F., & Astone N. M.
(2009). A quantitative examination of park characteristics related to park use and physical
activity among urban youth. Journal of Adolescent Health, 45, S64-S70.
19. Mmari, K., Roche, K. M., *Sudhinaraset, M., & Blum, R. W. (2009). When a parent goes
off to war: Understanding impacts on adolescents and their families. Youth & Society, 40,
455 - 475.
20. *Ries, A.V., Gittelsohn, J., Voorhees, C.C., Roche, K. M., Clifton, K.J., & Astone, N. M.
(2008). The environment and urban adolescents’ use of recreational facilities for physical
activity: A qualitative study. American Journal of Health Promotion 23, 43-50.
21. Roche, K. M., Ahmed, S., & Blum, R. W. (2008). The enduring consequences of parenting
for risk behaviors from adolescence into early adulthood. Social Science and Medicine, 66,
2023 - 2034.
22. *Ries, A.V., Voorhees, C. C., Gittelsohn, J., Roche, K. M. & Astone, N. M. (2008).
Adolescents' perceptions of environmental influences on physical activity. American Journal
of Health Behavior, 32, 26 - 39.
23. Trent, M., Clum, G., & Roche, K. M. (2007). Sexual victimization and reproductive health
outcomes in urban youth. Ambulatory Pediatrics, 7, 313 - 316.
24. Roche, K. M., Ensminger, M. E., & Cherlin, A. J. (2007). Variations in parenting and
adolescent outcomes among African American and Latino families living in low-income,
urban areas. Journal of Family Issues, 28, 882 - 909.
25. Roche, K. M., Astone, N. M., & Bishai, D. (2007). Caring for young adolescents during outof-school hours: Impact on problem behaviors among youth in low-income, urban areas.
Journal of Family and Economic Issues, 28, 471 - 488.

7
26. Roche, K. M., Ensminger, M. E., Ialongo, N., Poduska, J., & Kellam, S. (2006). Early
entries into adult roles: Associations with aggressive behavior from adolescence into young
adulthood. Youth & Society, 38, 236 - 261.
27. Roche, K. M., Mekos, D., Alexander, C. S., Astone, N. M., Bandeen-Roche, K., &
Ensminger, M. E. (2005). Parenting influences on early sex initiation among adolescents:
How neighborhood matters. Journal of Family Issues, 26, 32 - 54.
28. Roche, K. M., Ellen, J., & Astone, N. M. (2005). Effects of out-of-school care on early sex
initiation in low-income, central city neighborhoods. Archives of Pediatrics and Adolescent
Medicine, 159, 68 - 73.
29. Roche, K. M., Ensminger, M. E., Chilcoat, H. & Storr, C. (2003). Establishing
independence in low-income urban areas: The relationship to adolescent aggressive behavior.
Journal of Marriage and Family 65 (3), 668 - 680.
30. Roche K. M., Webster, D., Alexander, C. S., & Ensminger, M. E. (2003). Neighborhood
variations in the salience of family support to boys’ fighting. Adolescent and Family Health
3 (2), 55 - 64.
31. Gittelsohn, J., Roche, K. M., Alexander, C. S., & Tassler, P. (2001). The social context of
smoking among African American and White adolescents in Baltimore City. Ethnicity and
Health 6, 211-225.
Non-peer reviewed reports
Biehl, M., Acosta Price, O., Roche, K. M., Spielberg, F. & Bhattacharajee, A. (2014).
“Improving School Health and Wellness in Prince George’s County Public Schools,
Maryland: A Needs Assessment.”
Blum, R., Roche, K. M., & Blum, L. M. (2004). “School connectedness: Effective strategies and
promising approaches.”
Georgia Kids Count Fact Book, 1993. Georgians for Children: Atlanta, GA.
Georgia Kids Count Fact Book, 1992. Georgians for Children: Atlanta, GA.
Invited Presentation:
Structural Equation Modeling & Theory Testing: An Overview and Application to the Study of
Culture and Parenting for Latino Immigrant Families. Wednesday Noon Seminar Series,
February 5, 2014. Johns Hopkins Bloomberg School of Public Health.
Invited Conference Participant:
“Cutting the Edge of Research in Adolescent Sexuality: Considering Normative Development
PART II Conference” (April 29 – May 2, 2004, San Francisco, CA). One of 20 researchers
invited to participate in a mini-conference sponsored by the Center for Research on Gender and
Sexuality at San Francisco State University (Director: Deborah Tolman). This network of
researchers is focused on building intellectual and practical bridges among researchers whose
diverse work does or should incorporate the study of adolescent sexuality.
Professional Presentations:

8
Roche, K. M., Vaquera, E., White, R. B. M., & Rivera, M. I. (2018). Impacts of Anti-immigrant
Actions and News on The psychological distress of US Latino Parents Raising Adolescents.
Paper to be presented in the Latino/a Youth and Legal Liminality section, Annual Meeting of the
American Sociological Association, August 11 – 14, Philadelphia, PA.
Roche, K. M., Lambert, S. F., Little, T. D., Calzada, E. J., & Schulenberg, J. & White, R. M. B.
Latent Profile Analysis of Parental Monitoring and Parent-Child Conflict in Latino Immigrant
Families: Impacts on Adolescent Adjustment. Poster presentation April 13, 2018 at the Biennial
Meeting, Society for Research on Adolescence.
Nair, R. N., Roche, K. M., White, R. B. M. (2017). Acculturative Family Distancing Among
Latino Youth: Examining Prospective Links to Family Processes, Depression and Achievement.
Poster presentation in the Race, Ethnicity, Culture and Context section, Biennial Meeting,
Society for Research on Child Development, April 7.
*Martinez, D.J., Turner, M.M., Roche, K.M., & Horn, K.A. (2017). What May Be Associated
with Young Adult E-Cigarette Use? Examination of Key Correlates. Poster Presentation in the
Alcohol, Tobacco, and Other Drugs Section, Student Award Candidate. American Public Health
Association (APHA) Annual Meeting & Expo, Atlanta, GA, Nov. 5-8.
Roche, K. M., Ghazarian, S. R., Little, T. D., Lambert, S. F., Calzada, E. J., & Schulenberg, J.
(2016). Residual-centered Latent Variables to Address the Multicollinearity Problem in
Parenting Research. Session Chair & Paper presented at 2016 Biennial Meeting for Society for
Research on Adolescence, Baltimore, MD, Session Title: “Applying Innovative Analytic
Methods to Advance Knowledge About Parenting Impacts on Adolescent Adjustment.” March
31 – April 2.
Ghazarian, S. R., Roche, K. M., Caughy, M. O. & Franzini, L. (2014). Cultural Value
Differences Among Mexican-American Youth and Parents: Associations With Parent-Youth
Conflict and Youth Depression. Paper presentation for the 2014 Society for Research on Child
Development Special Topic Meeting: New Conceptualizations in the Study of Parenting-AtRisk. San Diego, CA, Session Title: "Parenting in the Context of Socioeconomic Disadvantage
in Mexican American Families Across Developmental Periods” November 13 - 15.
Roche, K.M. Session Chair for Specifying Neighborhood Conditions that Matter for Adolescent
Mental Health and Well-being. Paper Symposium at the 2014 Society for Research on
Adolescence Biennial Meeting, Austin, TX. March 20 – 22.
Roche, K. M., Caughy, M. O., Schuster, M., Bogart, L.M., Wallander, J., Windle, M. &
Franzini, L. (2014). Latino Cultural Orientations and Early Adolescent Adjustment: Pathways to
Parental Behavioral Control in Middle Adolescence. Poster presentation at the 2014 Society for
Research on Adolescence Biennial Meeting, Austin, TX. March 20 – 22.
Roche, K. M., Lambert, S. F., Ghazarian, S. R. (2014). Language Brokering and Parental
Behavioral Control among Latino Youth in a New Immigrant Destination Area. Paper presented
at the 2014 Society for Research on Adolescence Biennial Meeting, Austin, TX. March 20 – 22.

9

Roche, K. M., Caughy, M. O., Schuster, M., Bogart, L.M., Davies, S., Dittus, P. J., & Franzini,
L. (2012). Cultural Orientations and Latino/a Adolescent Autonomy Development. Chair of
session and presenter of paper for the 2012 Society for Research on Adolescence Biennial
Meeting, Vancouver, BC, Canada, Session Title: “Understanding Parenting and Adolescent
Adjustment in Latino/a Families: How Cultural Orientation Matters” March 8 – 10.
Ghazarian, S. R., Roche, K. M., Caughy, M. O., & Franzini, L. (2012). Measurement invariance
for parental autonomy granting constructs among African American, White, and Hispanic
families. Poster session at the 2011 SRCD Themed Meeting: Developmental Methodology.
Tampa, Florida. February 9 - 11.
Roche, K. M., Caughy, M. O., Schuster, M. A., Bogart, L. M., Davies, S., Dittus, P. J. &
Franzini, L. (2011). Cultural Orientations in Latino Families and Maternal Views on Adolescent
Autonomy. Paper presented at 73rd Annual Conference on Family Relations. Orlando, FL,
Session Title: “The Role of Parental Acculturation in the Development of Immigrant Children”
November 15 – 19.
Roche, K. M. & Ghazarian, S. R. (2010). Acculturation and Mexican-Origin Adolescents’
Depressive Symptoms. Paper presented at 72nd Annual Conference of the National Conference
on Family Relations. Minneapolis, MN, Session Title: “Contexts and Pathways to Well-being:
Family Relationships of Latino Youth” November 3 – 6.
Ghazarian, S. R. & Roche, K. M. (2010). Social Network Support and Engaged Parenting in
Low-income Urban Neighborhoods: Longitudinal Associations with Youth Delinquency.
Session Chair & Paper presented at 2010 Biennial Meeting for Society for Research on
Adolescence, Philadelphia, PA, Session Title: “Protective Factors that Matter for the Emotional
and Behavioral Well-being of Adolescents Faced with Neighborhood Challenges” March 11 –
13.
Roche, K. M. & Ghazarian, S. R. (2009). Family routines and adolescent success in the face of
urban poverty. Chair and Paper presented at the 71st Annual Conference of the National Council
on Family Relations. San Francisco, CA, Session Title: “Diversity among Vulnerable Youth: A
Look at Positive Outcomes,” November 11 - 14.
Roche, K. M., Ghazarian, S. R., Leventhal, T., & Little, T. (2008). Reciprocity in parenting and
adolescent adjustment within poor urban neighborhoods. Poster presented at the 70th Annual
Conference of the National Council on Family Relations. Little Rock, AR, November 5 – 8.
*Martinez, C. & Roche, K. M. (2008). Acculturation and marijuana use: Structural influence of
friendship networks on Mexican American youth. Paper presented at 136th American Public
Health Association Annual Meeting. Session Title: “Immigration, Stress and Substance Use
Among Latinos.” San Diego, CA, October 25 – 29.
Roche, K.M. & Leventhal, T. (2008). Parenting in the face of neighborhood risk: Impacts on
adolescent problem behavior. Paper presented at the Society for Research on Adolescence

10
Biennial Meeting. Session Title: “How and When Neighborhoods Matter: Toward an
Understanding of Adolescent Problem Behavior.” Chicago, IL, March 6 – 9.
*Ries, A.V., Gittelsohn, J., Voorhees, C.C., Roche, K., Clifton, K.J., & Astone, N. (2008)
“Environmental factors impacting African American adolescents’ use of recreational facilities: A
qualitative study.” Paper presented at the Robert Wood Johnson Active Living Research
Conference. Washington, DC. April 9-12, 2008.
Roche, K.M. & Leventhal, T. (2007). Parenting and early adolescent sex: Why neighborhood
risk matters. Session Co-Chair and paper at the 69th National Council on Family Relations
Annual Conference, Session Title: “Vulnerable Families: Parenting Adolescents and
Neighborhood Risk.” Pittsburgh, PA, November 7 - 10.
Roche, K. M., Ahmed, S. & Blum, R.W. (2006). Parenting’s enduring consequences from early
adolescence into young adulthood. Paper presentation at the 68th National Council on Family
Relations Annual Conference, Session Title: “Parents and Adolescents,” Research & Theory
Section, Minneapolis, MN, November 8 – 11.
Roche, K. M., Ensminger, M. E., & Cherlin, A. J. (2006). Parenting and adolescent outcomes
among low-income, urban racial/ethnic minority families. Session Chair & paper presentation at
the 2006 Biennial Meeting for the Society for Research on Adolescence, San Francisco, CA,
Session Title: “Variations in Parenting Across Race, Ethnicity and Culture.” March 23 – 26.
*Ries, A.V., Voorhees, C. C., Alexander, C., Gittelsohn, J. & Roche, K. M. (2006).
“Environmental influences on the use of recreation centers and parks for physical activity among
African American adolescents,” Paper presentation at the Robert Wood Johnson Foundation:
Active Living Research Annual Conference, San Diego, CA, February 16 – 18.
Roche, K. M., Ensminger, M. E., & Cherlin, A. J. (2005). Neighborhood variations in parenting
influences on African American youth. Paper presented at the 67th National Council on Family
Relations Annual Conference, Session Title: “Parenting,” Ethnic Minorities & Family Research
& Theory Sections, Phoenix, AZ, November 16 – 20.
Roche, K. M., Mekos, D., Alexander, C. S., & Astone, N. M. (2005). “The simultaneous
influences of neighborhoods and parenting on young adolescents’ initiation of sex.” Paper
presented at the 2005 Society for Research on Child Development Biennial Meeting.
Symposium title: “The Intersection of Neighborhood and Family Influences: Implications for
Youth from Four Longitudinal Studies,” Atlanta, GA, April 7 - 10.
Roche, K. M., Astone, N. M., & Bishai, D. (2004). “Out-of-school care in poor urban areas:
Effects on adolescent behavior.” Paper presented at the 66th National Council on Family
Relations Annual Conference, Session Title: “Transitions in the Lives of Low-Income Families,”
Family Policy Section, Orlando, FL, November 17 – 20.
Trent, M., Clum, G., Poduska, J., Kellam, S., & Roche, K. M. (2005). “Effect of sexual
victimization on reproductive health outcomes in young adults from segregated urban

11
communities.” Paper presented at the 2005 Society for Adolescent Medicine Annual Meeting,
Los Angeles, CA, March 30 – April 2.
Roche, K. M., Jones, A. S., Alexander, C. S., & Sugland, B. (2002). “When families differ from
their neighbors: Influences on adolescent heavy alcohol use.” Poster presented at the 9th Biennial
Meeting of the Society for Research on Adolescence, New Orleans, LA, April 11-14.
Alexander, C. S., Roche, K. M., Bandeen-Roche, K., & Ensminger, M. E. (2002). “Gender
differences in neighborhood and family predictors of early sexual intercourse.” Poster presented
at the 9th Bienniel Meeting of the Society for Research on Adolescence, New Orleans, LA, April
11-14.
Roche, K. M., Webster, D., Alexander, C. S., & Ensminger, M. E. (1999). “Neighborhood
effects on the association between parenting and adolescent fighting.” Paper presented at the
1999 Annual Meeting of the American Sociological Association, Regular Session on Sociology
of Children and Youth, Chicago, IL, August 6-10.
Roche, K. M. & Alexander, C. S. (1998). “Family and neighborhood social processes:
Influences on adolescent violence.” Paper presented at the 126th Annual Meeting of the
American Public Health Association, Session title: “Assessing Adolescent Health Issues,”
Washington, D.C., November 15-18.
University Service
The George Washington University
The George Washington University
Advisory to the Office of the Vice President of Research
Senate Research Committee

2016-17
2016-present

Milken Institute School of Public Health
Research Committee
Conflict of Interest Committee

2013-16
2015-present

Department of Prevention & Community Health
Research Committee
Awards Committee
Faculty Search Committee
Doctoral Advisory Committee

2013-17
2015-17
2014-15; 2017-18
2017 – present

Center Affiliation
Associate, Center on Health and Healthcare in Schools

2013 – present

Georgia State University
Department of Sociology
Chair, Faculty Search Committee
Faculty Search Committee
SOCIOPATH – Department newsletter

2011 – 2012
2010 – 2011
2011 – 2012

12
Outreach Committee
Center Affiliation
GSU Partnership on Urban Health Research
Emory University Center on Injury Control

2011 – 2012
2010 – 2012
2010 – 2012

The Johns Hopkins University
Bloomberg School of Public Health
Committee on Equity, Diversity, and Civility
Student Diversity Advisory Board

2006 – 2009
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Department of Population, Family, and Reproductive Health
Family and Health Working Group
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Doctoral Committee
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Chair, Working Group on Families and Health
Director, Masters in Health Science Program
Committee on Academic Standards
Child Health and Development Track

2006 – 2009
2009 - 2010
2009 – 2010
2007 – 2008
2006 - 2007
2005 – 2007
2006 - 2007
2000-present

Center Affiliation
Population Center
Center for Adolescent Health
Center for the Prevention of Youth Violence

2004 - 2010
1998 – 2006
2001 – 2006

Professional Activities
National Service
Rueben Hill Awards Committee 2008 – 2010
National Council on Family Relations
Social Policy Awards Committee 2011 - 2014
Society for Research on Adolescence
Publications Committee
2014 – present Society for Research on Adolescence
Society Memberships
Society for Research on Adolescence
Society for Research on Child Development
National Council on Family Relations
Community Affiliation
• Co-Lead. Community Engagement Module, CTSI-CN (2016-present), a GWU-Children’s
Hospital partnership aimed at addressing improving the health of children in the DC metro
area
• Center for Trauma and the Community: Family Trauma Research Group (2014 – 2016), a
research collaborative based in the Department of Psychiatry at the Georgetown University
Medical School aimed at using a family approach to addressing child and family trauma.
• Action Langley Park (2007 – 2009) a non-profit organization focused on improving the well
being of primarily Central American immigrants living in Langley Park, Maryland.

13
•

Baltimore City Data Collaborative (2005 – 2007), a collaborative aimed at developing
neighborhood-level indicators useful for the evaluation of campaign to improve the health
and safety of children in Baltimore City.

Professional Service
NIH Peer Review Group / Study Section
10/2018

Regular Member, NIH Psychosocial Development, Risk and Prevention
(PDRP) Study Section (July 2018 - June 2022)

Ad hoc reviewer
06/2018
06/2017
10/2017
06/2017
02/2017

NIH PDRP Study Section, Chicago, IL
NIH Special Emphasis Review Panel, teleconference
NIH PDRP Study Section, Washington, DC
NIH PDRP Study Section, Orlando, FL
NIH PDRP Study Section, Washington, DC

Journal Service:
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2015 – present
2015 – present
2013 – present
2013 – present
2011 – present
2010 – present
2007 – present

Applied Developmental Science
Adolescent Research Review
Journal of Family Psychology
Journal of Youth & Adolescence
Journal of Family Theory and Review
Journal of Research on Adolescence
Journal of Marriage and Family

Reviewer
Journal of the American Medical Association
American Journal of Public Health Association
Child Development
Demography
Cultural Diversity & Ethnic Minority Psychol.
Journal of Family Issues
Journal of Family and Economic Issues

Family Relations
Social Forces
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Youth & Society
Journal of Early Adolescence
Archives of Pediatrics & Adolescent Medicine
Journal of Research in Crime & Delinquency

External Activities/Partnerships
NIH Workshop Panel, “Pathways to Prevention” workshop advancing research to prevent suicide
in youth; Office of Disease Prevention in the Office of the Director, the National Institute
on Mental Health, the National Institute on Drug Abuse, and the National Center for
Complementary and Integrative Health at the National Institutes of Health, March 29 –
31, 2016.

14
Teaching Portfolio
The George Washington University
Advisees
MPH Candidate
Year
Karin Bleeg
2012
Jessica Bress
2012
Margaret Dudley
2012
Vanessa Frontiero
2012
Bo Ra Joo
2012
Devon MacKenzie 2012
Ashley Oberndorfer 2012
Kyonna Moore
2012-14
Sarah Oravecz
2012-13
Kristen Wehling
2012-14
Allison Power
2013-2015
Katherine Meyer
2013-present
Carley Thompson
2012-14
Darien Mather
2014-2015
Brittany Monks
2014-2015
John Fallon
2014-2015
Eileen Doty
2013-14
Brittany Perrotte
2014-present
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Shahina Akter
2013- 2015
Veronique Hionis
2014- 2015
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2014- present
Massomeh Nicoravan 2014- 2015
DrPh Candidate
Amy Gedal Douglass

Samantha Griffin
Alexis Hall
Semira Kassahun
Roushanac Partovi
Lauren Niles
Laura Liles
Denerica Curry
Alexi McHugh
Kiran Edelstein
Kathleen Murphy
Celeste Gee
Valerie Echeveste
Ashley John
Shawn Orenstein
Zareena Kahn
Jaclyn Leiser
Hannah Rothman
Amanda Kimball
Ranjana Kodwani
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Jaclyn Leiser

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2014-2015
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2014-2015
2014-2015
2015
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2015–2017
2015-2017
2015-present
2015-present
2016-present
2017-present
2017-present
2018-present
2017-present
2016-present
2017-present
2017-present

Year
2012-2015

Advisor for Culminating Experience, MPH
Marisa Cordon “Gender differences in how immigration changes are affecting US Latino
parents” 2018
Camilo Alfonso “A cross-sectional study on depression and risk factors for depression among atrisk Latino youth” 2018
Rachel Picard “Policies and procedures for obstetric emergencies” 2018
Katie Meyer “Sports for Development Gender Equality Impacts from Basketball Program: Shifts
in Attitudes and Stereotyping in Senegalese Youth and Coaches” 2016
Roushanac Partovi “Immigrant Parent Stress and Latino Adolescent Depressive Symptoms”
2016
Carley Thompson “Parenting Factors and Reproductive Health among Adolescent Girls in
Ghana” 2014

15
Kyonna Moore “Maternal Mental Health Disorders and Neonatal Birth Outcomes” 2014
Aly Brennan, “The Role of the Father in Early Childhood Mental Health” 2014
Kristen Wheling, “Parental Engagement and Sexual Risk Taking Among Low-Income and
Urban Adolescents: A Secondary Analysis of the Three City Study” 2014
Devon MacKenzie “Promoting Postpartum Family Planning at the Health Facility Level:
Assessment of Jhpiego/MCHIP Country Achievements in Postpartum IUD (PPIUD)
2013 Service Delivery and Secondary Analysis of Factors Associated with PPIUD
Satisfaction and Removal in India”
Karin Bleeg “The characteristics of women seeking funding from the DC Abortion Fund” 2013
Preliminary Oral Dissertation Defense
Amy Gedal Douglass, Department of Prevention & Community Health, DrPh Candidate 2014
Thesis: “Promoting Positive Child Outcomes through Parents: Direct and Indirect Effects
of the Early Head Start Program”
Final Oral Dissertation Defense
Jessica Henry, Department of Psychology, PhD Candidate 2014
Thesis: “Parental racial socialization and adolescent well-being”
Diane Martinez, Department of Prevention & Community Health, DrPH Candidate, 2016.
Thesis: “An Examination of Internal and External Factors Associated with Young Adult
Electronic Cigarette Use and Potential Moderation by User Types”
Amy Gedal Douglass, Department of Prevention & Community Health, DrPh Candidate, 2015.
Thesis: “Promoting Positive Child Outcomes through Parents: Direct and Indirect Effects
of the Early Head Start Program”
Ana Maria del Rio Gonzales, Department of Psychology, PhD Candidate 2015
Thesis: “Sexual Risk Behaviors Among Rural Youth in Colombia: An Application of the
Integrative Model with Emphasis on Social Norms”
Lyzaida Rivera, Department of Psychology, PhD Candidate 2016
Thesis: “Defining the Paternal Role and Understanding the Effects of Paternal Role
Consensus and Maternal Gatekeeping on Father Involvement in Non-cohabiting African
American and Hispanic Adolescent Parents”
Kate Leiberman, Department of Psychology, PhD Candidate 2018
Thesis: “Preventing Perinatal Depression in African American Adolescents”
Classroom Instruction
Practical Data Analysis - MPH@GW

Social & Behavioral Science Research Methods

(12 section)
(12 section)
(12 section)
(12 section)
(12 section)
(10 section)
(4 section)
(22)
(14)

2018, Spring II
2017, Fall
2016, Fall
2016, Spring II
2015, Fall
2015, Spring II
2014, Fall
2018, Spring
2016, Spring

16

Culminating Experience Part I & II - MPH@GW
Child Development & Public Health
Social & Behavioral Approaches to Public Health
Social Ecology of Child & Adolescent Health

(10)
(10 section)
(10 section)
(10, section)
(9)
(19)
(20)
(33)
(85)
(10)

2015, Spring
2016, Summer - Fall
2015, Spring I - Spring II
2015-16, Fall - Spring
2014, Fall
2012, Fall
2013, Fall
2013, Spring
2013, Summer
2014, Spring

Guest Lectures
Introduction to Maternal and Child Health:
“Adolescent Development”
“Social Contexts of Adolescent Health”
Promotion of Mental Health:
“Adolescent Mental Health”
Adolescent Health:
“Social Ecology of Adolescent Health”
Doctoral Research Methods III:
“Missing Data: Introduction & Overview
Doctoral Seminar - Foundations
“Social & Behavioral Determinants of Health”

2013 – 2015
2017
2013 - 2014
2013 - 2014
2013
2014, 2016

Georgia State University
Preliminary Oral Defense
Jessica Thomason, Community Psychology PhD Candidate 2011
“A mixed-methods approach to evaluating the delivery of sexuality education in a youth
development context”
Kelsey Schwartz, MA Sociology Candidate 2011
“Parent-teen sex communication and acculturation among Latino Families”
Final Oral Defense
Jessica Thomason, Community Psychology PhD Candidate 2013
“An evaluation of the delivery of sexuality education in a youth development context”
Kelsey Schwartz, MA Sociology Candidate 2011
“Parent-teen sex communication and acculturation among Latino Families”
Classroom Instruction
Social Research Methods, Sociology

(25)
(25)

2011, Spring & Fall
2012, Spring

17
Johns Hopkins Bloomberg School of Public Health
Advisees
MPH/MHS candidate
Tiffany Riser
Frances Hsieh
Jessica R. Carda
Jessica Donaldson
Kristen Smith

2009
2008
2008 - 09
2006 - 07
2006 - 08

PhD candidate
Craig Martinez
Neetu John
Katherine Vassos

2004 –09
2009
2006

Postdoctoral fellow
Sharon R. Ghazarian 2008 - 10
PhD - Department of Human Development & Family Studies, University of North
Carolina, Greensboro.
Shalon Irving
2009 - 11
PhD – Department of Sociology, Purdue University, Purdue, Illinois
Advisor for Capstone Project, MPH
Frances Hseih, “Enhancing HPV vaccination for adolescents in the US,” 2010
Finbar Foley, “Maternal Stress Impacts on BMI among Low-Income Children,” 2009
Tara Loyd, “An Unprecedented Loss of Parents: The impact of HIV/AIDS on vulnerable
children, families, and communities in rural Lesotho,” 2008
Kristen Smith, “Buffalo Public School District Wellness Policy Proposal,” 2008
Jessica Carda, “Prevention of Teen Dating Violence Victimization: Bridging the
Gap between Research and Policy,” 2009
Preliminary Oral Defense
Nanlesta Pilgrim, PhD Candidate 2009
“The Effects of Family Environment on Sexual Vulnerability & HIV Sexual Risk
Behavior on Ugandan Females, ages 15-19”
Katherine Vassos, PhD Candidate 2008
“Understanding Young Women’s Sexual Relationships and Perceived Risk of HIV in
Northern Namibia”
Renata Hilson, PhD Candidate 2008
“Neighborhood hazards and depression and anxiety symptoms among older adults in
Baltimore City”
Beth Marshall, DrPh Candidate 2008
“Turning the Corner Achievement Program evaluation proposal”
Keri L. Jowers, PhD Candidate 2008
“Examining familial risk for the development of aggressive behavior during childhood”
Craig Martinez, PhD Candidate 2007

18
“Acculturation, gender and friend networks: Alcohol use among Mexican American
youth”
Lydia Isaac, PhD Candidate 2007
“What is the effect of the social and physical environment on racial and socioeconomic
disparities in cardiovascular disease risk?”
Amy Vastine Reis, PhD Candidate 2005
“Environmental influences on physical activity among urban African American youth”
Jessica Miller Rath, PhD Candidate 2004
“What does parental academic involvement have to do with adolescent health?”
Richelle deMayo, PhD Candidate 2004
“Adolescent health literacy assessment”
Gwendolyn Bergen, PhD Candidate 2004
“How do zero tolerance laws act to lower adolescent driving after drinking?”
JoAnn Binko, PhD Candidate 2003
“Behavior change during adolescence: Toward a new understanding of adolescent girls”
Anita Chandra, DrPh Candidate 2003
"Exploring factors that influence adolescent mental health service use: The youth
perspective"
Neil Maniar, PhD Candidate 2002
“Determinants of weapon use among high school students in the U.S.”
Final Oral Defense
Sophia Y. Lo, PhD Candidate 2010
Thesis: “Neighborhood environment, residential mobility, and health: A longitudinal
examination of individual and neighborhood factors”
Sarah Renee Lindstrom Johnson, PhD Candidate 2009
Thesis: “Using concept mapping to structure students’ views of the school environment’s
contribution to school violence: Providing suggestions for school environment
intervention”
Lydia A. Isaac, PhD Candidate 2009
Thesis: “The neighborhood physical environment and cardiovascular disease risk
factors: Implications for policy”
Craig Martinez, DrPh Candidate 2009
Thesis: “Acculturation, gender and friend networks: Alcohol use among Mexican
American youth”
Andrea Leigh Stone, PhD Candidate 2005
Thesis: “Parental functioning and adolescent marijuana involvement”
Elizabeth Costendater, PhD Candidate 2002
"The dynamics of injection drug users' social networks in Baltimore"
Classroom Instruction
Social Ecology of Adolescent Health
Child Health and Development Doctoral Seminar
Growth and Development III: Adolescence
Introduction to Maternal and Child Health

(5-21)
(4)
(24)
(35)

2000 – 10
2008 – 10
2004
2003

Exhibit B

Journal of Adolescent Health 62 (2018) 525–531

www.jahonline.org
Original article

Impacts of Immigration Actions and News and the Psychological
Distress of U.S. Latino Parents Raising Adolescents
Kathleen M. Roche, M.S.W., Ph.D. a,*, Elizabeth Vaquera, Ph.D. b, Rebecca M.B. White, Ph.D., M.P.H. c,
and Maria Ivonne Rivera, M.P.H. d
a

Department of Prevention & Community Health, Milken Institute School of Public Health, The George Washington University, Washington, District of Columbia
Department of Sociology and Department of Public Policy & Public Administration, The George Washington University, Washington, District of Columbia
T. Denny Sanford School of Social and Family Dynamics, Arizona State University, Tempe, Arizona
d
The Rivera Group, Washington, District of Columbia
b
c

Article history: Received December 27, 2017; Accepted January 29, 2018
Keywords: Immigration; Latino Families; Parent Psychological Distress; Adolescents
See Related Editorial on p. 505

A B S T R A C T

Purpose: U.S. Latino parents of adolescents face unprecedented threats to family stability and wellbeing due to rapid and far-reaching transformations in U.S. immigration policy.
Methods: Two hundred thirteen Latino parents of adolescents were recruited from community
settings in a suburb of a large mid-Atlantic city to complete surveys assessing parents’ psychological distress and responses to immigration actions and news. Univariate and bivariate analyses
were conducted to describe the prevalence of parents’ responses to immigration news and actions
across diverse residency statuses. Multiple logistic regression models examined associations between
immigration-related impacts and the odds of a parent’s high psychological distress.
Results: Permanent residents, temporary protected status, and undocumented parents reported
significantly more negative immigration impacts on psychological states than U.S. citizens. Parents
reporting frequent negative immigration-related impacts had a significantly higher likelihood of
high psychological distress than did other parents, and these associations were maintained even
when accounting for parents’ residency status, gender, education, and experience with deportation or detention. The odds of a parent reporting high psychological distress due to negative
immigration impacts ranged from 2.2 (p < .05) to 10.4 (p < .001).
Conclusions: This is one of the first empirical accounts of how recent immigration policy changes
and news have impacted the lives of Latino families raising adolescent children. Harmful impacts
were manifest across a range of parent concerns and behaviors and are strong correlates of psychological distress. Findings suggest a need to consider pathways to citizenship for Latina/o parents
so that these parents, many of whom are legal residents, may effectively care for their children.
© 2018 Society for Adolescent Health and Medicine. All rights reserved.

IMPLICATIONS AND
CONTRIBUTION

In response to rapid and
unprecedented changes in
immigration actions and
news, high proportions of
U.S. Latino parents of adolescents reported recently
having modified behaviors
and experiencing worry.
Adverse responses to immigration events were
associated with more than
300% greater odds of a U.S.
Latino parent’s high psychological distress.

Conflicts of Interest: There are no potential conflicts, real or perceived, for any authors of this study. The study sponsors had no role in the study design; collection,
analysis and interpretation of data; writing of the report; or the decision to submit the manuscript for publication.
Author contributions: K.M.R. conceptualized and designed the study, conducted analyses, drafted the initial manuscript, and approved the final manuscript. E.V.
conceptualized and designed the study, contributed to writing all manuscript sections, reviewed and revised the manuscript, and approved the final manuscript.
R.M.B.W. conceptualized and carried out measurement work for immigration-related impacts, critically reviewed the survey instrument, contributed to writing some
manuscript sections, reviewed and revised the manuscript, and approved the final manuscript. M.I.R. supervised and collected data, reviewed and revised the manuscript, and approved the final manuscript.
* Address correspondence to: Kathleen M. Roche, M.S.W., Ph.D., Department of Prevention & Community Health, Milken Institute School of Public Health, The George
Washington University. 950 New Hampshire Ave, Suite 300, Washington, DC 20052.
E-mail address: [e-mail] (K.M. Roche).
1054-139X/© 2018 Society for Adolescent Health and Medicine. All rights reserved.
https://doi.org/10.1016/j.jadohealth.2018.01.004

526

K.M. Roche et al. / Journal of Adolescent Health 62 (2018) 525–531

Media reports indicate that U.S. Latina/o immigrants have experienced heightened stress and threats to family stability since
the new President took office in 2017 [1,2]. However, little empirical data document how rapid changes in immigration news
and actions are affecting Latina/o (hereafter, referred to as Latino)
families. Adverse consequences of today’s immigration climate
may be pronounced for Latino parents with adolescent children. Compared with younger children, adolescents have a better
cognitive understanding of the stressors their families face, experience more direct exposure to extrafamilial risks, and have
spent more formative years of identity development within a U.S.
context [3]. The present study describes parents’ behavioral and
emotional responses to recent immigration actions and news and
investigates how these responses are associated with Latino
parents’ psychological distress. We describe how immigrationrelated impacts vary by residency status, conceptualized along
a hierarchy from the most to least secure categories [4]. Participants included those who were U.S.-born and naturalized U.S.
citizens (most secure), permanent residents, Temporary Protected Status (TPS)1 residents, and undocumented residents (least
secure).
Extensive research has described stressors experienced by U.S.
Latinos [5,6], particularly the undocumented [7–14]. Latino immigrants often experience fear of deportation, exploitation by
employers [8], trauma [15], distrust in public services [16], language barriers, racism [11], and financial strain [17]. These
stressors are important predictors of psychological distress, indicated by anxiety, depression, and somatization [12,18,19]. The
costs and burdens of psychological distress extend far beyond an
affected individual. Parents’ psychological distress is especially
important; adolescents whose parents are depressed and/or
anxious face heightened risk of poor social functioning [20], academic failure [21], and mental health problems [20].
Immigration threats have impacts well beyond the acute harm
conferred to the subset of Latinos directly experiencing events
such as deportation [13,22]. Informed by public health’s injury
pyramid, Dreby suggested that an event such as deportation severely hurts those at the top of the pyramid—Latinos experiencing
deportation—but also produces less severe harm for a large
number of Latinos at the bottom of the pyramid—those not directly experiencing deportation [23]. This is because politics,
threats of deportation, and anti-immigrant sentiments lead to
widespread fear and anxiety among Latinos not directly affected by the event [10,23,24].
Immigration actions and news likely are affecting Latino
parents across diverse residency statuses. The most notable immigration policy changes in 2017 were: (1) expanded eligibility
for deportation, which increased deportation of long-term residents without criminal records [25]; (2) the elimination of, and/
or plans to eliminate, TPS [26–28]; and (3) an end to the Deferred

1
2

Action for Childhood Arrivals (DACA) program, which has protected hundreds of thousands of undocumented Latinos brought
to the United States as children [29]. Our study provides some
of the first evidence to date indicating how U.S. Latino parents
of adolescents cope, react, and manage emotions in response to
recent immigration news and actions. Given that the adolescents of parents in this study were U.S. citizens or brought to the
United States as children, our research can advance knowledge
about the family context for a large and critical segment of the
U.S. population.
Methods
Procedures and sample
Drawing from a mixed-method study conducted in the fall of
2017, we analyzed survey data for 213 Latina/o immigrant parents
living in a suburban area of a large mid-Atlantic city in the United
States. Numerous immigration policy changes took place before,
during, and immediately after our collection.2 The community
includes a large Latino population, mostly from El Salvador and
Guatemala and, to a lesser extent, from Mexico, Honduras, Nicaragua, and the Dominican Republic. An author of this study with
expertise in data collection among this community utilized her
existing network to recruit participants. Survey-only respondents were provided $10 and those who also participated in the
focus group were provided $50. Eligibility was limited to Latino
parents with at least one child aged 12–18 years. The sample was
stratified so that about one-third were undocumented (n = 69),
one-third were permanent residents (n = 70), and the remaining one-third included the same number of U.S. citizen (n = 37)
and TPS parents (n = 37).
Data collection was conducted in Spanish by bicultural and
bilingual interviewers. To protect participants’ safety, we collected data anonymously, obtained oral consent only, and obtained
a Certificate of Confidentiality from the National Institutes of
Health. All study procedures were approved by the Institutional Review Board at the institution where the research was
conducted.
Measures
Residency status. Parents’ residency status was measured by four
dummy coded variables for U.S. citizen (the reference group), permanent resident, TPS, and undocumented.
Immigration impacts on parents. The 15-item Political Climate Scale
was used to assess impacts of immigration news and actions [30].
The instrument opens with: “As you know, there have been stories
in the news about immigrants and immigration, and there have

TPS residents refer to those granted permission to live in the United States due to extraordinary and temporary conditions in the country of origin [26].
Timeline of survey data collection and policy announcements:

K.M. Roche et al. / Journal of Adolescent Health 62 (2018) 525–531

been official actions affecting immigrants and other people. We
would like to know whether these news stories and official actions
have affected you or your family over the past few months.”
Parents responded to 15 statements indicating worry or behavior modification. The original 1 to 5 response options were
recorded into “never/almost never, not very often, or sometimes” (the reference group) versus “very often or always/
almost always.”
Parent’s psychological distress. A modified 16-item version of the
Brief Symptom Inventory-18 [31] was used to assess parents’
symptoms of depression, anxiety, and somatization (due to Institutional Review Board concerns, two items—suicidal thoughts
and chest pains—were removed). Parents reported being distressed or bothered in the past seven days by things such as feeling
worthless, lonely, and nervous (0 = “not at all” to 4 = “extremely”). Results from Principal Components Analysis indicated a single
factor of psychological distress (α = .96). We recoded the summed
average scores into a dichotomous variable, whereby, “high distress” represented the top quartile of scores (≥3.19).
Background variables. Parent characteristics included sex (female
was the referent); having at least a high school education (less
than high school was the referent); living in the United States
for more than 15 years (<=15 was the referent); and being from
El Salvador (referent group), Guatemala, Honduras, Mexico, United
States, or “Other.” We assessed if parents moved to the United
States for any of the following reasons: (1) get a better job or make
more money; (2) improve education for their child; (3) escape
gangs or violence; and/or (4) reunite with family in the United
States. Finally, we assessed whether or not the parent had a family
member who was deported or detained since the new U.S. President took office in January 2017.

527

Analyses. We ran cross-tabulations with chi-square tests to
examine residency status differences in background variables and
impacts of immigration actions and news. We then ran logistic
regression models whereby parents’ psychological distress was
regressed on variables measuring impacts of immigration actions
and news. We excluded background measures that bivariate
results suggested might pose a multicollinearity problem. We
report regression coefficients as unadjusted odds ratios and adjusted odds ratios (AORs), with 95% confidence intervals (CIs). In
post hoc analyses, we used two-way interaction terms to examine
the degree to which immigration-related impacts on psychological distress differed for Latino parents in marginalized residency
status groups (i.e., undocumented, TPS) versus others (i.e., U.S.
citizens, permanent residents). All analyses used two-tailed statistical tests.
Results
Participants included slightly more mothers than fathers. About
half of the parents were El Salvadoran, with the remainder including mostly Central Americans and a small number of Mexicans
and U.S.-born parents. As shown in Table 1, virtually all TPS and
U.S. citizen parents had lived in the United States for more than
15 years, compared with less than two-thirds of permanent resident and less than one-third of undocumented parents. Over
three-quarters of U.S. citizens had at least a high school degree,
compared with 40% to 50% of permanent resident and undocumented parents, and less than one-fifth of TPS parents. Although
60% of TPS parents reported that a family member had been detained or deported since the new president took office in 2017,
less than a quarter of undocumented, permanent resident, and
U.S. Citizen parents reported a family member’s recent deportation or detention. Finally, the majority of youth whose parents

Table 1
Distribution of sample characteristics by parents’ residency status, n = 213
Undocumented

Country of origin
El Salvador
Guatemala
Honduras
Mexico
United States
Other
Live in United States > 15 Yearsa
≥ High School Educationb
Have DACA-eligible childc
Fam mem deported/detainedd
Reason(s) moved to United Statese
Get a job or a better job
Better education for child
Escape gangs or violence
Reunite family in United States
High psychological distress

TPS

Resident

U.S. citizen

Total

Chi-square (df)

n (%)

n (%)

n (%)

n (%)

n (%)

test

–
–
–
–
–
–
21 (30.9)†
34 (49.3)†
27 (39.1)
16 (23.5)†

–
–
–
–
–
–
35 (97.2)‡
7 (18.9)¶
9 (24.3)
22 (59.5)‡

–
–
–
–
–
–
45 (64.3)¶
27 (38.6)†
17 (24.3)
17 (24.6)†

–
–
–
–
–
–
36 (97.3)‡
29 (78.4)‡
–
7 (18.9)†

117 (55.2)
25 (11.8)
20 (9.4)
17 (8.0)
13 (6.1)
20 (9.3)
137 (64.9)
97 (45.5)
53 (30.1)
62 (29.4)

–
–
–
–
–
–
χ2 (3) = 68.14***
χ2 (3) = 28.42***
χ2 (2) = 4.39
χ2 (3) = 19.95***

12 (17.4)†
26 (37.7)
37 (53.6)
16 (23.2)†
16 (23.2)‡

15 (41.7)‡
18 (48.6)
24 (64.9)
10 (27.0)†,‡
18 (48.6)†

12 (17.9)†
23 (34.3)
33 (49.3)
29 (43.3)‡
19 (27.1)‡

–
–
–
–
3 (8.1)¶

39 (22.7)
67 (38.7)
94 (54.3)
55 (31.8)
56 (26.3)

χ2 (2) = 9.37**
χ2 (2) = 2.11
χ2 (2) = 2.37
χ2 (2) = 6.82*
χ2 (3) = 16.23***

“–” Indicates cell size was too small for cross-tabulation.
Some categories do not add up to 213 due to item-level missing data.
a Includes n = 13 parents born in the United States. Reference group: Lived in United States < 15 years.
b
Reference group: Parent had less than a high school education.
c
Parent reports having an undocumented child brought to United States prior to age 18. Among parents with “DACA-eligible” child, n = 14 (26.4%) report that their
child has protection under the DACA program.
d “Fam” = Family; “Mem” = member. Reference group: Had not had family member who was deported or detained since new U.S. president took office January 2017.
e
Analyses excluded U.S. Citizens due to small numbers having been born outside United States; respondents may mark more than one reason.
* p < .05 **p < .01 ***p < .001.
†,‡,¶ Proportions in the same row that do not share superscripts differ at p < .05 using Chi-square tests of significance.

528

K.M. Roche et al. / Journal of Adolescent Health 62 (2018) 525–531

are in this study are U.S. citizens; just 30% of the non-U.S. citizen
parents report having a “DACA-eligible” child—one brought to the
United States prior to age 18 and lacking legal residency status.
Just over 40% of TPS parents moved to the United States in
order for the parent or spouse to improve their employment situation, compared with less than a fifth of permanent resident
and undocumented parents. In addition, over 40% of permanent residents moved to reunite with family in the United States,
compared with about a quarter of TPS and undocumented parents.
Over half of the non-U.S. citizen parents (i.e., TPS, undocumented, permanent residents) moved to the United States to
escape gangs or violence and almost 40% did so for their children to get a better education. Finally, almost half of TPS parents
(48.6%) reported high psychological distress, compared with about
a quarter of undocumented (23.2%) and permanent resident
(27.1%) parents and just 8.1% of U.S. citizen parents.

(2) believing it would be hard to get a better job or make more
money; and (3) worrying that it would be hard for their children to get a job. There were no significant differences in the
proportions of TPS, undocumented, and permanent residents who
reported frequently changing daily routines or worrying about
contact with authorities such as police.
Due to small cell sizes, we do not present results for the most
extreme immigration consequences; these responses did not differ
significantly by residency status. Overall, between 14% and 18%
of parents reported “very often” or “almost always/always” being
stopped, questioned or harassed, and/or considered leaving the
country. U.S. citizens were least likely to report all other adverse
immigration impacts.

Variations in immigration impacts by parents’ residency status

A parent’s odds of being highly psychological distressed were
significantly greater if the parent frequently modified behavior
in response to immigration actions and news. Results in Table 3
include unadjusted odds ratios as well as adjusted odds ratios.
The odds of a parent’s high psychological distress were 118%
greater for parents who frequently avoided contact with authorities such as the police (44.3% vs. 19.2%, AOR = 2.18, CI: 1.03–
4.60) and three to four times greater for parents who frequently
warned their child to stay away from authorities (43.6% vs. 9.9%,
AOR = 4.06, CI: 1.75–9.45); worried it would be hard for their child
to get a job (40.8% vs. 14.0%, AOR = 3.19, CI: 1.49–6.81); worried
that family members would get separated (35% vs. 9.6%,
AOR = 3.52, CI: 1.28–9.67); and considered leaving the United
States (51.4% vs. 20.6%, AOR = 4.13, CI: 1.71–9.96). The odds of high
psychological distress were 8–11 times higher when parents reported that, due to immigration actions and news, they had
frequently been stopped, questioned or harassed (60.0% vs. 21.0%,
AOR = 8.03, CI: 2.68–24.05); avoided seeking medical care or assistance from police and government services (48.8% vs. 11.6%,
AOR = 5.30, CI: 2.45–11.47); talked to their child about changing behaviors such as where the child hangs out (49.0% vs. 6.2%,
AOR = 8.74, CI: 3.42–22.39); felt negatively affected (49.5% vs. 7.8%,
AOR = 7.78, CI: 3.33–18.20); believed that their children had been

Table 2 presents results for parental responses to immigration actions and news. As shown, the majority of TPS and
undocumented parents reported that immigration news and
actions led them to very often or always (1) worry about family
separation; (2) feel their child had been negatively affected; and
(3) worry it would be hard for their child to finish school. Although TPS parents were more likely than other groups to report
concerns about the safety and well-being of the family and children, substantial proportions of undocumented and permanent
resident parents reported these same concerns. Specifically, a substantial proportion of TPS, undocumented, and permanent resident
parents reported having frequently (1) warned their children to
stay away from authorities; (2) talked to their children about
changing behaviors such as where they hang out; (3) avoided
seeking medical care, public assistance (e.g., Supplemental Nutrition Assistance Program, The Special Supplemental Nutrition
Program for Women, Infants, and Children), or help from the
police; and (4) felt that their child or themselves had been negatively affected by immigration actions and news. Undocumented
parents were most likely to report jobs concerns including (1)
having a hard time imagining they could get a job or keep a job;

How immigration impacts matter for parents’ psychological
distress

Table 2
Proportion of parents in different residency statuses reporting “Very Often” or “Almost Always/Always” experiencing outcomes due to immigration news and events,
n = 213
Due to immigration actions and news

Undocumented

TPS

Resident

U.S. citizen

Total

Chi-square (df)

Parent Often or Almost Always/Always

n (%)

n (%)

n (%)

n (%)

n (%)

significance test

63 (29.6)
94 (44.1)
98 (46.2)
101 (47.6)
140 (65.7)
70 (33.0)
84 (39.4)
92 (44.0)
98 (46.0)
78 (36.8)
95 (45.2)
61 (28.8)
100 (46.9)
n = 213

χ2 (3) = 22.35***
χ2 (3) = 32.00***
χ2 (3) = 21.50***
χ2 (3) = 32.55***
χ2 (3) = 55.35***
χ2 (3) = 15.30**
χ2 (3) = 13.89**
χ2 (3) = 21.47***
χ2 (3) = 34.18***
χ2 (3) = 21.15***
χ2 (3) = 16.76**
χ2 (3) = 7.38
χ2 (3) = 15.73**

Hard to get or keep a job
Hard to imagine better job, more money
Worried will be hard for child to get job
Warned child to stay away from authorities
Worried family members will get separated
Changed daily routines
Avoided medical care, police, and services
Child negatively affected
Worried hard for child to finish school
Child affected at school
Parent negatively affected
Worried contact with police, authorities
Talked to child about changing behavior, such as where s/he hangs out
Total

(47.8)†

33
48 (69.6)†
42 (60.9)†
38 (55.1)†
61 (88.4)†
28 (41.2)†
29 (42.0)†
39 (56.5)†
40 (58.0)†
26 (37.7)†
34 (50.0)†,‡
24 (34.8)†
37 (53.6)†,‡
n = 69

(29.7)†,‡

11
15 (40.5)‡
21 (56.8)†,‡
28 (77.8)‡
31 (83.8)†
17 (45.9)†
23 (62.2)‡
22 (61.1)†
28 (75.7)†
24 (64.9)‡
24 (64.9)†
12 (32.4)†
24 (64.9)†
n = 37

(24.3)‡

17
25 (35.7)‡
29 (42.0)‡
30 (42.9)†
40 (57.1)‡
22 (31.4)†
24 (34.3)†,¶
25 (37.3)‡
24 (34.3)‡
23 (32.9)†
30 (44.1)‡
21 (30.4)†
31 (44.3)‡
n = 70

(5.4)¶

2
6 (16.2)¶
6 (16.2)¶
5 (13.5)¶
8 (21.6)¶
3 (8.1)‡
8 (21.6)¶
6 (16.2)¶
6 (16.2)¶
5 (13.9)¶
7 (18.9)¶
4 (10.8)‡
8 (21.6)¶
n = 37

Bolded numbers signify the residency status with the highest proportion of parents reporting “very often” or “almost always/always” experiencing a particular adverse
outcome. Some categories do not add up to 213 due to item-level missing data.
** p < .01; *** p < .001.
†,‡,¶ Proportions in the same row that do not share superscripts differ at p < .05 using Chi-square tests of significance.

K.M. Roche et al. / Journal of Adolescent Health 62 (2018) 525–531

529

Table 3
Immigration actions and news as correlates of parent’s high psychological distress (n = 213)a,b
Number
Due to Immigration Actions and News, Parent “Very Often” or “Always”…c
Believe hard to find or keep a job
Believe hard to get better job, more money
Worried will be hard for child to get job
Warned child to stay away from authorities
Worried family members will get separated
Changed daily routines
Avoided medical care, police, and services
Child has been negatively affected
Worried will be hard for child finish school
Child has been affected at school
Has been negatively affected
Avoided contact with police, authorities
Considered leaving United States
Been stopped, questioned, and harassed
Talked to child about changing behavior, such as where child hangs out

%

Bivariate

#
63
94
98
101
140
70
84
92
98
78
95
61
37
30
100

%
29.6
44.1
46.2
47.6
65.7
33.0
39.4
44.0
46.0
36.8
45.2
28.8
17.5
14.2
46.9

OR
2.67**
1.76
3.86***
6.48***
5.82***
3.24***
7.67***
15.79***
12.03***
13.22***
11.25***
3.21**
4.00***
5.72***
14.50***

Multivariate
95% CI
(1.38–5.20)
(.93–3.32)
(1.96–7.57)
(3.08–13.64)
(2.34–14.43)
(1.68–6.25)
(3.77–15.61)
(6.60–37.77)
(5.26–27.51)
(6.12–28.57)
(5.06–25.01)
(1.64–6.28)
(1.85–8.64)
(2.38–13.76)
(6.09–34.51)

AOR
1.79
1.56
3.19**
4.06**
3.52*
2.07
5.30***
10.39***
9.85***
7.65***
7.78***
2.18*
4.13**
8.03***
8.74***

95% CI
(.82–3.88)
(.73–3.33)
(1.49–6.81)
(1.75–9.45)
(1.28–9.67)
(.99–4.32)
(2.45–11.47)
(4.01–26.92)
(3.81–25.42)
(3.33–17.53)
(3.33–18.20)
(1.03–4.60)
(1.71–9.96)
(2.68–24.05)
(3.42–22.39)

AOR = adjusted odds ratio; CI = confidence interval; OR = odds ratio.
a Each immigration impact variable was examined in separate logistic models.
b
Adjusted models control for parent’s residency status; gender; having at least a high school education; and, reporting that a family member was detained or
deported since the new President took office in 2017. Years living in the United States and country of origin were not included in multivariate models due to multicollinearity with residency status.
c
The reference group includes responses of “never/almost never,” “not very often,” or “sometimes.”
* p ≤ .05; ** p ≤ .01; *** p ≤ .001.

negatively affected (51.1% vs. 6.8%, AOR = 10.39, CI: 4.01–26.92);
expected their children would have a hard time finishing school
(48.0% vs. 7.8%, AOR = 9.85, CI: 3.81–25.42), and thought their children had been affected at school (55.1% vs. 9.0%, AOR = 7.65, CI:
3.33–17.53). Once control variables were included, parent reports
of having changed daily routines, feeling it was harder to find or
keep a job and having a hard time imagining getting a better job
or making more money, were not associated with parents’ psychological distress.3
Discussion
Contemporary immigration actions and news have had profound and far-reaching adverse impacts on U.S. Latino parents
raising adolescents. In a departure from prior research [8,19], this
descriptive study is informative about Latino parents across a hierarchy of residency statuses. Although parental worries and
behavior modifications tied to immigration actions and news were
least prevalent among U.S. citizens, pernicious immigrationrelated consequences were by no means limited to the
undocumented. Across noncitizen groups, especially those with
TPS, parents experienced concern for family, as indicated by parents
warning their children to avoid authorities; avoiding medical care,
public assistance, or the police; and, worrying that their children had been negatively affected at school due to immigration
actions and news. Similarly high proportions of TPS and undocumented parents had frequently talked to their children about
changing behaviors such as where they hang out, felt that the
immigration actions and news negatively affected the parent, and
3 Post hoc analyses indicated that just three of 15 two-way interaction terms
between residency status and immigration impacts were statistically significant (all suggested stronger immigration impacts on psychological distress for
U.S. citizen and permanent resident than for TPS and undocumented parents).
Given concerns about a Type I error, we concluded that associations between
immigration-related impacts and the odds of parents having high psychological distress were similar for Latino parents specifically targeted by official
immigration actions and those not specifically targeted.

worried about their own and their children’s job prospects. As
suggested by research on DACA recipients [15], the vulnerability
of TPS parents in this study may stem from the temporary nature
of the TPS program and/or the stress of having undocumented
family members [26,32]. Almost all TPS parents in this study has
lived in the United States for more than 15 years, and 60% had
experienced a family member’s deportation or detention during
the first nine months of the new president’s term in office. Taken
together, these findings highlight the pronounced vulnerability
of TPS parents vis-à-vis today’s immigration changes.
Evidence for adverse consequences of immigration actions and
news across residency statuses is consistent with research indicating that immigration policy can be equally harmful to
documented and undocumented Latinos [23,32]. TPS and, in some
cases, permanent resident parents were at least as harmed by
immigration events as were undocumented parents. In this way,
our findings do not support the idea of “hierarchy” of residency
status but rather point to the uniquely protective value of having
U.S. citizenship. A substantial proportion of non-U.S. citizen
parents frequently engaged in behaviors designed to avoid the
attention of government authorities. These parental responses
align with prior research indicating that Latino immigrants often
hesitate contacting police for fear of mistreatment and/or the deportation of another family member [33]. Given that over half
of the non-U.S. citizen parents in this study moved to the United
States to escape gangs and violence, unease among these parents
is especially understandable. Regardless of residency status, a
small proportion of Latino parents (approximately 15% to 18%)
reported “very often” or “always” considering leaving the United
States and/or getting stopped, harassed, or questioned. These findings support the conclusion drawn by Enriquez that “sanctions
intended for undocumented immigrants seeped into the lives of
individuals who should have been protected by their citizenship status.”
Adverse immigration impacts were associated with at least
a 300% increase in the odds of a parent having high psychological distress. Worrying about youth’s education, perceiving

530

K.M. Roche et al. / Journal of Adolescent Health 62 (2018) 525–531

negative impacts on the family, being stopped/questioned/
harassed, and considering leaving the United States appeared to
be especially harmful; frequently experiencing these outcomes
was associated with more than an eight-fold increase in the odds
of a parent’s high psychological distress. Unlike parental concerns about their family, parent aspirations for their own upward
mobility (e.g., hoping to get a better job or make more money)
appeared not to compromise parents’ mental health once accounting for background variables.
Regardless of societal concerns about the mental health and
well-being of Latino adults, our findings raise serious concerns
about the health and well-being of U.S. Latino adolescents. Adolescents whose parents get deported often experience posttraumatic stress disorder [9]. In this research, almost twothirds of parents frequently worried about family separation and
close to half frequently warned their adolescent children to stay
away from authorities, talked to their children about changing
behaviors such as where they hang out, and avoided access to
medical care, police, and public assistance. These behaviors directly threaten youth’s safety and mental and physical health and
can be indirectly harmful by way of parents’ psychological distress [34]. Although risks likely are magnified for adolescents
whose parents are not U.S. citizens, the vast majority of Latino
adolescents in this study were U.S. citizens. Thus, even though
Latino youth themselves are not undocumented, they face risks
to well-being on account of their parents’ vulnerable residency
status [35].
This study is not without limitations and suggests important directions for future research. First, this study’s use of crosssectional data limits causal inferences. Second, the reliance on
self-reported data for a convenience sample of Latinos from a
single immigrant community is limiting. A larger sample size
would help elucidate findings for TPS parents, a group at heightened risk for adverse outcomes. Given that many Latino parents,
may live in “mixed-status” families with documented and undocumented family members, it will be important for future
research to explicitly investigate the unique difficulties faced by
mixed-status families [36]. Third, given the small number of
parents with children covered by the DACA program in this study,
further research is needed to elucidate the degree to which DACA
protections may or may not shield parents from immigrationrelated concerns and worries. Fourth, it is unclear how parental
responses to today’s immigration actions and news might differ
from those experienced during the Obama administration, which
witnessed even higher numbers of deportations to Mexico and
Central America. In this regard, however, any comparison is complicated by the fact that President Trump’s election in 2016 was
followed by fewer attempted illegal crossings into the United
States, an increased number of deportations in the interior of
the country, and expanded eligibility for deportation, resulting
in more deportations of individuals with long histories of lawabiding behavior [37]. Finally, our study did not investigate Latino
parents’ experiences of racism and discrimination. Yet, stress
tied to discrimination experiences are highly prevalent among
Latino immigrants and positively associated with anti-immigrant
policies [38] and inequity due to residency status [11]. Given
that parents’ reports of being frequently stopped, questioned,
or harassed due to immigration actions and news did not differ
by residency status, it is possible that immigration changes increased racial profiling for a much larger segment of the U.S.
Latino population than has been targeted by official immigrant
actions.

Public discourse around immigration has progressed at a rapid
pace since the 2016 presidential campaign and election. Extant
research has demonstrated that residency status serves as a mechanism of social stratification affecting Latino citizen youth by
blocking access to critical developmental resources [39]. The
current study suggests that increased anti-immigrant and antiLatino rhetoric taking place [1,2] may lead to psychological distress
among Latino parents of adolescents—a finding that generalized to all four residency status groups. Community-based
organizations must educate Latino residents about their rights,
ensure that these rights are not violated, and counteract rumors
that can have a chilling effect on Latino families’ use of public
services. Given robust negative implications of parent psychological distress for adolescents [20,21], alongside the large portion
of Latino adolescents who are U.S. citizens, pathways to citizenship for Latino parents are critical in order to mitigate longterm, collateral consequences for numerous Americans.
Acknowledgments
The authors thank Roushanac Partovi, MPH and Tom Salyers
for valuable contributions to this project and to the Latina/o
parents who participated in this research.
Funding Sources
This work was supported by The George Washington University (PI: Roche; Cross-Disciplinary Research Award); the National
Institutes of Health Center for Advancing Translational Sciences (PI: Guay-Woodfard; grant numbers: UL1TR001876;
KL2TR001877), and the William T. Grant Foundation (PI: White;
grant number 182878).
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[news release]. Washington, DC; 2017. https://www.dhs.gov/news/2017/
11/06/acting-secretary-elaine-duke-announcement-temporary
-protected-status-nicaragua-and. Accessed December 21, 2017.
[29] US Department of Homeland Security. Consideration of Deferred Action for
Childhood Arrivals (DACA); 2018. Available at https://www.uscis.gov/
archive/consideration-deferred-action-childhood-arrivals-daca. Accessed
December 21, 2017.
[30] Roosa MW, Liu FF, Torres M, et al. Sampling and recruitment in studies of
cultural influences on adjustment: A case study with Mexican Americans.
J Fam Psychol 2008;22:293–302.
[31] Derogatis LR. Symptom Checklist-90-Revised, Brief Symptom Inventory, and
BSI-18. In: Maruish ME, editor. Handbook of Psychological Assessment in
Primary Care Settings. 2nd ed. New York, NY: Routledge/Taylor & Francis
Group; 2017. p. 599–629.
[32] Enriquez LM. Multigenerational punishment: Shared experiences of
undocumented immigration status within mixed-status families. J Marriage
Fam 2015;77:939–53.
[33] Messing JT, Becerra D, Ward-Lasher A, Androff DK. Latinas’ perceptions of
law enforcement: Fear of deportation, crime reporting, and trust in the
system. Affilia 2015;30:328–40.
[34] Lorenzo-Blanco EI, Meca A, Unger JB, et al. Longitudinal effects of Latino
parent cultural stress, depressive symptoms, and family functioning on youth
emotional well-being and health risk behaviors. Fam Process 2017;56:981–
96.
[35] Capps R, Fix M, Zong J. A profile of U.S. children with unauthorized
immigrant parents. Migration Policy Institute; 2016. Available at https://
www.migrationpolicy.org/research/profile-us-children-unauthorized
-immigrant-parents. Accessed December 21, 2017.
[36] Zayas LH, Bradlee MH. Exiling children, creating orphans: When immigration
policies hurt citizens. Soc Work 2014;59:167–75.
[37] The Economist Group Limited. Donald Trump is deporting fewer people than
Barak Obama did. The Economist; 2017. Available at https://www
.economist.com/news/united-states/21732561-deportation-has-also
-become-considerably-more-random-donald-trump-deporting-fewer
-people. Accessed January 26, 2018.
[38] Ayón C, Valencia-Garcia D, Kim SH. Latino immigrant families and restrictive
immigration climate: Perceived experiences with discrimination, threat to
family, social exclusion, children’s vulnerability, and related factors. Race
Soc Probl 2017;9:300–12.
[39] Yoshikawa H, Suárez-Orozco C, Gonzales RG. Unauthorized status and youth
development in the United States: Consensus statement of the society for
research on adolescence. J Res Adolesc 2017;27:4–19.

Exhibit C

Statement of the Evidence
Child Evidence Brief

Society for Research in Child Development

JUNE 20, 2018

The Science is Clear: Separating Families has Long-term
Damaging Psychological and Health Consequences for
Children, Families, and Communities
After the United States Department of Justice announced the “Zero Tolerance Policy for Criminal Illegal
Entry,” Immigration and Custom Enforcement (ICE — an arm of the Department of Homeland Security)
separated approximately 2,000 children from their parents in April and May 2018 as they approached
the U.S. border. Children and parents were placed in separate facilities as they were being processed
and were not told when or how they would be reunited. This policy and its consequences have raised
significant concerns among researchers, child welfare advocates, policy makers, and the public, given
the overwhelming scientific evidence that separation between children and parents, except in cases
where there is evidence of maltreatment, is harmful to the development of children, families, and communities. Family separations occurring in the presence of other stressors, such as detention or natural
disaster, only adds to their negative effects.
Evidence on Harmful Effects of Parent-Child
Separation
The evidence that family separation is harmful dates back
to studies on the effects of parent-child separations on
children’s well-being during World War II. This research
documented far reaching effects of these separations into
adulthood, including increased risk for mental health
problems, poor social functioning, insecure attachment,
disrupted stress reactivity, and mortality (Pesonen &
Räikkönen, 2012; Rusby & Tasker, 2009; Mitrani, Santisteban, & Muir, 2004). Other research similarly documents
the harmful effects of parental separation on child wellbeing in a variety of other child populations including
children in Romanian orphanages (Zeanah, Nelson, Fox,
et al., 2003), children in foster care (Flannery, Beauchamp,
& Fisher, 2017) and children of incarcerated parents
(Geller, Garfinkel, Cooper & Mincy, 2009; Miller, 2006).
More recent work has documented the increased mental
health risk faced by both parents and children when they
are separated in the immigration process (Suarez-Orozco,
Bang, & Kim., 2011; Rusch & Reyes, 2013). Parent-child
separation has long-term effects on child well-being, even
if there is subsequent reunification. After being separated,
reunited children can experience difficulty with emotional
attachment to their parents, self-esteem, and physical and

psychological health (Smith, Lalonde, & Johnson, 2004;
Gubernskaya & Debry, 2017). For some children, time
does not appear to fully heal these psychological wounds
(Shonkoff et al., 2012).

Parents Buffer Children from Adverse Effects
of Toxic Stress
Parental separation is considered a toxic stressor, an
experience that engages strong and prolonged activation of the body’s stress-management system (Bridgman,
2014). The physiological and psychological toll of early
life stress, including parental separation, changes how
the body responds to stress in the long term, disrupting
higher-order cognitive and affective processes as well
as negatively altering brain structures and functioning
(Lupien, McEwen, Gunnar, & Heim, 2009; Pechtel &
Pizzagalli, 2011; Kumar et al., 2014). Such stressors put
children at greater risk for a multitude of health and psychological impairments, including anxiety, depression,
post-traumatic stress disorder, lower IQ, obesity, immune
system functioning, physical growth, cancer, heart and
lung disease, stroke, and morbidity (Granqvist, Sroufe,
Dozier, Hesse, & Steele, 2017; Heim & Nemeroff, 2001;
Maniam, Antoniadis, & Morris, 2014; Pechtel & Pizzagalli, 2011; Shirtcliff, Coe, & Pollak, 2009; Taylor, 2010).

Society for Research in Child Development | 1825 K Street, NW, Suite 325 | Washington, DC 20006 | 202-800-0677 | [e-mail] | @SRCDtweets

Children depend on their primary caretakers to successfully navigate stressful and traumatic events. Children’s
physiological responses to stress can be significantly reduced by access to their primary caretaker (Hostinar, Sullivan, & Gunnar, 2013). The separation of the family unit
under extreme conditions of stress worsens the psychological and physiological ramifications of that stressor on
children, especially younger children (Masten & Narayan,
2012). Conversely, ongoing contact with primary caregivers under conditions of stress can protect against risk
(Rodriguez & Margolin, 2015).

Impact of Border Family Separations on
U.S. Citizens

There is also evidence that family separations harm U.S.
citizens whose family members experience border detention or deportation. Parental separation increases the risk
for these U.S. children’s mental health problems such as
anxiety, depression, behavior problems, and symptoms of
post-traumatic stress disorder (Allen, Cisneros, & Tellez,
2015; Rojas-Flores, Clements, Hwang Koo, & London,
2017; Zayas, Aguilar-Gaxiola, Yoon, & Rey, 2015). U.S.
citizens of Latino descent also report heightened worries
and concerns for their families and their communities
Child-Separation from Parents Impacts
as a result of changes in implementation of immigration
Children at All Ages
policies such as the Deferred Action for Childhood ArMuch of the research on family separation has focused
rivals (DACA) policy (Roche, Vaquera, White, & Rivera,
on the impacts on children early in development. How2018). Moreover, countries with supportive integration
ever, puberty is also an especially vulnerable time of rapid policies are more likely to have child populations with
change (Doom & Gunnar,
better overall health and men2013). Stressors during
Parent-child separations
tal health indicators than those
adolescence can have lastwith less supportive approaches
lead to a host of long-term
ing impacts — the effects
(Marks, McKenna, & Garcia Coll,
psychological, social, and health
of which may not become
2018). Thus, there is evidence that
problems that are not necessarily policies about parental separaevident until adulthood
— (Humphreys, Gleason,
tions can negatively affect Ameriresolved upon reunification.
Drury, et al., 2015; Lupien,
can citizens.
McEwen, Gunnar, & Heim,
The Policy Implications are Clear
2009). Further, the effects of traumatic experiences are
cumulative; children and adolescents who have already
The scientific evidence is conclusive. Parent-child separafaced previous adversity are particularly susceptible to
tions lead to a host of long-term psychological, social, and
long term further negative consequences (Brown, Anda,
health problems that are not necessarily resolved upon
& Tiemeier, et al, 2009; MacKenzie, Bosk, & Zeanah,
reunification. In particular, the disruption of biological
2017). Thus, the research shows that across infancy, child- stress regulation mechanisms in the body induced by the
hood, and adolescence, child-family separations can be
need to seek refugee or asylum status are further taxed
related to negative outcomes across the lifespan.
by the absence of parental support. The science is clear:
Full references are available at www.srcd.org/policy-
media/statements-evidence

policies that separate immigrant families upon entry to
the U.S. have devastating and long-term developmental
consequences for children and their families.

AUTHOR INFORMATION*

Gustavo Carlo, Ph.D.
University of Missouri

Linda C. Halgunseth, Ph.D.
University of Connecticut

Carola Suárez-Orozco, Ph.D.
University of California, Los Angeles

Johayra Bouza
University of Miami

Ximena Franco, Ph.D.
Frank Porter Graham Development Inst.
University of North Carolina-Chapel Hill

Amy Marks, Ph.D.
Suffolk University

Rebecca M. B. White, Ph.D.
Arizona State University

Gabriela Livas Stein, Ph.D.
Univ. of North Carolina-Greensboro

*Authors are listed in alphabetical order.

Daisy E. Camacho-Thompson, Ph.D.
Reach Institute
Arizona State University

Cynthia García Coll, Ph.D.
Albizu University

The Society for Research in Child Development (SRCD) advances developmental science and promotes its use to improve human lives. Established in 1933 by the National
Academy of Sciences, SRCD is an interdisciplinary scientific organization with members from more than 50 countries. This Statement of the Evidence was authored by
invited experts in the field, and designed to summarize leading scientific evidence to inform policy decisions and improve the lives of children and families. We thank the
SRCD Latino Caucus for their contributions. © Society for Research in Child Development, 2018

Society for Research in Child Development | 1825 K Street, NW, Suite 325 | Washington, DC 20006 | 202-800-0677 | [e-mail] | @SRCDtweets

Exhibit 59

1
2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

8
STATE OF WASHINGTON, et al.,

NO.2:18-cv-00939

9
Plaintiff,
10
V.

11
12

DECLARATION OF PIA
ESCUDERO IN SUPPORT OF
PLAINTIFFS' MOTION FOR
EXPEDITED DISCOVERY

THE UNITED STATES OF AMERICA,
et al.,

13

Defendants.

1 415

16
17

I, Pia Escudero, declare as follows:
1.

I am over the age of 18 and have personal knowledge of the matters contained

18

within this Declaration. If I am called upon to testify as to the statements made herein, I could

19

and would competently testify hereto.

20

2.

I am a national mental health leader and social work professional with nearly 30

21

years working as a psychiatric social worker. For the past 10 years, I have served as the

22

director of the School Mental Health and Crisis Counseling & Intervention Services, within the

23

Student Health and Human Services Division of the Los Angeles Unified School District

24

("LAUSD" or "District").

25
26

3.

As the director of the School Mental Health and Crisis Counseling &

Intervention Services, I oversee and manage School Mental Health professionals and services

DECLARATION OF PIA ESCUDERO IN
SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

1

OFFICE OF THE ATTORNEY GENERAL
STATE of CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

I

that promote the mental health, well-being and academic achievement of all LAUSD students.

2

LAUSD programs support positive student connections with peers, family, school and

3

community to facilitate student development and academic success. They also facilitate the

4

ability to successfully deal with problems, crises, or traumatic experiences. For the past 20

5

years, I have collaborated with research partners at UCLA, USC and RAND Corporation to

6

develop cutting edge, evidence-based practices for individuals, groups, and classrooms to treat

7

youth exposed to violence and traumatic events.

8

4.

As the nation's second largest school district, LAUSD is proud to bring together

9

students and families from diverse backgrounds and cultures, many of whom are immigrants.

10

In fact, members of our school communities speak 94 languages other than English, including

11

Spanish, Armenian, Korean, Tagalog, Cantonese, and Arabic.

12

5.

As determined by the California Supreme Court in Serrano v. Priest, LAUSD

13

believes education is a fundamental right for all children. LAUSD has been on the forefront of

14

ensuring that all students, regardless of immigration status, are afforded a free public education

15

aligned with the United States Supreme Court case of Plyler v. Doe, which held that

16

undocumented children have a constitutional right to receive a free public K-12 education that

17

provides the means to becoming a "self-reliant and self-sufficient participant in society"

18

and instills the "fundamental values necessary to the maintenance of a democratic political

19

system."

20

6.

LAUSD has long welcomed immigrant students and provided comprehensive

21

academic, health, and social-emotional supports so they can learn and achieve their academic

22

potential. The District's School Mental Health department, first established in 1933, today

23

employs over 400 psychiatric social workers, psychiatrists, and support staff, who partner with

24

educational professionals to address barriers that prevent students from learning to optimize

25

their academic achievement.

26

7.

School Mental Health provides services throughout the district, using an

DECLARATION OF PIA ESCUDERO IN
SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

2

OFFICE of THE ATTORNEY GENERAL
STATE CALIFORNIA
13300 0 I Street
Sacramento, CA 95814
916-445-9555

integrated and comprehensive approach that employs (1) universal, (2) targeted, and (3)
21 intensive remedies. Universal strategies are aimed at all school stakeholders and include

teacher and parent training in mental health awareness, psychological first aid, and the
4

promotion of resiliency and nonviolence among students school wide and in the classrooms.
Targeted services are designed for early intervention for at-risk students. LAUSD also operates

6

15 Wellness Centers and 7 Mental Health Clinics that provide intensive therapeutic services to

7

individuals, groups, and families. These programs emphasize evidence-based, trauma-specific

8

interventions to address significant mental, emotional, and behavioral disorders.

9

8.

The forcible separation of immigrant children from their parents is traumatic

10

and cruel, and runs counter to our ethical standards, societal norms, and national aspirations.

11

Studies have demonstrated that such trauma can cause irreparable harm: trauma can literally

12

rearrange the brain's wiring, affecting areas dedicated to pleasure, engagement, control, and

13

trust.'

14

9.

In my experience, a system that induces trauma to children and other vulnerable

15

populations inevitably incurs additional and costly services to repair the cognitive and

16

emotional damage it has caused. Based on news reports, I have learned about the federal

17

government's recent practice of separating migrant families, which has led to a population of

18

over 2,000 separated children. The trauma endured by these children requires access to

19

necessary mental health services. Studies show that forced separation from parents in these

20

circumstances negatively impacts the educational outcomes of students, causing increased

21

anxiety and withdrawal, inability to focus on learning, and fear of being left alone.' If any of

22
23
24
25
26

Bessel van der Kolk, The Body Keeps Score (New York: Viking, 2014), referenced in Alejandra Acuna
and Pia Valenzuela Escudero, "Helping Those Who Come Here Alone," Kappan 11agazine 97, no. 4 (2016): 43.
2 See, e.g., Patricia Gandara and Jongyeon (Joy) Ee, "U.S. Immigration Enforcement Policy and Its
Impact on Teaching and Learning in the Nation's Schools," The Civil Rights Project, last modified February 28,
2018. https://wwlv.civilriglitsproject.ucla.edu/research/k-12-education/integration-and-diversity/u.s.-immigrationenforcement-policy-and-its-impact-on-teaching-and-learning-in-the-nations-schools; "How DACA Affects the
Health of America's Children," Immigration Policy Lab, accessed June 29, 2018, https:Himmigrationlab.org/
project/daca-affects-health-americas-children/; J. Hainmueller el al., "Protecting Unauthorized Immigrant Mothers
Improves Their Children's Mental Health," Science (August 2017).

DECLARATION OF PIA ESCUDERO IN
SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

1'I

the children separated from their families enters LAUSD, s/he will have access to LAUSD's

21

mental health services.

31

10.

Children need their parents and other caregivers to thrive in school. In my

4

experience, children who endure trauma, such as family separation, have a much more difficult

5

time in school and require more mental health services to alleviate trauma and psychological

6

damage.

7
8
9

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed this 29t1i day of June, 2018 at Los Angeles, California.

10
11
12

PIA ESCUDERO
13
14
15
16
17
18
19
20
21
22
23
24
25
26

DECLARATION OF PIA ESCUDERO IN
SUPPORT OF PLAINTIFFS' MOTION
FOR EXPEDITED DISCOVERY

4

OFFICE OF THE ATTORNEY GENERAL
STATE OF CALIFORNIA
1300 I Street
Sacramento, CA 95814
916-445-9555

Exhibit 60

Exhibit 61

Exhibit 62

Exhibit 63

Exhibit 64

1
2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

8
9

STATE OF WASHINGTON, et al.,
Plaintiff,

10
11
12

NO. 18-cv-00939
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW
YORK STATE OFFICE OF
TEMPORARY DISABILITY
ASSISTANCE

v.
DONALD TRUMP in his official capacity
as President of the United States, et al.,

13

Defendants.

14
I, Barbara C. Guinn, declare as follows:
15
1.

I am over the age of 18 and have personal knowledge of all the facts stated herein.

2.

I serve as the Executive Deputy Commissioner of the New York State Office of

16
17

Temporary and Disability Assistance (“OTDA”).

I am the principal assistant to the

18
Commissioner of OTDA, advise on matters of policy, and co-manage the operations of the
19
agency with the Commissioner.
20
3.

The mission of OTDA is to help vulnerable New Yorkers meet their essential

21
needs and advance economically by providing opportunities for stable employment, housing,
22

and nutrition. The agency’s vision is to empower New Yorkers to improve their financial

23
security and household stability in support of strong families and communities.
24
4.

OTDA was created by Chapter 436 of the Session Laws of New York for 1997

25
as the successor to the New York State Department of Social Services. Chapter 436 transferred
26
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

1

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

to OTDA the functions, powers duties, and obligations of the former Department of Social

2

Services concerning public assistance programs, Supplemental Nutrition Assistance Program

3

(“SNAP”), the Low-Income Home Energy Assistance Program (“LIHEAP”), and services

4

provided to refugees and other non-citizens.

5

5.

OTDA administers a wide range of programs that provide services and support to

6

low-income families and individuals, including services for refugees and other non-citizens.

7

OTDA administers many of these programs through social services districts, providing policy

8

guidance and systems support to the districts in their implementation of OTDA programs, as

9

well as fiscal monitoring and quality assurance of district operations and adjudication of fair

10
11

hearings reviewing district determinations.
6.

To the extent that children separated pursuant to the challenged policy would be

12

placed with sponsors in New York, they may be eligible to receive assistance or services through

13

one or more of the State or federally-funded programs described below, provided the children

14

have an appropriate immigration status and/or meet other program eligibility criteria. The

15

circumstances under which children who have been separated from their parents may qualify for

16

assistance or services is described more fully in the paragraphs below.

17

7.

Article XVII of the Constitution of the State of New York states that “the aid,

18

care and support of the needy are public concerns and shall be provided by the state and by such

19

of its subdivisions, and in such manner and by such means, as the legislature may from time to

20

time determine.”

21

inhabitants of the state are matters of public concern and provision therefor shall be made by the

22

state and by such of its subdivisions and in such manner, and by such means as the legislature

23

shall from time to time determine.” N.Y. Const., art. XVII, § 1.

24

8.

It further provides that “the protection and promotion of the health of the

OTDA is authorized to establish rules, regulations, and policies to carry out its

25

powers and duties as established under the Social Services Law (“SSL”). SSL §

26

20(3)(d). Among its duties is the supervision of local departments of social services and the
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

2

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

reimbursement of welfare costs, the advancement of grants of money for welfare purposes, and

2

the administration of a discretionary fund. See SSL § 20(3). The SSL additionally provides

3

OTDA with broad authority to establish rules, regulations, and policies upon which public

4

assistance and care will be provided within the State. See SSL §17.

5

9.

SSL § 17(a)-(b) and (j) provide, in part, that the Commissioner shall “determine the

6

policies and principles upon which public assistance, services, and care shall be provided within the

7

state both by the State itself and by the local governmental units … ,” shall “make known his policies

8

and principles to local social services officials and to public and private institutions and welfare

9

agencies subject to his regulatory and advisory powers … ,” and shall “exercise such other powers

10
11

and perform such other duties as may be imposed by law.”
10.

The Commissioner of OTDA is charged with the responsibility of taking

12

cognizance of the interests of health and welfare of the inhabitants of the State who lack or are

13

threatened with the deprivation of the necessaries of life and of all matters pertaining thereto.

14

SSL § 34(3)(c).

15

11.

The local social services districts are charged with the duty, so long as funds are

16

available, to provide adequately for those unable to maintain themselves, in accordance with the

17

requirements and provisions governing assistance and related provisions of the SSL. SSL §

18

131(1). Local social services districts “shall, whenever possible, administer such care, treatment

19

and service as may restore such person to a condition of self-support or self-care, and shall further

20

give such service to those liable to become destitute as may prevent the necessity of their

21

becoming public charges.” Id.

22

12.

In carrying out this duty, OTDA is required to respect family integrity. SSL §

23

131(3) provides that to the extent possible, families are to be kept together and “shall not be

24

separated for reasons of poverty alone,” and that families shall be provided services which

25

maintain and strengthen family life. SSL § 131(3).

26
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

3

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

13.

The Commissioner of OTDA exercises general supervision over the work of all

2

local welfare authorities, determines the policies and principals upon which public assistance

3

and care is provided within the State by State and local government units, and establishes

4

regulations for the administration of public assistance and care by the State and local government

5

units in accordance with the law. SSL § 34(3)(d); § 34(3)(f).

6

14.

Pursuant to SSL § 34(3)(f), OTDA’s Commissioner must establish regulations

7

for the administration of public assistance and care within the State by the districts and by the

8

State itself, in accordance with the law. Pursuant to SSL § 34(6), OTDA’s Commissioner “may

9

exercise such additional powers and duties as may be required for the effective administration of the

10
11

department and of the State system of public aid and assistance.”
15.

In furtherance of its constitutional and statutory obligations, OTDA supervises

12

the administration of several programs by social services districts. These programs include

13

Public Assistance (“PA”), which includes both Family Assistance (“FA”) and Safety Net

14

Assistance (“SNA”); SNAP; LIHEAP; and components of the Refugee Resettlement Program.

15

OTDA is also authorized to enter into contracts for purposes of carrying out the Response to

16

Human Trafficking Program (“RHTP”), and the Refugee Resettlement Program. SSL Article 10-

17

D, SSL § 358(4).

18

16.

The purpose of federally-funded FA is to provide cash assistance to eligible needy

19

families that include a minor child living with a parent (including families where both parents

20

are in the household) or a caretaker relative. FA operates under federal Temporary Assistance

21

for Needy Families (“TANF”) guidelines. For New York State fiscal year 2018-2019,

22

$1,400,000,000 has been appropriated for FA in the New York State budget. Chapter 53 of the

23

Session Laws of New York for 2018. The Personal Responsibility and Work Opportunity

24

Reconciliation Act of 1996 (“PRWORA”), provides the block grant funding to states for TANF.

25

This federal law requires states to operate a public assistance program to “provide assistance to

26

needy families so that children may be cared for in their own homes or in the homes of
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

4

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

relatives…” The program provides continuing assistance to needy families with children under

2

the age of 18, or under the age of 19 and regularly attending a secondary school or the equivalent

3

level of vocational or technical training, who meet the following criteria: (1) the child is living

4

with caretaker relatives as set forth in 18 N.Y.C.R.R. § 369.1(b); (2) the family meets the

5

categorical eligibility requirements as set forth in 18 N.Y.C.R.R. § 369.2, including citizen or

6

immigration status; and (3) the family meets the financial eligibility requirements as set forth in

7

18 N.Y.C.R.R. § 352. Because federal law restricts eligibility for federally-funded benefits to

8

non-citizens with certain forms of immigration status, one aspect of determining eligibility for

9

FA includes assessing whether an applicant has an appropriate immigration status. Should a

10

child who has been separated from a parent be granted asylum, or another qualified immigration

11

status as set forth in SSL § 122, that child could receive FA, if otherwise eligible.

12

17.

SNA is the New York category of PA provided to needy individuals and families

13

who are not eligible for FA. SNA is a State-funded program for which $555,000,000 has been

14

appropriated in the New York State budget for State Fiscal Year 2018-2019. Chapter 53 of the

15

Session Laws of New York for 2018. SNA provides assistance to single adults, childless

16

couples, children living apart from any adult relative, families of persons found to be abusing

17

drugs or alcohol, families of persons refusing drug/alcohol screening, assessment or treatment,

18

persons who have exceeded the 60-month limit on family assistance, and certain non-citizens

19

who are eligible for public assistance, but who are not eligible for federal reimbursement under

20

the family assistance program or who are considered permanently residing in the United States

21

under color of law. In determining eligibility for SNA, several factors are considered, including

22

an applicant’s citizenship or immigration status. The immigration status requirements for SNA

23

are less restrictive than the eligibility requirements for federally-funded programs. For example,

24

a child who has an application for asylum pending and has received employment authorization

25

from the United States Citizenship and Immigration Service, a child who has been granted

26

deferred action, a child who has been paroled into the United States for less than one year, and a
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

5

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

child who is residing in the United States pursuant to an order of supervision under § 241(a)(3)

2

of the Immigration and Nationality Act (“INA”) can receive SNA, if he or she meets program

3

requirements and other eligibility criteria.

4

18.

The purpose of the federally funded SNAP, formerly known in New York as the

5

Food Stamp program, is to reduce hunger and malnutrition by supplementing the food

6

purchasing of eligible low-income individuals and families, including low-income working

7

people, senior citizens, and the disabled. For State Fiscal Year 2018-2019, $400,000,000 has

8

been appropriated in the New York State budget for SNAP. Chapter 53 of the Session Laws of

9

New York for 2018. SNAP eligibility and benefit levels are based on household size, income,

10

and other factors, including immigration status. Federal law restricts eligibility for federally-

11

funded benefits to non-citizens with certain forms of immigration status. Should a child who

12

has been separated from a parent be granted asylum, or another qualified immigration status, that

13

child could receive SNAP benefits, if otherwise eligible. OTDA administers SNAP in New

14

York. SSL §§ 95, 29. OTDA has authority to: (1) develop the required State plans to utilize the

15

Federal Food Stamp Act of 1977, as amended, (2) accept a designation which makes

16

supplemental nutrition assistance benefits available to eligible persons, (3) delegate or assign

17

appropriate functions to other State departments and agencies with the approval of the Governor.

18

SSL § 95. OTDA, with the approval of the Governor, is further authorized to accept a

19

designation from, and act as the agent of, the duly authorized federal agency in the administration

20

of relief and related activities affecting the welfare of individuals and communities, and the

21

disbursement or expenditure of federal funds and commodities. SSL § 29.

22

19.

LIHEAP is a federally-funded block grant program, for which $500,000,000 has

23

been appropriated in the New York State budget for State Fiscal Year 2018-2019. Chapter 53 of

24

the Session Laws of New York for 2018. The block grant is administered by the U.S. Department

25

of Health and Human Services (“HHS”), Office of Community Services (“OCS”) within the

26

Administration for Children and Families (“ACF”). OTDA is authorized to: (1) develop and
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

6

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

submit to the Governor the LIHEAP application and plan required by federal law; (2) to take

2

whatever action may be necessary with respect to the plan; (3) to take action that may be required

3

to submit, implement, administer, and operate the plan; and (4) to secure for the state the benefits

4

available under such act. SSL §97. In New York, the federal LIHEAP program is known as

5

HEAP. The program assists eligible low-income individuals, particularly those with the lowest

6

income who pay a high proportion of household income for home energy in meeting their

7

immediate energy needs. Because federal law restricts eligibility for federally-funded benefits

8

to non-citizens with certain forms of immigration status, one aspect of determining eligibility for

9

HEAP includes assessing whether an household members have an appropriate immigration

10

status. Households that include asylees or individuals with another qualified immigration status,

11

including children separated from parents, who have been granted such status could receive

12

HEAP benefits if otherwise eligible. Should a child who has been separated from a parent be

13

granted asylum, or another qualified immigration status, that child could receive HEAP benefits,

14

if otherwise eligible. In New York, insufficient heating and/or cooling is a health and safety

15

concern that is especially acute in low-income households with members who are elderly,

16

disabled, and/or include children under the age of six. Therefore, New York provides an

17

additional benefit amount to these households.

18

20.

The Refugee Resettlement Program provides services to refugees and their

19

families to help them achieve economic and social self-sufficiency. For State Fiscal Year 2018-

20

2019, $26,000,000 has been appropriated in the New York State budget for the Refugee

21

Resettlement Program. Chapter 53 of the Session Laws of New York for 2018. As a condition

22

of receiving federal funding, states are required to submit a state plan outlining how it proposes

23

to encourage effective refugee resettlement, to promote economic self-sufficiency as quickly as

24

possible, and insure language training and employment services. States are also required to

25

designate a state-employed individual who will be responsible for insuring coordination of public

26
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

7

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

and private resources in refugee resettlement. This individual is the State Refugee Coordinator.

2

8 U.S.C. § 1522; 45 C.F.R. Part 400.

3

21.

OTDA was designated by the Governor of New York as the State agency

4

responsible for developing the Refugee Resettlement Program State Plan, and for administering

5

and supervising the implementation of New York’s State Plan. In designating OTDA as the

6

responsible State Agency, the Commissioner of OTDA or his/her designee, was identified as the

7

State Coordinator, with the responsibility and authority to ensure coordination of public and

8

private resources in refugee resettlement in the State. SSL § 358(3); SSL § 358(4).

9

22.

The Refugee Resettlement Program serves certain refugees, admitted under § 207

10

of the INA, asylees granted asylum under § 208 of the INA, Cuban or Haitian Entrants (as

11

defined in subdivision (e) of § 501 of the Refugee Education Assistance Act of 1980), non-

12

citizens admitted into the United States as Amerasian Immigrants as described in §

13

402(a)(2)(A)(i)(V) of the Personal Responsibility and Work Opportunity Reconciliation Act of

14

1996 (8 U.S.C. §1612(a)(2)(A)(v)), individuals paroled as refugees or asylees under § 212(d)(5)

15

of the INA, Certified Trafficking Victims who have received a certification or eligibility letter

16

from the U.S. Department of Health and Human Services, certain family members of a certified

17

trafficking victim as described in § 101(A)(15)(T)(ii) of the INA, Iraqis and Afghans Granted

18

Special Immigrant Status as described in § 101(a)(27) of the INA, and Lawful Permanent

19

Residents, provided that the individual previously held one of the aforementioned statuses.

20

Children separated from their parents who acquire one of the aforementioned statuses can receive

21

certain Refugee Resettlement Program services, provided that they meet other program

22

eligibility criteria.

23

23.

The Refugee Resettlement Program includes a component that provides services

24

to Unaccompanied Refugee Minors (URM).

25

mentioned statuses, non-citizens who have been granted Special Immigrant Juvenile Status under

26

8 U.S.C. § 1101(a)(27)(J) or who have been granted U nonimmigrant status under §
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

In addition to non-citizens with the above-

8

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

101(a)(15)(U) of the INA are also eligible for services as URM. If children separated from their

2

parents acquire one of the aforementioned statuses and are reclassified as URM by the Office of

3

Refugee Resettlement, then the children could receive services through this component of the

4

Refugee Resettlement Program.

5

implement an appropriate plan for the care and supervision of, and services provided to, each

6

unaccompanied minor, place the child in a foster home or other setting approved by the legally

7

responsible agency and in accordance with the child's need for care and for social, health, and

8

educational services. Case planning for unaccompanied minors must, at a minimum, address the

9

following elements: (1) family reunification; (2) appropriate placement of the unaccompanied

10

child in a foster home, group foster care, residential facility, supervised independent living, or

11

other setting, as deemed appropriate in meeting the best interest and special needs if the child;

12

(3) health screening and treatment, including provision for medical and dental examinations and

13

for all necessary medical and dental treatment; (4) orientation, testing, and counseling to

14

facilitate the adjustment of the child to American culture; (5) preparation for participation in

15

American society with special emphasis upon English language instruction and occupational as

16

well as cultural training as necessary to facilitate the child's social integration and to prepare the

17

child for independent living and economic self-sufficiency; and (6) preservation of the child's

18

ethnic and religious heritage. States must review the continuing appropriateness of each

19

unaccompanied minor's living arrangement and services no less frequently than every six

20

months. 45 C.F.R. Part 400.

21

24.

States that provide services to URM must develop and

OTDA enters into contracts with certain entities to provide services to human

22

trafficking victims through the RHTP. RHTP is a State-funded program that has the purpose of

23

assisting human trafficking victims who would not be otherwise eligible for services due to the

24

lack of an appropriate immigration status. SSL § 483-bb. For State Fiscal Year 2018-2019,

25

$397,000 has been appropriated in the New York State budget for RHTP. Chapter 53 of the

26

Session Laws of New York for 2018.
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

9

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

25.

OTDA has authority to coordinate with and assist law enforcement agencies and

2

prosecutors to access appropriate services for human trafficking victims. SSL § 483-bb. In

3

providing such assistance, OTDA may enter into contracts with non-government organizations

4

for providing services to individuals who have a pending application for federal certification as

5

a victim of a severe form of trafficking in persons as defined in § 7105 of Title 22 of the United

6

States Code, but have not yet obtained such certification, or a person who has reported a crime

7

to law enforcement and it reasonably appears to law enforcement that the person is such a victim.

8

To the extent that children separated from their parents are identified as such individuals, State-

9

funded services could be provided to them. These State-funded services may include, but are

10

not limited to, case management, emergency temporary housing, health care, mental health

11

counseling, drug addiction screening and treatment, language interpretation and translation

12

services, English language instruction, job training and placement assistance, post-employment

13

services for job retention, and services to assist the individual and any of his or her family

14

members to establish a permanent residence in New York or the United States. SSL § 483-bb.

15

26.

The Commissioner’s ability to administer and oversee the aforementioned

16

policies and programs have been and continues to be adversely impacted by the challenged

17

Trump Administration policy to forcibly separate families.

18

27.

The challenged policy acts as a barrier to the release of the affected parents and

19

children. Some of those who will be released in New York could be eligible for OTDA programs

20

and services. Therefore, the challenged policy is preventing OTDA from carrying out its

21

constitutional and statutorily-mandated obligations to assist needy non-citizen families.

22
23
24
25
26
DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

10

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

1

28.

The challenged Trump Administration policy to forcibly separate families

2

fundamentally contradicts the principles set forth in the New York State Constitution and Social

3

Services Law.

4
5
6

I declare under penalty of perjury under the laws of the States of New York and
Washington and the United States of America that the foregoing is true and correct.
DATED this 29th day of June, 2018 at Albany, New York.

7
8
9
Barbara C. Guinn
Executive Deputy Commissioner

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DECLARATION OF BARBARA C.
GUINN, EXECUTIVE DEPUTY
COMMISSIONER OF THE NEW YORK
STATE OFFICE OF TEMPORARY AND
DISABILITY ASSISTANCE

11

ATTORNEY GENERAL OF NEW YORK
28 Liberty Street
New York, NY 10005

Exhibit 65

Exhibit 66

1
2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

8

STATE OF WASHINGTON, et al.,

NO. 2:18-cv-00939

9
Plaintiff,

10

DECLARATION OF RUBEN
REEVES IN SUPPORT OF STATES'
MOTION FOR PRELIMINARY
INJUNCTION

V.

11
12

DONALD TRUMP in his official capacity
as President of the United States, et al.,

13

Defendants.

14
I, RUBEN REEVES, declare as follows:
15
1.

I am over the age of 18 and have personal knowledge of all the facts stated herein.

2.

I have been employed by the Washington State Department of Social and Health

16
17
Services (DSHS) for over 21 years. Within DSHS, I am currently the acting Deputy Statewide
18
Administrator in the Children's Administration for the Division of Licensed Resources (DLR).
19
DLR oversees, among other things, the licensing of Washington's overnight group care facilities,
20
including group homes and youth care centers, as well as licensing of all agencies that care for
21
children outside their homes.
22
3.

My job duties and responsibilities include providing managerial and clinical

23
guidance and leadership to Area Administrators and Program Managers in all areas of DLR
24
(including but not limited to child safety, family engagement, and child well-being) and for
25
ensuring that each field office and program under their authority complies with applicable laws,
26
DECLARATION OF RUBEN REEVES IN
SUPPORT OF STATES' MOTION FOR
PRELIMINARY INJUNCTION
2:18-CV-00939

I

OFFICE OF THE ATTORNEY GENERAL
1250 Pacific Avenue, Suite 105
P.O. Box 2317
Tacoma, WA 98401
[phone]

1

regulations and policies and procedures. I also provide extensive leadership in the strategic

2

planning for statewide programs, initiatives and activities.

3

4.

DSHS is statutorily directed to safeguard the health, safety and well-being of

4

children by ensuring that agencies (as defined in RCW 74.15.020) meet the minimum standards

5

for the care of children.

6

5.

DSHS oversees the licensing, inspection, and monitoring of providers who care

7

for children away from their parents. Pursuant to RCW 74.15.030, DSHS is authorized to

8

establish minimum licensing requirements for these agencies and individuals, and to issue

9

licenses and regulate the licensure of these childcare facilities.

10

6.

Specifically, pursuant to RCW 74.15.090, any agency under RCW 74.15.020 that

11

cares for children on a 24-hour basis away from their parents must be licensed. Under RCW

12

74.15.080, all agencies subject to licensure "shall accord the department of social and health

13

services ... the right of entrance and the privilege of access to and inspection of records for the

14 purpose of determining whether or not there is compliance with [licensing
15

requirements]." These provisions are consistent with the declared intent of chapter 74.15 RCW,

16

which is to protect and promote the health, safety and well-being of children receiving care away

17

from home. RCW 74.15.010. An agency is granted a group care license only after it, its staff,

18

and property meet the licensing regulations, and all required documents are in the licensing file.

19

WAC 388-145-1315.

20

7.

The licensing requirements for group homes and overnight youth shelters are

21

provided in ch. 388-145 WAC. Many of the licensing requirements impose requirements that

22

are intended to promote the wellbeing of children in the care of these agencies, regardless of

23

whether they are also in the state's custody. For example, WAC 388-145-1350 states: "The

24

department must have access to your facility, staff, and the children in your care at any time. You

25

must allow us to meet privately with staff or children in your care, at our request." This mandate

26
DECLARATION OF RUBEN REEVES IN
SUPPORT OF STATES' MOTION FOR
PRELIMINARY INJUNCTION
2:18-CV-00939

2

OFFICE OF THE ATTORNEY GENERAL
1280 Pacific Avenue, suite 105
P.O. Box 2317
Tacoma, WA 98401
[phone]

1

allows state licensing officers to privately inquire of the children or staff about the care delivered

2

at the agency.

3

8.

Likewise, WAC 388-145-1335(3) requires all licensed group care facilities that

4

care for more than five children to meet state health and safety requirements. , For example, they

5

must obtain a certificate of compliance from the Washington State Department of Health and

6

comply with fire safety requirements from the Washington State Patrol fire protection bureau.

7

9.

DSHS also assesses, as part of licensure, whether the staff in group care facilities

8

have the ability, physical health, and emotional stability necessary to meet the needs of children

9

in the facility's care. WAC 388-145-1330(4). Before issuing a license, the DSHS licensor

10

assesses the facility's ability to provide a safe environment for children and to provide the quality

11

of care they need. WAC 388-145-1330(7). These licensing regulations are designed to ensure

12

children in group care facilities are safe, healthy and protected from all forms of child abuse and

13

neglect according to RCW 26.44.020(1) and chapter 38845 WAC. WAC 388-145-1300.

14

10.

As of today's date, there are 144 licensed group care facilities across the state.

15

This number includes facilities that contract with the state to care for foster children who are in

16

the state's custody, as well as state-licensed facilities that care for children who are not in the

17

state's custody, such as those that contract with ORR to care for unaccompanied minors in

18

ORR's custody.

19

11.

I am aware that as of June 22, 2018, at least 9 children in federal ORR custody

20

were placed in state-licensed group care facilities in Washington State following separation from

21

their parents.

22

12.

I am aware that one of these private agencies issued a statement confirming that

23

it operates group care facilities that are currently caring for children in ORR custody who were

24

separated from their families.

25
26

13.

Washington State DSHS has a statutory mandate under RCW 74.13.031(2) to

recruit and retain adequate placement resources for children in foster care in the state's custody.
DECLARATION OF RUBEN REEVES IN
SUPPORT OF STATES' MOTION FOR
PRELIMINARY INJUNCTION
2:18-CV-00939

3

OFFICE OF THE ATTORNEY GENERAL
1250 Pacific Avenue, suite 105
P.O. Box 2317
Tacoma, WA 98401
[phone]

I

If additional placement resources are deflected away from foster children in the state's custody

2

in favor of contracts with the federal government to care for children in ORR custody, this is

3

likely to adversely impact the Department's mandate to safeguard the health, safety, and well-

4

being of these children.

5
6

I declare under penalty of perjury under the laws of the State of Washington and the
United States of America that the foregoing is true and correct.

7

_JL
8

DATED this

cc.~v

7 day of June, 2018 at

10

, Washington.

BEN~~
K
Acting Deputy Statewide Administrator

11
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15
16
17
18
19
20
21
22
23
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26
DECLARATION OF RUBEN REEVES IN
SUPPORT OF STATES' MOTION FOR
PRELIMINARY INJUNCTION
2:18-CV-00939

4

OFFICE OF THE ATTORNEY GENERAL
1250 Pacific Avenue, Suite 105
P.O. Box 2317

Tacoma, WA 98401
[phone]