Private Immigration Legislation

^Pr^ep^ar^{ed f}^o^r^M^e^m^b^ers^an^d^Com^mⁱ^t^t^ees^of^C^ong^r^e^ss

Private immigration bills warrant careful consideration with regard to precedent since they are a
special form of relief allowing the circumvention of the public laws concerning immigration and
nationality in uniquely meritorious cases. This report will give an overview of the congressional
subcommittee procedure and precedents concerning private immigration bills. This report will not
cover parliamentary procedural issues for private bills, which are covered by CRS Report 98-628,
Private Bills: Procedure in the House, by Richard S. Beth.

Authority and Purpose.....................................................................................................................1
General Procedure and Precedents..................................................................................................2
Subcommittee Procedure..........................................................................................................2
Stays and Administrative Review.......................................................................................2
Precedent s ................................................................................................................................. 5
House Subcommittee Rules................................................................................................5
Historic Trends....................................................................................................................7
Recent Practice...................................................................................................................8
Honorary Citizenship Distinguished...................................................................................9
Table A-1. Private Immigration Bills Introduced and Enacted, 104^th-110^th Congresses...............28
Appendix. Private Laws, 104^th-110^th Congresses...........................................................................11
Author Contact Information..........................................................................................................29

Congressional authority over immigration is not explicit in the U.S. Constitution, but generally is
considered to derive from several constitutional clauses. The U.S. Supreme Court has noted that,
“The Constitution grants Congress the power to ‘establish an uniform Rule of Naturalization.’
Art. I., § 8, cl. 4. Drawing upon this power, upon its plenary authority with respect to foreign
relations and international commerce, and upon the inherent power of a sovereign to close its
borders, Congress has developed a complex scheme governing admission to our Nation and status ¹
within our borders.” Further, the Fourteenth Amendment defines citizens as “[a]ll persons born
or naturalized in the United States and subject to the jurisdiction thereof.” Amend. XIV, § 1, cl. 1.
Although some legal scholars have argued that the phrase “uniform Rule of Naturalization” ²
precludes Congress from enacting legislation granting relief to a specific individual, the courts
have interpreted the phrase as simply requiring geographic uniformity throughout the States, ³
meaning that Congress cannot enact legislation applying different rules to different States. The
constitutional basis for private immigration bills generally is found in the First Amendment
prohibition against Congressional enactments abridging the right of the People “to petition the
Government for a redress of grievances” (Amend. I, cl. 3.) and in the power of Congress to pay ⁴
the debts of the United States (Art. I, § 8, cl. 1). Regardless of academic concerns about the
clarity of authority for private immigration legislation, clearly, Congress has a long history of ⁵
such enactments.
When the public laws relating to immigration operate to prevent someone from entering or
remaining in the United States or obtaining some other benefit such as citizenship, private
immigration bills provide for exceptions for named individuals or small groups of individuals
whose circumstances merit special consideration. Private bills are intended to be a last resort for ⁶
relief after all administrative and judicial remedies are exhausted. Aside from the individual

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⁵^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t^69-²²⁶^.
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⁽^c^onti^nue^d.^..)

relief granted, the number and type of private bills introduced and of private laws enacted often ⁷
revealed flaws in the public laws which led to amendments to resolve such problems.
Conversely, expansion of immigration restrictions and elimination of relief in the public ⁸
immigration laws may lead to an increase in private bills. Overall, 7321 private immigration ⁹
laws have been enacted since the first such law was enacted in 1839.

Although the first private immigration laws enacted were related to naturalization, naturalization
waivers constitute the lowest percentage of private laws because of the serious ramifications of
conferring citizenship and its rights and obligations and of the United States’ undertaking the ¹⁰
protection of its new citizens. The majority of private immigration bills confer lawful permanent
resident (LPR) status by waiving a general law provision which prevents the granting or
maintenance of such status, whether that provision concerns grounds of inadmissibility or
deportation, numerical allocation limits, definitions of eligible immigrant categories, etc.
As noted above, under the rules of both the Senate Subcommittee on Immigration, Border
Security and Citizenship and the House Subcommittee on Immigration, Border Security and
Claims, no private bill shall be considered or acted upon by the Subcommittee until all avenues ¹¹
for administrative and judicial relief have been exhausted. If the beneficiary is subject to
removal/deportation, the mere introduction of a bill does not stay such removal/deportation.
A stay will generally be authorized by the U.S. Immigration and Customs Enforcement (ICE) in
the Department of Homeland Security (DHS) when it receives a request for a report on
information concerning a beneficiary’s case from either the Senate or House Subcommittee

^(...c^on^tin^ue^d)
^revⁱ^sioⁿ^s^{) f}^o^{r th}^{e 1}¹⁰^th^C^o^ng^r^e^s^s^a^ppa^r^e^ntly^ha^s^{not y}^e^{t be}^eⁿ^f^o^r^m^ally^c^ons^ide^r^e^d^by^the^c^ong^r^e^s^sⁱ^on^a^l^Subc^om^m^itte^e^s^.
^T^h^e^H^ous^e^Su^bc^om^m^itte^e^ha^s^be^{en r}^e^na^m^e^{d the}^Su^bc^om^m^itte^e^{on I}^m^mⁱ^g^r^a^{tion, C}^itiz^eⁿ^s^hⁱ^p^{, R}^e^f^u^g^e^es^{, B}^o^r^d^e^r
^S^ecu^ri^t^y^,^an^d^In^t^e^rn^atⁱ^oⁿ^a^l^L^a^w^.
⁷^I^M^M^I^GRAT^I^ON^L^AW^AN^D^P^ROCE^DURE^,^s^upr^a^f^oot^no^te^1,^§^74.⁰⁹^[¹^]^;^Ma^g^u^ir^e^,^s^upr^a^f^oot^note^4,^a^t⁸⁷⁽^notiⁿ^g^the^dr^o^pⁱⁿ
^bills^s^e^e^k^ing^to^by^pa^s^s^quota^re^s^t^ric^tions^a^f^te^{r the}^re^pe^a^l^of^the^qu^ot^a^s^y^s^t^em^{in pl}^{ace f}^r^o^m^1921-¹⁹⁶⁵⁾^.
⁸^I^M^M^I^GRAT^I^ON^L^AW^AN^D^P^ROCE^DURE^,^s^upr^a^f^oot^no^te^1,^§^74.⁰⁹^[¹^]^.^A^f^te^r^eⁿ^a^c^t^m^e^{nt of}^the^I^lle^g^a^{l I}^m^mⁱ^g^r^a^{tion R}^e^f^o^r^m
^a^{nd Im}^mⁱ^g^r^aⁿ^{t Re}^s^pons^ibil^ity^A^c^t^of¹⁹^{96 (IIRIRA}⁾^(e^na^c^t^e^d^a^s^Dⁱ^vⁱ^sⁱ^{on C}^of^the^O^m^nibus^Co^ns^oli^d^a^t^e^d
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ⁱⁿ^creased^f^r^o^m²ⁱⁿ^t^h^{e 10}⁴^C^ongr^{ess t}^o⁹ⁱⁿ^t^h^e¹⁰⁵^C^ong^r^e^s^s^a^{nd 18 in the}¹⁰⁶^Con^g^ress.^Ho^wever,ⁱⁿ^th^{e w}^a^ke
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^ha^s^c^oun^te^d⁵⁵^pr^iv^a^t^e^im^mⁱ^g^r^a^{tion la}^w^s^eⁿ^a^c^t^e^d^f^r^o^m^the¹⁰¹^st^C^ong^r^e^s^s^thr^o^ug^{h t}^h^e¹¹⁰^th^C^ong^r^e^s^s^a^s^of^the^da^te^of
^{this re}^p^o^rt.
¹⁰^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t¹⁹^8-⁹⁹^.
¹¹^Se^na^te^Su^bc^om^m^.^R^u^le^s^,ⁿ^o^.^{3, a}^{nd H}^ous^e^S^ubc^om^m^.^R^u^le^s^,^no.^3.

Chairman.¹² However, this stay is granted as a matter of custom and courtesy by the agency to the ¹³
congressional subcommittee and thus is purely discretionary, not legally mandated. Under the
Senate Subcommittee rules, requests for reports on private bills will be made by the
Subcommittee Chairman only upon a written request addressed to the Chairman by the author of ¹⁴
the bill. The Senate Subcommittee will not request a report or make other communications to
defer deportation of beneficiaries who entered the United States as nonimmigrants, stowaways, in
transit, deserting crewmen, or without inspection through the land or sea borders. The
Subcommittee may make an exemption from this rule where the bill is intended to prevent
“unusual hardship” to the beneficiary or to U.S. citizens related to the beneficiary and the author
of the bill has submitted complete documentary evidence to the Subcommittee in support of a ¹⁵
request to make an exception to the rule.
Under the House Subcommittee rules, the Subcommittee will not intervene in
removal/deportation proceedings or request a stay by requesting a report from ICE unless the bill
is designed to prevent “extreme hardship” to the beneficiary or a U.S. citizen spouse, parent or ¹⁶
child. The distinction between the Senate and House Subcommittee rules is that the Senate
Subcommittee will generally request a report upon the request of the author of a bill without an
initial consideration of the merits of the case and only requires a showing of hardship for certain
disfavored categories, whereas the House Subcommittee will not request a report in any case
unless a motion to request a report has been made at a formal meeting of the Subcommittee and a ¹⁷
consideration of whether the “extreme hardship” requirement has been met.
When ICE has received a request for a report on a private bill beneficiary and granted a stay of
removal/deportation, the date established for removal/deportation or voluntary departure under
any final order shall be February 1 of the next odd-numbered year, or in other words, of the first ¹⁸
session of the next Congress following the one in which the bill was introduced. However, if the
beneficiary’s continued presence in the United States would be or becomes contrary to the best
interests of the United States, removal/deportation may be carried out after consultation with the ¹⁹
author of the private bill and the Judiciary Committee that requested a report. If adverse action
is taken on a private bill for which a stay of removal/deportation has been granted, ICE will
establish a date by which removal/deportation or voluntary departure must be effected; ICE may
extend the deadline at its discretion.
Exactly what constitutes an adverse action or disposition is not defined in the laws, regulations, or
Operations Instructions concerning immigration. It appears that such actions would include a
decision by the Subcommittees to not recommend a private bill for action by the full Committee;

¹²^O^p^e^r^a^tions^Iⁿ^s^t^r^u^c^tⁱ^ons⁽^O^I⁾¹^07.¹⁽^c⁾^{; Se}^na^te^S^ubc^om^m^.^R^u^le^s^,^no.^{1, a}ⁿ^{d H}^ous^e^S^ubc^om^m^.^R^u^le^s^,^{no. 5}^.
¹³^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t²⁴^,²⁵^3-^5;^I^M^M^I^GRA^T^I^ON^L^{AW A}^N^D^P^ROCE^DURE^,^s^upr^a^f^o^o^t^no^t^e^1,^§⁷⁴^.⁰^9[^2]^[^a^]^an^d^[³^]^.
¹⁴^Se^na^te^Su^bc^om^m^.^R^u^le^s^,ⁿ^o^.^1.
¹⁵^Se^na^te^Su^bc^om^m^.^R^u^le^s^,ⁿ^o^.^2.
¹⁶^H^ous^e^S^ubc^om^m^.^R^u^le^s^,^no.^4,^5.
¹⁷^Id^.^and^I^M^M^I^GRA^T^I^ON^L^AW^AN^D^P^ROCE^DURE^,^s^upr^a^f^o^o^t^no^t^e^1,^§⁷⁴^.⁰^9[^3]^.
¹⁸^{OI 10}^7.^1(f^{)(2)(i). A}^c^c^o^rding^{to st}^a^f^f^of^the^Se^na^te^a^{nd House}^J^udicⁱ^a^r^y^Com^m^itte^e^s^{, U.S. Im}^mⁱ^g^r^a^{tion a}ⁿ^{d C}^u^stom^s
^Eⁿ^f^o^rce^m^en^t^(ICE⁾^h^a^{s i}ⁿ^dⁱ^cat^ed^at^l^eastⁱⁿ^f^o^rmal^l^y^t^h^atⁱ^t^s^c^u^rre^nt^polic^y^{is to g}^r^aⁿ^{t a}^sta^y^of^re^m^ova^l/de^p^orta^tio^{n u}ⁿ^til
^Ma^rc^{h 15}^of^the^fⁱ^{rst se}^ssion^of^th^e^f^o^llowⁱ^ng^Cong^re^{ss f}^o^{r the}^be^ne^fⁱ^cⁱ^a^r^y^o^f^a^priv^a^t^e^{bill f}^o^{r w}^hom^a^re^port^ha^{s be}^eⁿ
^re^que^ste^d^{. How}^e^v^e^{r, this ha}^{s n}^o^t^be^eⁿ^a^f^fⁱ^r^m^e^d^{in w}^r^iting^{in a}ⁿ^y^p^ublis^he^d^doc^um^eⁿ^{t; the}^O^p^e^r^a^tion^s^Instruc^tⁱ^{ons a}^r^e
^cu^rren^tly^b^eⁱⁿ^g^revⁱ^sed^an^d^u^p^d^a^t^e^d^acco^rdⁱⁿ^g^t^o^t^h^e^{U.S. C}^itizen^s^h^ip^aⁿ^d^Im^mⁱ^g^r^atioⁿ^Serv^{ices we}^b^s^ite.
¹⁹^O^I¹⁰^7.¹⁽^f⁾⁽²⁾⁽ⁱⁱ⁾^.

a decision by the full Committee to not report a bill favorably to the entire Chamber; a negative
vote by either Chamber; or a veto by the President. Presumably, adverse dispositions may also
include a decision at a formal meeting under the House Subcommittee rules to not request a
report because the extreme hardship requirement has not been met or a decision in the ²⁰
Subcommittee or full Committee to table a private bill.
If no adverse action or final positive action has been taken on a bill by the end of a Congress, the
February 1 deadline affords the author of a private bill time to reintroduce a bill in the following ²¹
Congress; ICE may extend the deadline at its discretion. ICE notifies the beneficiary if a bill has
had an adverse disposition or is not reintroduced and informs them of the new date set for
execution of any outstanding order of removal/deportation or deadline for any voluntary ²²
departure granted.
A complete report on the beneficiary of a private bill is transmitted by ICE to the requesting ²³
Subcommittee. If classified or confidential information exists with regard to the beneficiary that
ICE is not authorized to transmit, ICE will refer the Subcommittee to the pertinent agency for ²⁴
further information. After the submission of a report, if further material information is received
or any material action is taken concerning a beneficiary which may affect congressional
consideration of a private bill, a supplementary report shall be submitted to the Committee or ²⁵
Subcommittee. ICE may advise the Committee or Subcommittee informally if the new
information concerns the granting of administrative relief or is particularly adverse. If a private
bill for which a report was made is reintroduced in the following Congress in the same chamber
whose Subcommittee requested the report, any additional material developed from a review of the
file and any new background checks or interviews shall be in transmitted to the Subcommittee in ²⁶
a supplemental letter. If the previous report was made to a different chamber in the immediately
preceding Congress or to the same chamber in a previous Congress not immediately preceding
the one in which the bill has been reintroduced, a new full report shall be submitted to the
requesting Subcommittee. If adverse action was taken on a private bill at any time and a new bill
is subsequently introduced for the same purpose for the same beneficiary in either chamber, ICE
will not honor a request for a report concerning the new bill unless the adverse action on the ²⁷
previous similar bill is reconsidered and ICE is notified of such reconsideration.
If a private bill beneficiary holds a nonimmigrant visa status, the introduction of a private
immigration bill to confer permanent resident status raises a presumption of termination of such

²⁰^House^S^ubc^om^m^.^Rule^no.^{9 pr}^o^vⁱ^de^{s tha}^t^the^Su^bc^om^m^itte^e^sha^{ll ta}^k^e^{no f}^u^rthe^{r a}^c^tio^{n o}ⁿ^a^priv^a^t^e^{bill t}^h^a^t^ha^s
^b^een^t^a^b^l^{ed b}^y^t^h^{e f}^u^l^l^Ju^di^ci^ary^Co^mmⁱ^t^t^ee.^T^h^{e Ho}^u^s^{e S}^u^b^c^o^mm.^Ru^l^e^{s S}^t^at^em^en^t^o^f^P^o^lⁱ^c^y^f^u^rt^h^e^{r p}^r^o^vⁱ^d^{es t}^h^at^t^h^e
^Subc^om^m^itte^e^{is re}^luc^t^aⁿ^{t to re}^c^o^nside^r^b^{ills ta}^b^l^e^d^by^the^f^u^{ll Co}^m^m^itte^eⁱⁿ^pr^e^vⁱ^ous^C^oⁿ^g^{resses ab}^sen^tⁿ^e^w^evi^d^en^ce
^{or inf}^o^rm^a^{tion n}^o^{t a}^v^a^ila^ble^a^t^t^h^e^tim^e^of^initia^{l c}^onside^r^a^tⁱ^on.^Seⁿ^a^te^Subc^om^m^.^Rule^no.^{6 pr}^ov^ide^s^tha^t^bi^lls
^p^r^evi^o^u^s^l^y^t^a^b^l^ed^sh^al^lⁿ^o^t^b^e^recoⁿ^sⁱ^d^{ered un}^l^e^{ss n}^e^w^evi^d^en^{ce i}^sⁱⁿ^t^r^od^u^ced^s^h^o^wⁱⁿ^{g a m}^a^t^e^ri^al^ch^an^{ge o}^f^f^act^s
^k^now^{n to t}^h^e^C^o^m^m^itte^e^.
²¹^{OI 10}^7.^1(f^)(2)(iii).
²²^{OI 1}⁰⁷^.¹⁽^f⁾⁽²^)(v^).
²³^Se^e^the^S^p^e^cⁱ^a^l^A^g^eⁿ^{t’s Fie}^l^{d Ma}^nua^{l, C}^h^.^23:^P^r^iv^a^t^e^Bill^Iⁿ^v^e^stig^a^{tions, f}^o^r^de^ta^ile^{d i}ⁿ^f^o^rm^a^{tion o}ⁿ^the^c^oⁿ^duc^t
^a^{nd c}^o^nteⁿ^t^of^priv^a^t^e^bill^inv^e^stig^a^{tions a}ⁿ^d^re^ports^.
²⁴^Id^.
²⁵^O^I¹⁰^7.¹⁽^g⁾^.
²⁶^O^I¹⁰^7.¹⁽^f⁾⁽¹⁾^.
²⁷^O^I¹⁰^7.¹⁽^c⁾^.

status, which will be handled as described below.²⁸ Any pending removal/deportation proceedings
are conducted to a final determination; any resulting order of removal/deportation may be stayed
according to procedural practice described above. If such proceedings are not already pending
and the beneficiary had a lawful B (visitor), C (transit), D (crewmen), or H (temporary worker)
visa status when the private bill was introduced, ICE will notify the beneficiary of the termination
of nonimmigrant status due to the private bill introduction and request a response from the
beneficiary within 30 days from receipt of notice about whether he/she desires to have status
adjusted through the private bill. If the beneficiary does not desire adjustment by the private bill, ²⁹
nonimmigrant status will likely be restored. If a report has been requested, ICE shall submit the
report with an explanation of why the beneficiary does not desire adjustment through the private
bill. If adjustment through the private bill is desired, removal/deportation proceedings shall be
initiated and conducted to a final determination.
If removal/deportation proceedings have not been initiated and the beneficiary had a lawful A
(foreign government official) or G (representative to an international organization) visa status
when the bill was introduced, he/she shall be considered to have voluntary departure for the
remaining period of such status. Upon the expiration of this period, if the beneficiary has not
departed, removal/deportation proceedings shall be initiated and conducted to a final
determination.
If the beneficiary had lawful E (treaty trader/investor), F (academic/language student), I (media),
J (exchange visitor), or M (vocational student) visa status, removal/deportation proceedings shall
not be initiated, however, any request for an extension of the visa period shall be denied unless
the presumption of termination of nonimmigrant status is overcome. Instead, voluntary departure
shall be granted in increments of one year if the beneficiary otherwise maintains visa status.
Removal or deportation proceedings shall not be initiated in any case involving appealing
humanitarian factors.
If a private bill is enacted, ICE and relevant offices of the State Department shall take appropriate
action in accordance with the terms of the private law and ICE shall not subsequently institute
removal/deportation proceedings against the beneficiary on grounds based solely on information ³⁰
developed and contained in the Judiciary Committees’ reports on the legislation.
For further information on parliamentary procedure re private bills, see CRS Report 98-628,
Private Bills: Procedure in the House, by Richard S. Beth.
Aside from the hardship factor, the most important factor considered by the Subcommittees is
whether a private immigration bill falls within the precedents for past private laws. Although the

²⁸^{8 C}^.^F^.^R^.^{§ 2}¹⁴^.¹⁽^d)^{; O}^I¹⁰^7.1⁽^e⁾^.
²⁹^S^{ee a}^l^so^I^M^M^I^GRA^T^I^ON^L^{AW A}^N^D^P^ROCE^DURE^,^s^upr^a^f^o^o^t^no^t^e¹^,^§⁷⁴^.^09[^{3] an}^d^acco^m^p^an^yⁱⁿ^g^f^o^o^t^not^{e 6}⁸^(a
^be^ne^fⁱ^cⁱ^a^r^y^o^f^a^priv^a^t^e^{bill w}^{ho c}^l^aⁱ^m^s^{it w}^a^s^introduc^e^d^w^ith^out^hi^s^k^now^le^dg^e^a^{nd c}^ons^eⁿ^{t w}^{ill be}^r^e^s^t^ore^d^to^la^w^f^ul
^non^im^mⁱ^g^r^aⁿ^{t sta}^t^{us if}^the^bi^{ll is f}^o^rm^a^l^l^y^w^ithdra^w^n).
³⁰^O^I¹⁰^7.¹⁽^h)^.

Senate Subcommittee rules do not explicitly address precedents, the House Subcommittee rules
expressly provide that, “It is the policy of the Subcommittee generally to act favorably on only
those private bills that meet certain precedents” and that it will only review “those cases that are ³¹
of such an extraordinary nature that an exception to the law is needed.”
The House Subcommittee rules provide that certain types of bills shall be subject to a point of
order unless two-thirds of the Subcommittee votes to consider the bill, including those that do not
comply with the rules, those that waive the two-year foreign residence requirement for doctors
with a J-visa adjusting to LPR status, and those waiving any law regarding naturalization.
The House Subcommittee rules include a Statement of Policy concerning certain types of bills,
the criteria for reviewing them, and the favorable precedential conditions for those categories.
The categories include:
• waivers of existing requirements for adopted children—favored if the child is
young and there has been a longstanding parent-child relationship;
• waivers permitting non-immigrant doctors and nurses to adjust status—
disfavored;
• waiver of criminal grounds for deportation requires testimony and affidavits
regarding rehabilitation and good conduct subsequent to the conviction to
determine whether the bill is in the best interests of the community;
• waivers permitting persons who entered the United States for advanced medical
treatment to remain permanently (typically for conditions requiring monitoring or
continuous treatment)—disfavored generally and requires an advisory opinion
from international health organizations regarding the availability of adequate
medical treatment in the beneficiary’s home country;
• waivers permitting persons with deferred action or parole status to adjust to LPR
stat us—disfavored;
• waivers of health exclusion grounds will require the posting of a bond—
disfavored;
• waivers of exclusion for those seeking LPR status to avoid military conscription
in their home country—disfavored;
• waivers of exclusion for visa fraud—disfavored;
• expedited naturalization for athletes seeking to compete as U.S. citizens, waivers
of naturalization requirements, restoration of citizenship to those who have
previously renounced U.S. citizenship, and posthumous citizenship are all
disfavored generally and the authors of such bills must provide evidence that they
would be in the national interest, not merely the personal interest of the
beneficiary.

³¹^H^ous^e^S^ubc^om^m^.^R^u^le^s^,^a^t^3.

Historically, the majority of private immigration laws have granted lawful permanent resident
(LPR) status to persons who needed expedited status under the quota system which existed from

1921 until 1965 or waivers from certain requirements of the immigration family or ³²

employment/occupational preference system, such as those for foreign orphans adopted or in the
process of being adopted by U.S. citizen parents but who did not meet the requirements under the ³³
law and to war brides and children of U.S. citizen servicemen and displaced persons/refugees ³⁴
after World War II prior to public legislation addressing gaps in the law. The other major
category concerning conferral of LPR status was the waiver of certain grounds of ³⁵
exclusion/inadmi ssibility.
A minority of private immigration laws provided for citizenship.³⁶ Generally, it appears that most
of these laws did not grant citizenship outright, but instead they waived the application of certain
requirements, which would either have barred the naturalization of a certain individual or would
have presented a hardship to the individual by prolonging the naturalization process, such as
residence requirements. Cases where it appears citizenship may have been granted outright

³²^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t^73-^{83. A}^c^c^o^r^d^ing^t^o^Ma^g^u^ir^e^,^65%^o^f^the^pr^iv^a^t^e^la^w^s^eⁿ^a^c^t^e^d^durⁱⁿ^g^the^fⁱ^r^s^{t 100}
^C^ong^r^e^s^s^e^s^r^e^la^te^{d to q}^uota^/^pr^e^f^er^eⁿ^c^e^r^e^lie^f⁽^a^{t 87-}⁸⁸⁾^.^T^h^e^s^e^inc^l^ude^{d c}^onf^e^r^r^a^{l of}^im^m^e^dia^t^e^r^e^la^tⁱ^v^e⁽^non-^qu^ota⁾
^sta^t^{us (35%}^of^the^q^uota^/^pre^f^e^r^eⁿ^c^e^-re^la^te^{d la}^w^s^);^w^a^iv^ing^r^a^cⁱ^a^l^ine^lig^ibility^f^o^{r a}^vⁱ^sa^{, pa}^rtic^ula^r^l^y^the^e^x^c^l^{usion f}^o^r
^c^e^r^ta^{in A}^s^ia^ns^unde^r^the^Q^uota^A^c^{t of}¹⁹²^{4 (}⁴³^Sta^t^.¹⁵³⁾⁽⁸^%^of^the^qu^ota^/^pr^e^f^e^r^eⁿ^c^e^-^r^e^la^te^{d la}^w^s⁾^;^by^pa^s^sⁱ^ng
^ov^e^r^s^ubs^c^r^ibe^d^qu^ota^s^or^ina^d^e^q^u^a^te^f^a^mⁱ^l^y^or^em^ploy^m^e^{nt pr}ⁱ^o^r^ity^s^y^s^t^em^s^b^y^e^s^ta^blis^hing^a^pr^e^f^e^r^enc^e^f^o^r^the
^be^ne^fⁱ^cⁱ^a^r^y⁽⁷^%^of^the^quota^/^pr^e^f^e^r^eⁿ^c^e^-^r^e^la^te^{d law}^s⁾^;^fⁱ^aⁿ^{cees o}^f^{U.S. citizen}^s^b^e^f^o^re^publ^ic^la^w^pr^ov^ide^d^vⁱ^s^a^s^t^a^t^us
^an^d^w^a^iv^{ers o}^f^ex^clu^s^ioⁿ^o^rⁱⁿ^ad^mⁱ^s^s^ib^ility^oⁿ^h^ealth^o^r^crimⁱⁿ^{al g}^r^o^uⁿ^d^s^f^o^{r su}^ch^fⁱ^an^{cees (3}^%^o^f^t^h^e
^quo^ta^/pre^f^e^re^nc^e^-re^la^te^{d la}^w^s^{); a}^{nd m}ⁱ^sc^e^lla^ne^{ous re}^a^s^{ons of}^m^e^dic^a^l^c^a^r^e^,^m^ilita^r^y^se^r^v^ic^e^,^na^tiona^l^inte^re^{st, re}^f^u^g^e^e^s
⁽^b^e^f^or^e^publ^ic^la^w^s^w^e^r^e^eⁿ^a^c^t^e^d⁾^,^f^a^mⁱ^l^y^unifⁱ^c^a^{tion, by}^pa^s^sⁱ^ng^of^pa^r^tic^ula^r^ly^low^c^ountr^y^quota^s⁽⁴^6%^of
^quo^ta^/pre^f^e^re^nc^e^-re^la^te^{d la}^w^s^).^S^{ee a}^l^so^I^M^M^I^G^RA^T^I^ON^L^AW^AN^D^P^R^O^CE^DURE^,^s^upr^a^f^ootn^o^te^1,^§⁷⁴^.⁰⁹^[²^]^[^c^]^.
³³^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t⁹²^,^96-⁹⁸^{. F}^o^r^e^x^am^ple^,^the^a^g^e^lim^it^f^o^r^f^o^r^e^ig^{n a}^dopte^d^c^h^il^dr^eⁿ^a^t^oⁿ^e^tim^e^w^a^s¹⁴
^y^e^a^r^s^{old, a}^s^op^pos^e^d^to¹⁶^y^e^a^r^s^old^to^da^y^;^this^c^a^u^s^e^{d ha}^r^d^s^hⁱ^p^pa^r^tic^ula^r^ly^af^te^r^W^o^r^l^{d W}^a^r^I^I^,^w^h^eⁿ^m^aⁿ^y^U^.^S.
^c^itiz^eⁿ^s^s^oug^ht^to^br^ing^ov^e^r^or^p^h^a^ne^{d r}^e^la^tiv^e^s^{, inc}^l^u^d^ing^olde^r^c^hⁱ^l^dr^eⁿ^{, w}^h^e^r^e^the^r^e^w^e^r^e^{no ot}^he^r^s^u^r^v^iv^ing^r^e^la^tiv^e^s
^ab^ro^ad^.
³⁴^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t^90-^91.
³⁵^Ma^g^u^ire^,^s^upr^a^f^o^o^tⁿ^o^t^e⁴^,^at¹³⁹^,¹⁴^8-50^.^Overal^l^,²⁵^{% o}^f^t^h^{e p}^rⁱ^v^at^{e i}^m^mⁱ^gratⁱ^oⁿ^l^a^w^s^en^act^edⁱⁿ^t^h^{e f}ⁱ^rst¹⁰⁰
^Cong^re^sse^s^w^a^ive^d^v^a^{rious e}^x^c^l^usion/iⁿ^a^d^mⁱ^ssibility^la^w^s^{. Ma}^g^u^ire^ideⁿ^tif^ie^{s se}^v^e^ra^{l c}^a^te^g^o^rie^s^of^s^u^c^h^la^w^s^—^w^aⁱ^ve^rs
^o^f^cri^mⁱⁿ^al^gro^uⁿ^d^s^f^o^{r cl}^o^s^{e rel}^a^tⁱ^v^{es o}^f^U.^S^.^ci^tⁱ^zen^{s o}^r^L^P^Rs,^the^v^a^st^m^a^jorit^y^inv^o^lv^ing^c^r^im^e^s^of^m^o^ra^{l turpitu}^de^,
^the^re^m^a^inde^{r inv}^o^lv^ing^f^r^a^{ud, dr}^ug^{s, a}^{nd sm}^ug^g^ling^(53%^of^e^x^c^l^usion^/ina^d^mⁱ^ssibility^-re^la^te^{d la}^ws^{); w}^a^ive^r^{s of}^he^a^lth
^g^r^oun^{ds of}^m^e^nta^l^re^ta^rda^{tion or}^t^ube^rc^ul^{osis (4}^1%^of^e^x^c^l^usion/iⁿ^a^d^mⁱ^ssib^ility^-r^e^l^a^t^e^d^la^{ws); a}^{nd m}ⁱ^sc^e^lla^ne^ous
^w^aⁱ^v^e^r^s^f^o^{r dra}^f^{t e}^v^a^s^{ion, Com}^m^unist^P^a^r^t^y^m^e^m^b^e^r^{ship, ill}^ite^ra^c^y^{, e}^t^c^.^(5%^of^e^x^c^l^usion/iⁿ^a^d^mⁱ^ssibility^-re^la^te^{d la}^w^s^).
³⁶^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t¹⁹^{2. O}^v^e^r^a^{ll, 1}⁰^%^of^the^pr^iv^a^t^e^im^mⁱ^g^r^a^{tion la}^w^s^eⁿ^a^c^t^e^d^{in the}^fⁱ^r^s^{t 10}^{0 C}^o^ng^r^e^s^s^e^s
^r^e^la^te^{d to c}^itiz^eⁿ^s^h^{ip a}^nd^na^tur^a^li^z^a^{tion. T}^h^e^pe^a^k^w^a^s^{152 i}ⁿ^the⁹⁰^th^C^ong^r^e^s^s⁽¹⁹⁶^7-⁶⁸⁾^,^of^w^h^ic^{h 140}^w^e^r^e^w^aⁱ^v^e^r^s^th
^of^r^e^sⁱ^de^nc^e^r^e^quir^e^m^e^nts^,^a^{nd 1}⁰⁷ⁱⁿ^the⁸⁹^C^o^ng^r^e^s^s⁽¹⁹⁶^5-⁶⁶⁾^,^of^w^h^ic^{h 88 w}^e^r^e^w^a^ive^r^s^of^the^r^e^sⁱ^de^nc^e
^req^uⁱ^rem^eⁿ^t^{s, p}^r^im^aril^y^f^o^{r Cu}^b^aⁿⁿ^a^ti^oⁿ^a^{ls seek}ⁱⁿ^g^ex^p^e^d^itedⁿ^a^tu^ralizatioⁿ^b^ecau^{se o}^f^citizen^sh^ip^req^uⁱ^rem^eⁿ^t^s^to
^pr^a^c^tic^e^c^e^r^ta^{in pr}^of^e^s^sⁱ^ons^{; t}^h^e^s^e^c^ons^tit^ute^d^33%^of^the^c^itiz^eⁿ^s^hⁱ^p^-^r^e^la^te^{d la}^w^s^eⁿ^a^c^t^e^d^dur^ing^t^h^e^fⁱ^r^s^{t 100}
^C^ong^r^e^s^s^e^s⁽^a^{t 197,}²^19-²²⁰⁾^{. T}^h^e^C^uba^{n A}^d^jus^t^m^e^{nt A}^c^{t of}¹⁹⁶⁶^,^e^f^f^e^c^tiv^e^l^y^g^r^aⁿ^ting^pe^r^m^aⁿ^eⁿ^{t r}^e^sⁱ^de^{nt s}^t^a^t^us^to
^C^ubaⁿ^na^tio^na^ls^{, e}^lim^ina^t^e^d^theⁿ^e^e^d^f^o^r^pr^iv^a^t^e^eⁿ^a^c^t^m^e^{nt of}^w^a^ive^r^s^f^o^r^m^aⁿ^y^C^uba^{n na}^ti^ona^ls^{, a}ⁿ^{d the}^r^e^w^a^s^a
^c^o^r^r^e^s^pon^ding^de^c^lineⁱⁿ^the^num^be^r^s^of^pr^iv^a^t^e^im^mⁱ^g^r^a^{tion la}^w^sⁱⁿ^s^u^bs^e^que^nt^C^o^ng^r^e^s^s^e^s^.^Ma^g^u^ir^e^ideⁿ^tif^ie^s^s^e^v^e^r^a^l
^c^a^t^e^g^orie^{s of}^c^itiz^eⁿ^ship-re^la^te^{d p}^r^iv^a^t^e^la^w^s^—^w^aⁱ^v^e^{r of}^re^sⁱ^de^nc^e^r^e^quir^e^m^e^nts^f^o^r^na^tur^a^liz^a^{tion (}⁵^2%^of^c^itiz^eⁿ^s^h^ip-
^rel^a^t^e^d^l^a^w^s^);^w^aⁱ^v^{er o}^f^t^h^{e i}ⁿ^abⁱ^lⁱ^t^y^t^o^coⁿ^f^{er ci}^tⁱ^zen^shⁱ^p^up^on^chi^l^d^r^en^o^r^d^e^ri^{ve ci}^tⁱ^zen^shⁱ^p^t^h^rou^{gh p}^a^ren^t^{s b}^ecau^se
^o^fⁱⁿ^su^f^fⁱ^ci^en^t^resi^d^eⁿ^{ce p}^e^ri^o^d^s⁽⁴³^%^o^f^ci^tⁱ^zen^shⁱ^p^-rel^a^t^e^{d l}^a^w^s^);^w^aⁱ^v^{er o}^f^l^o^{ss o}^f^ci^tⁱ^zen^shⁱ^p^b^ecau^{se o}^f^vo^l^uⁿ^t^ary
^a^c^t^{s (13%}^of^c^itiz^eⁿ^ship-re^la^te^d^l^a^{ws); re}^stora^tion^of^c^itiz^eⁿ^sh^ip^lo^{st f}^o^{r f}^a^ilure^{to sa}^tisfy^o^f^re^te^ntio^{n re}^qu^ire^m^eⁿ^ts
⁽^13%^of^c^itiz^eⁿ^s^h^ip-^r^e^la^te^d^la^w^s⁾^;^a^{nd m}ⁱ^s^c^e^lla^ne^ous^w^aⁱ^v^e^r^s^of^na^t^u^r^a^liz^a^tion^la^w^s^inc^l^uding^cⁱ^vⁱ^c^s^a^{nd E}ⁿ^g^lis^h
^k^now^le^dg^e^re^quirem^e^nts^a^{nd ine}^lⁱ^g^ibility^of^Co^m^m^unis^t^pa^rty^m^e^m^b^e^r^s^a^nd^dra^f^{t dodg}^e^r^s^(5%^of^c^iti^z^eⁿ^s^h^ip-re^la^te^d
^la^w^s⁾⁽^a^{t 193-}⁴⁾^.^S^{ee a}^l^s^o^I^M^M^I^GR^AT^I^ON^L^AW^AN^D^P^ROCE^DURE^,^s^upr^a^f^o^o^t^no^t^e¹^,^§⁷⁴^.0^9[^2]^[^c^]^.

generally involved either (1) women who had lost their citizenship through marriage to a
foreigner and a move abroad under now obsolete laws and who sought to regain their citizenship
upon being widowed or divorced and moving back to the United States; (2) children born abroad
to U.S. citizens who had moved back to and resided in the United States, who mistakenly
believed they were U.S. citizens, and subsequently discovered that they were not citizens, in some ³⁷
cases after years in the United States, including military service; or (3) persons who, while born
U.S. citizens, had lost citizenship because of retention requirements under now-obsolete laws and ³⁸
sought to regain citizenship.
In the 1970s, a series of corruption scandals such as Abscam, involving payoffs for the
sponsorship of private immigration laws, culminated in the expulsion of one Member of the
House of Representatives and led to a decline in private immigration laws, which were perceived
as tainted in general by the scandals. In the past decade, the trend reached a low point with only 2 ^th
private immigration laws enacted in the 104 Congress. The late 1990s, after the enactment of the
Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA), saw a brief
increase in the number of private laws, with a decline in the wake of 9/11. Four private ^th^th
immigration laws were enacted in the 108 Congress; none have yet been enacted in the 109
Congress, although 72 private immigration bills have been introduced as of the date of this report.
During the past decade, beneficiaries of private immigration laws are persons who generally were ³⁹
unable to receive permanent resident status through no fault of their own. Despite the efforts of
relatives petitioning for them, errors or delays on the part of the agencies responsible for
processing petitions rendered the beneficiaries ineligible for an immigrant visa or adjustment to
permanent resident status. The two most common circumstances that can be generalized into
categories appear to be errors or delays that result (1) in an orphan adoptee aging out before the
adoption and the immigrant petition or permanent resident adjustment can be completed and (2)
in a conditional permanent resident petition for an alien spouse not being approved before the
untimely death of a U.S. citizen spouse.
In the orphan adoption cases, a frequent circumstance appears to be the efforts of U.S. citizens to
adopt older children whose deceased parents or guardians were friends or extended family of the
petitioners. Historically, the precedents regarding juveniles generally concern the natural or
adopted children of U.S. citizen parents who for various reasons fell in the gaps in the public law
and thus needed special dispensation to emigrate immediately to rejoin the U.S. citizen parent(s) ⁴⁰
or legal guardian(s). The justification for such expeditious treatment would be family
reunification, one of the fundamental policies behind U.S. immigration and nationality laws. In
certain cases, beneficiaries came to the United States as very young children but reached
adulthood without obtaining LPR status because of the errors or deaths of their parents or
guardians. Often, minor siblings dependent on the beneficiary are either U.S. citizens or are still
eligible for administrative or judicial relief and family unification again is a factor in granting
private law relief.

³⁷^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t¹⁹^5-¹^96,¹^99-²⁰^0.
³⁸^Ma^g^u^ire^,^s^upr^a^f^oot^note^{4, a}^t¹⁹^5-^6.
³⁹^Se^e^“^A^ppe^ndix^:^P^r^iv^a^t^e^L^a^w^s^{, 19}^95-²⁰^05.”
⁴⁰^Se^e^s^upr^a^f^ootn^o^te^33.

The faultless actions of the beneficiary and the bureaucratic delays combined with other
hardships or sympathy resulting from the death of an immediate relative who was a U.S. citizen
or LPR seem to be the most common factors. Generally, the relative had a pending petition for an
immigrant visa/adjustment of status for the beneficiary of the private bill, but the petition expired
due to the death of the petitioning relative. Typically, the beneficiary had no other avenue for
immigration or adjustment of status, has strong ties to other family members in the United States
and no remaining familial ties to his/her native country. Despite having other close relatives in the
United States, those relatives may be minor U.S. citizen children who are not yet old enough to
petition for the beneficiary, or may be relatives who do not have a degree of relation close enough
to petition for the beneficiary, such as the parents of a deceased spouse. In certain cases, special
circumstances raise a case out of the ordinary, such as the death, arising out of a hate crime in the
wake of the 9/11 attacks, of a person petitioning for family members or the death of a foreign
national employed abroad by the U.S. Government whose dedication to his job could have cost
his family the opportunity to emigrate to the United States.
Certain cases appear to have had unique circumstances of particular national foreign-policy
interest. These include the high-profile human rights activist Wei Jingsheng. His case is
particularly notable because he had a pending employment-based immigration petition and was a
visiting university scholar at the time the private law was enacted, so he had not exhausted other
avenues for permanent lawful resident status pursuant to Subcommittee rules. Thus, enactment of
the private law appears to have been an act of support for the activist and the human rights and
democracy movements he represented more than relief for someone with no other recourse. Other
laws benefitted Persian Gulf War evacuees with U.S. ties, persons technically ineligible for Nazi
reparations, and a Swiss bank employee who exposed an attempt to unlawfully destroy the bank-
account records of Holocaust victims.
The House and Senate Subcommittee rules both favor cases of extreme or unusual hardship,
which would appear to be the operative factor in cases generally disfavored according to the
House Subcommittee rules discussed above. The Senate Subcommittee rules require the author of
a private bill to set forth the equities of a case and why other remedies are not available in a
written statement to the Subcommittee. As noted above, the Senate Subcommittee rules do not
discuss specific precedents; it would appear that these rules provide greater latitude in permitting
the equities of a particular case to overcome any negative precedent.
A private law to grant citizenship should not be confused with honorary citizenship. Honorary
citizenship is a rare and extraordinary honor granted to foreigners who have rendered great
service. Only a handful of individuals have received this honor, including Mother Teresa,
renowned for her charitable works on behalf of the destitute; Raoul Wallenberg, the Swedish
diplomat who saved the lives of thousands of Jews during World War II; Winston Churchill,
Prime Minister of the United Kingdom during World War II; and William Penn, the founder of
Pennsylvania, and Hannah Callowhill Penn, his wife. Honorary citizenship “is a symbolic
gesture. It does not grant any additional legal rights in the United States or in international law. It
also does not impose additional duties or responsibilities, in the United States or internationally, ⁴¹
on the honoree.” It “does not give the recipient any voting privileges. This has been a concern in
the past. It is crystal clear from the legislative history of the Churchill, Wallenberg, and Penn bills

⁴¹^H^.^R^e^pt.¹⁰^4-⁷^96,^1-^{2 (}¹⁹⁹⁶⁾^.

that conferral of honorary citizenship is purely a symbolic gesture. It is recognition of their ⁴²
outstanding commitment to their fellow man and to America.” Then-Representative Pat
Schroeder noted that Mother Teresa would not automatically have the right to reside in the United ⁴³
States even with the honorary citizenship unless she met the usual immigration requirements. ⁴⁴
Honorary citizenship is normally granted through a joint resolution enacted as a public law, not
a private law, since it is a public honor granted by the United States to a meritorious individual,
not private relief waiving the application of the public immigration and nationality laws for an
individual. For further information on honorary citizenship laws, see CRS Report RS21471,
Recipients of Honorary U.S. Citizenship, by Barbara Salazar Torreon.

⁴²¹⁴^{6 C}^o^ng^{. R}^e^c^.^H¹⁰⁴^{52 (}^d^a^ily^{ed. Se}^p^t^.^17,¹⁹⁹⁶⁾⁽^s^ta^te^m^e^{nt of}^R^e^{p. Fla}ⁿ^a^g^aⁿ⁾^.
⁴³¹⁴^{6 C}^o^ng^{. R}^e^c^.^H¹⁰⁴^53.⁽^d^a^ily^e^d^{. Se}^p^t^.^17,¹⁹⁹⁶⁾^.
⁴⁴^E.g.^,^P^.^L^.¹⁰^4-2^18,¹¹⁰^Sta^t^.³⁰²¹⁽¹⁹⁹^{6) (g}^ra^ntiⁿ^g^ho^nora^r^y^c^itiz^eⁿ^ship^to^Mo^the^r^T^e^re^sa^).

Private Law No. 104-3
H.R. 1031
Title: Private Bill; For the relief of Oscar Salas-Velazquez.
Sponsor: Rep. Ramstad, Jim [R-MN-3] (introduced 2/23/1995)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 104-810
Latest Major Action: Enacted 10/09/1996.
Serious Family Medical Conditions. Oscar Salas-Velazquez had been deported to Mexico
because of a prior fraudulent marriage to obtain lawful permanent resident (LPR) status in the
1980s. There was a genuine health risk for his second wife, a U.S. citizen, and possibly one of
their children were they to join or even visit Mr. Salas-Velazquez in Mexico, as well as the
financial and emotional hardship normally suffered in such cases. The wife and child suffered
from Reiter’s syndrome, a severe, disabling, incurable arthritic disease triggered by intestinal
infection with certain organisms which are widespread in the food and water supplies of Mexico.
The House Report noted:
^{It is}ⁿ^o^{t t}^h^e^C^o^m^mⁱ^t^t^ee’sⁱⁿ^teⁿ^tⁱⁿ^aⁿ^y^w^a^y^th^at^this^le^gⁱ^s^l^{ation s}^e^rv^{e as}^{a preceden}^{t f}^o^{r oth}^e^r
^p^r^iv^{ate leg}ⁱ^slatioⁿ^to^w^a^iv^er^th^{e e}^x^clu^s^ioⁿ^staⁿ^d^a^r^d^f^o^r^m^a^r^r^iag^e^f^r^au^d^.^Ra^th^er^{, t}^h^is
^legⁱ^s^l^ation^ac^kn^o^w^ledg^es^t^h^{e p}^r^ev^iou^s^l^y^s^e^{t pr}^eceden^{t in}^pri^v^{ate leg}ⁱ^s^l^ation^t^h^at^s^e^paration
^du^{e to}^m^e^{dical circum}^s^t^an^ce^s^is^vⁱ^e^w^{ed b}^y^t^h^{e C}^oⁿ^g^r^e^s^s^as^s^a^tis^fyⁱⁿ^g^t^h^{e s}^t^an^{dard of}
^ex^tre^m^e^h^a^rds^h^{ip to an}^Am^eric^an^citizen^{. B}^ecau^s^e^of^al^m^o^s^t^c^e^rtain^dev^e^lop^m^en^t^o^f^R^eⁱ^t^e^r’^s
^syⁿ^d^ro^m^e^{, Mrs}^.^S^a^l^a^s-^V^e^l^{azquez, an}^{d pos}^sⁱ^bl^y^on^{e of}^h^e^{r c}^hⁱ^l^d^r^eⁿ^,^c^aⁿⁿ^o^t^e^v^en^vⁱ^sⁱ^t^M^e^xⁱ^c^o
^to^m^aⁱⁿ^taⁱⁿ^a^f^a^m^{ilial r}^e^latioⁿ^s^hⁱ^p^.
Private Law No. 104-4
H.R. 1087
Title: Private Bill; For the relief of Nguyen Quy An and Nguyen Ngoc Kim Quy.
Sponsor: Rep. Lofgren, Zoe [D-CA-16] (introduced 2/28/1995)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 104-811
Latest Major Action: Enacted 10/19/1996.
South Vietnamese Disabled War Veteran Ineligible for Special Entry Program. Major
Nguyen Quy An was a 52-year old South Vietnamese national living in the United States on
humanitarian parole. He was a South Vietnamese helicopter pilot in Vietnam. During the war he
saved the lives of four American airmen. Later on in the war, the Major sustained injuries which
resulted in the amputation of both of his arms. As a result of his inability to perform work tasks,
in a ‘re-education’ camp, the North Vietnamese expelled him from the camp after nine weeks. An
entry program was set up by the United States to help Vietnamese immigrate to this country who
were severely punished for siding with the United States during the war. One of the requirements
of that program was that the individual had to have been placed in a re-education camp for a
period of one year. Because the Major was kicked out of the camp after only nine weeks, he did

not meet the requirement for entry through that program. If Major An had not lost his arms, he
would have stayed in the camp for the time required to qualify for entry through the program set
up for South Vietnamese allies.
The legislation originally included Major An’s daughter, who was also here on humanitarian
parole. Because Major An could file a petition for his daughter, an amendment was adopted at the
subcommittee to remove the daughter from the legislation. The version of the legislation reported
by the Subcommittee allowed Major An to file for permanent residence. An amendment was
offered and accepted at full Committee to allow Major An to forego the permanent residence
period and file for naturalization.

Private Law No. 105-1
S. 768
Title: Private Bill; A bill for the relief of Michel Christopher Meili, Giuseppina Meili, Mirjam
Naomi Meili, and Davide Meili.
Sponsor: Sen. D’Amato, Alfonse [R-NY] (introduced 5/20/1997)
Cosponsors: 8
Committees: Senate Judiciary; House Judiciary
H.Rept. 105-129
Latest Major Action: Enacted 7/29/1997.
Permanent Residency Granted to Whistle-blower re Holocaust-era Bank Records. The
beneficiary was a security guard in a Swiss bank who discovered that Holocaust-era bank records
possibly pertaining to assets of Holocaust victims were unlawfully being destroyed. Upon saving
and turning records over to the Swiss authorities, the beneficiary was fired from his job and
blacklisted from obtaining other employment. He and his family were harassed and received
death threats. They fled to the United States, entering as visitors for pleasure under the Visa
Waiver Program. No immigration relief or benefit was immediately available to them. The
Immigration and Naturalization Service (I.N.S.) reported that the beneficiary likely was ineligible
for asylum since he probably could not claim that the Swiss authorities were unable or unwilling
to protect him from persecution or that he was being persecuted for one of the statutorily
recognized grounds for asylum.
Private Law No. 105-3
H.R. 2731
Title: Private Bill; For the relief of Roy Desmond Moser.
Sponsor: Rep. Delahunt, William D. [D-MA-10] (introduced 10/24/1997)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 105-361
Latest Major Action: Enacted 11/21/1997.
Technical Ineligibility for Nazi Reparations. This law was one of two uniquely intended to
make the beneficiary eligible for reparations for Nazi persecution under a 1995 agreement
between the United States and Germany rather than enabling him to receive any actual
immigration benefit. The beneficiary emigrated from Canada as a child and served in the U.S.
military during World War II before he completed naturalization. During the war he was among a
group of American prisoners of war who were transferred to the Buchenwald concentration camp.

After surviving the brutal conditions there and returning home after the war, the beneficiary
became a naturalized U.S. citizen. Upon applying for reparations pursuant to the agreement, he
was informed that he was ineligible because he was not a U.S. national at the time of persecution,
one of only two such persons. The private law deemed him to have been a naturalized U.S. citizen
retroactive to the date he entered the U.S. military.
Private Law No. 105-4
H.R. 2732
Title: Private Bill; For the relief of John Andre Chalot.
Sponsor: Rep. Delahunt, William D. [D-MA-10] (introduced 10/24/1997)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 105-360
Latest Major Action: Enacted 11/21/1997.
Technical Ineligibility for Nazi Reparations. This private law benefitted the other individual
determined to be ineligible for reparations for Nazi persecution because he was not a U.S. citizen
at the time of persecution. The beneficiary emigrated to the United States from France as a child,
but did not complete naturalization before enlisting in the military. He entered the Canadian
military because he was too young to enlist in the U.S. military and later transferred to the U.S.
Army Air Corps. As a prisoner of war, the beneficiary was transferred to the Buchenwald
concentration camp. After the war, he became a naturalized U.S. citizen, but his claim for
reparations under the agreement was rejected for the reasons noted above. The private law
deemed him to have been a naturalized U.S. citizen retroactive to the date he entered the U.S.
military.
Private Law No. 105-5
H.R. 378
Title: Private Bill; For the relief of Heraclio Tolley.
Sponsor: Rep. Hunter, Duncan [R-CA-52] (introduced 1/7/1997)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 105-125
Latest Major Action: Enacted 11/10/1998.
Adoption Final after 16^th Birthday. According to the House Report, Heraclio and his brother,
Florencio, became orphans when their mother died and their father abandoned them at the ages of
2 and 4 respectively, leaving them to be raised by their maternal grandparents in Mexico. Several
years later, when their uncle visited, he learned that the boys were living with little or no
supervision, so he brought them back to the United States with him and took over full
responsibility and care for the boys. The uncle, who worked for the adopting family, was killed in
an auto accident a year later. At that time, the Tolleys contacted an adoption attorney and
instructed him to start proceedings for guardianship so that they could become legally responsible
for the boys as well as enroll them in school. However, because they began guardianship
proceedings prior to adoption proceedings, the completion of the adoption process was delayed
until four months after Heraclio’s 16 birthday. Immigration law requires that in order for an
adopted child to qualify for permanent residence status as a ‛child’ of an American citizen, the
child must have been adopted by the age of 16. The petition for adoption was filed prior to
Heraclio Tolley’s sixteenth birthday. If the Tolleys had begun adoption proceedings before the
guardianship proceedings, the adoption would have been finalized before he turned 16.

Private Law No. 105-6
H.R. 379
Title: Private Bill; For the relief of Larry Errol Pieterse.
Sponsor: Rep. Linder, John [R-GA-11] (introduced 1/7/1997)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 105-644
Latest Major Action: Enacted 11/10/1998.
Waiver of Deportation—Victim of Being Framed for a Drug Conviction and Sole Financial
Support for a U.S. Citizen Spouse with a Chronic Illness. During a bitter marital break-up
ultimately resulting in divorce, the beneficiary’s first wife planted drugs in his home and called
police. Due to financial difficulties, rather than complete trial proceedings, the beneficiary agreed
to a plea bargain for a misdemeanor drug conviction. Subsequent changes in the immigration
laws rendered him deportable. Subsequent attempts at relief failed, thus a private bill was the only
remaining avenue for relief. The Subcommittee on Immigration and Claims consulted with the
parole investigator for the Governor of Florida and the I.N.S. agent in charge of the case and also
received the confidential case analysis of the Florida Parole and Probation Commission’s Office
of Executive Clemency. Investigations by all three sources were exhaustive. All found that the ex-
wife clearly planted the drugs, and that Mr. Pieterse was guilty of no crime whatsoever. The
beneficiary was the sole provider for his second wife, a U.S. citizen who suffered from a chronic
illness, and assisted financially in the care of her children from a previous marriage. In addition to
waivers of deportation and inadmissibility upon reentry as a returning resident after future
departures from the United States, the law stipulated that the offense at issue in this case could
not be used as evidence of bad moral character, so it would not render the beneficiary ineligible
for naturalization.
Private Law No. 105-7
H.R. 1794
Title: Private Bill; For the relief of Mai Hoa “Jasmine” Salehi.
Sponsor: Rep. Sherman, Brad [D-CA-24] (introduced 6/4/1997)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 105-689
Latest Major Action: Enacted 11/10/1998.
Death of the U.S. Citizen Spouse During Pendency of Conditional Permanent Resident
Petition. The beneficiary and her husband filed a petition for her adjustment to conditional
permanent resident status, but due to a 14-month backlog for applications in Los Angeles, where
the beneficiary lived, her interview was scheduled 14 months after the filing. In the meantime, her
husband was killed during an armed robbery of the restaurant of which he was a co-owner. Under
immigration laws and regulations, the beneficiary was ineligible for waivers for which she would
have qualified if her petition had already been approved. The House Report noted:
^By^al^l^accoun^t^s^t^hⁱ^s^w^a^s^{a l}^e^gⁱ^tⁱ^m^at^e^m^a^rri^ag^{e, an}^{d i}^tⁱ^s^t^h^roughⁿ^o^f^a^u^l^t^of^h^e^{r o}^wⁿ^t^h^a^t^M^r^s^.
^Salehⁱ^h^a^sⁿ^o^t^m^e^{t t}^h^e^m^a^r^rⁱ^a^g^e^r^e^q^u^ir^e^m^en^t^s^o^f^th^{e [}^I^m^mⁱ^g^r^a^tioⁿ^aⁿ^d^Natioⁿ^a^lit^y^A^c^t
^(INA^{)].... [INA}^]^reg^u^l^atⁱ^ons^con^cernⁱ^ng^t^h^{e un}^tⁱ^m^e^l^y^deat^h^of^{a s}^pon^s^o^riⁿ^g^s^pous^{e al}^l^o^w^f^o^r
^{a w}^aⁱ^v^er^o^f^th^{e t}^w^o^y^ear^m^a^r^r^iag^e^r^e^q^u^ir^e^m^eⁿ^t^oⁿ^l^y^if^th^eⁱⁿ^dⁱ^vⁱ^d^u^al^’^s^p^e^titioⁿ^f^o^r
^coⁿ^d^itioⁿ^a^{l p}^e^r^m^an^eⁿ^{t r}^e^sid^eⁿ^{ce h}^a^{s b}^een^ap^p^r^o^v^ed^p^r^io^r^t^o^t^h^{e d}^e^a^t^h^.^I^f^t^h^e^r^e^h^a^dⁿ^o^t^b^e^eⁿ^a
¹⁴^-^m^oⁿ^t^h^b^ack^lo^g^oⁿ^p^e^titioⁿ^ap^p^r^o^v^{als in}^L^o^s^Aⁿ^g^e^le^{s, Mr}^{s. Saleh}ⁱ^w^o^u^l^d^h^a^v^e^b^een
^elig^{ible f}^o^r^th^{at w}^aⁱ^v^{er. A}^l^t^h^ou^gh^t^h^e^occu^rren^{ce o}^f^death^pr^{ior to t}^w^o^y^ears^o^f^m^a^rria^g^{e is}

^{rare, th}^e^w^aⁱ^v^{er is}^rou^tⁱⁿ^el^y^giv^eⁿ^f^o^{r hum}^anⁱ^t^arian^reas^onsⁱⁿ^{a cas}^{e of}^t^h^is^t^y^{pe if}^t^h^e
^p^e^titioⁿ^f^o^r^coⁿ^d^itioⁿ^a^{l p}^e^r^m^aⁿ^en^{t r}^e^sⁱ^d^eⁿ^{ce h}^a^{s b}^een^ap^p^r^o^v^ed^.
Private Law No. 105-8
H.R. 1834
Title: Private Bill; For the relief of Mercedes Del Carmen Quiroz Martinez Cruz.
Sponsor: Rep. Bateman, Herbert H. [R-VA-1] (introduced 6/7/1997)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 105-690
Latest Major Action: Enacted 11/10/1998.
Death of the U.S. Citizen Spouse During Pendency of Conditional Permanent Resident
Petition. The I.N.S. lost the petition for conditional permanent resident status filed by
beneficiary’s spouse; the beneficiary had a copy of the petition and a copy of its receipt from the
office where the petition was filed. Subsequently, the couple had a son who was a U.S. citizen at
birth. The beneficiary’s husband died of a heart attack a little over a year after the petition was
filed. At the time, the couple had been married about a month less than the two years which
would have permitted the beneficiary to file as the widow of a U.S. citizen; her petition as the
widow of a U.S. citizen was denied. If the agency had not lost her husband’s original petition on
her behalf, it likely would have been approved in a timely manner before her husband’s death.
The beneficiary would then have been eligible for a waiver of the two-year marriage requirement
to remove the conditions from her permanent resident status. The private law classified her as an
immediate relative, thus able to petition as a widow notwithstanding the length of her marriage,
and permitted her to adjust her status.
Private Law No. 105-9
H.R. 1949
Title: Private Bill; For the relief of Nuratu Olarewaju Abeke Kadiri.
Sponsor: Rep. Yates, Sidney R. [D-IL-9] (introduced 6/17/1997)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 105-524
Latest Major Action: Enacted 11/10/1998.
Alien Abandoned While a Minor by Parent Who, Unbeknownst to Her, Never Completed
Her Adjustment to Permanent Resident Status. The beneficiary was brought to the United
States as a minor child by her parents who subsequently separated and left their children with
cousins who raised the children as their guardians. The mother’s whereabouts were apparently
unknown; the father returned permanently to their home country after filing for and receiving
temporary resident status for his children under amnesty of the Immigration Reform and Control
Act of 1986. He never completed the adjustment of status for his children to permanent residents.
Neither the children nor their guardians realized this. By the time this was discovered, the
deadline had passed for completing the amnesty process by filing for adjustment to permanent
resident status. Although the beneficiary (still a minor at the time) immediately filed a petition
upon discovering that she did not have permanent status, the petition was denied as not timely
filed. Her only known family all resided in the United States where she had resided since she was
a young child; she had no other ties.

Private Law No. 105-10
H.R. 2744
Title: Private Bill; For the relief of Chong Ho Kwak.
Sponsor: Rep. Gekas, George W. [R-PA-17] (introduced 10/24/1997)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 105-645
Latest Major Action: Enacted 11/10/1998.
Waiver of Naturalization Oath for Incapacitated, Approved Applicant. The beneficiary was
approved for naturalization and scheduled to take the oath of allegiance on June 14, 1996. On
February 4, 1996, the beneficiary was shot in the head during the armed robbery of a grocery
store he owned. Although in a stabilized semi-comatose state, he has never regained
consciousness since the shooting. At the time this private law was enacted, immigration law
prohibited the naturalization of anyone who was unable to take and understand the oath. The
House Report noted, “It is clear Mr. Kwak intended to naturalize, that it was in no way his fault
that he did not complete that process, and that this is a unique situation.” Subsequent to this
legislation, the INA was amended in 2000 to permit the waiving of the oath for a person who is
unable to understand or communicate an understanding of the oath due to a physical or
developmental disability or mental impairment.

Private Law No. 106-3
H.R. 322
Title: Private Bill; For the relief of Suchada Kwong.
Sponsor: Rep. Rogan, James E. [R-CA-27] (introduced 1/6/1999)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 106-178
Latest Major Action: Enacted 12/3/1999.
Death of the U.S. Citizen Spouse During Pendency of Conditional Permanent Resident
Petition. Through no fault of the beneficiary and her deceased spouse, their petition for her
conditional permanent resident status was not approved prior to his death in a car accident. Due to
the beneficiary’s pregnancy, she was unable to undergo chest x-rays to determine definitively
whether she had tuberculosis, which would have rendered her inadmissible until she was cured.
Her husband died shortly after she gave birth to their U.S. citizen child and had chest x-rays
showing she did not have tuberculosis, but before their interview and approval of their petition.
Immigration regulations only permit approval of a widow’s self-petition where the couple has
been married at least two years and a waiver of the two-year requirement is given only where the
approval had already been granted at the time of the spouse’s death. Therefore, the private law
was necessary to enable the beneficiary to be granted permanent resident status. The House
Report noted the recent precedent of Private Law 105-7 and the additional factor of a U.S. citizen
child.

Private Law No. 106-4
S. 452
Title: Private Bill; A bill for the relief of Belinda McGregor.
Sponsor: Sen. Hatch, Orrin G. [R-UT] (introduced 2/24/1999)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-364
Latest Major Action: Enacted 5/15/2000.
I.N.S. Error re Diversity Program. This private law deemed Belinda McGregor and any child
of hers to have been selected for diversity visas under the FY2000 diversity visa program to
correct errors by the I.N.S. that resulted in her not receiving a diversity visa. Due to I.N.S.
mistakes arising out of confusion about her Austrian/British dual nationality and eligibility for a
diversity visa and a simultaneous application by her husband, an Irish national, Belinda
McGregor was not informed that she had been selected for a diversity visa until it was too late for
her to send in additional documents to apply for one. The I.N.S. does not have the authority to
correct such errors, therefore a private law was necessary.
Private Law No. 106-7
S. 302
Title: Private Bill; A bill for the relief of Kerantha Poole-Christian.
Sponsor: Sen. Torricelli, Robert G. [D-NJ] (introduced 1/25/1999)
Cosponsors: (none)
Committees: Senate Health, Education, Labor, and Pensions; Senate Judiciary; House Judiciary
H.Rept. 106-906
Latest Major Action: Enacted 10/13/2000.
Adoption Final after 16^th Birthday. The beneficiary’s mother had been working and residing in
the United States with the beneficiary. Leaving the beneficiary with friends in the United States,
she returned to Jamaica to be interviewed for an immigrant visa but was denied. She and the
natural father relinquished parental rights and authorized the friends to proceed with the adoption
of the beneficiary before she was 16 years old; during the process, the natural mother passed
away. The House Report noted:
^In^{order f}^o^r^an^adopt^{ee t}^o^l^a^w^f^ul^l^yⁱ^m^mⁱ^g^r^at^{e t}^o^t^h^{e U}ⁿⁱ^t^e^d^S^t^at^es^{, t}^h^{e i}^m^mⁱ^g^r^atⁱ^oⁿ^l^a^w
^requ^ires^an^adoption^to^h^a^v^e^o^ccu^{rred prior}^{to th}^{e ag}^{e of}^{16. Becau}^s^e^Keran^t^h^a^’^s^adoption^th
^w^a^{s n}^o^{t co}^m^p^leted^uⁿ^til^h^e^r¹⁷^bⁱ^r^t^h^d^ay^{, s}^h^e^w^o^u^l^dⁿ^eed^{a p}^r^iv^{ate b}^{ill in}^o^r^d^e^r^to^g^aⁱⁿ
^perm^aⁿ^eⁿ^{t res}ⁱ^den^{ce.... T}^h^e^preceden^{t con}^cernⁱ^ng^adoption^cas^es^is^w^e^ll^-^e^stablish^e^d.
^P^r^eced^en^{t d}ⁱ^{ctates th}^{at i}ⁿ^o^r^d^e^{r f}^o^{r f}^a^v^o^rab^l^{e co}ⁿ^s^id^eratioⁿ^o^f^{a p}^r^iv^{ate b}^{ill t}^h^{at allo}^w^s^aⁿ
^ad^o^p^tioⁿ^to^b^e^coⁿ^s^id^er^ed^leg^iti^m^a^te^f^o^rⁱ^m^mⁱ^g^r^atioⁿ^p^u^r^p^o^s^{es, th}^{e ad}^o^p^tioⁿⁿ^eed^{s to}^h^a^v^e
^been^fⁱⁿ^a^{lized a}ⁿ^d^m^u^st^h^a^v^e^been^{initiated prio}^{r to th}^{e ch}^ild^{’s tu}^rⁿⁱⁿ^g^{16.... It is clear f}^r^o^m
^th^{e docum}^eⁿ^tatioⁿ^prov^{ided th}^{at th}^{e C}^h^ri^s^tiaⁿ^s^w^e^re^activ^el^y^proceedin^g^wⁱ^t^h^th^e^adoption^th
^p^r^io^r^to^Ker^aⁿ^t^h^a^’^s¹⁶^birth^d^a^y^.

Private Law No. 106-8
H.R. 3646
Title: Private Bill; For the relief of certain Persian Gulf evacuees.
Sponsor: Rep. Rahall, Nick J., II [D-WV-3] (introduced 2/10/2000)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 106-580
Latest Major Action: Enacted 11/7/2000.
Persian Gulf War Evacuees with U.S. Ties. This private law provided for the adjustment to
LPR status for a group of named individuals who were evacuated from Kuwait during the Persian
Gulf War because they were the parents of U.S. citizen children or had secretly protected U.S.
citizens during the Iraqi invasion and occupation of Kuwait. A total of 2,227 persons were
evacuated, the majority of whom were Palestinian. The group was initially paroled into the
United States and later granted deferred enforced departure. Over the years, the majority adjusted
status through employer-sponsored visas and other means. Kuwait declined to receive any
deportees; although most had been long-time residents, they were not Kuwaiti nationals.
Although most could have been deported to Jordan, which grants passports to Palestinians, most
had never even been to Jordan. The private law was intended to permanently resolve the situation
by enabling permanent resident status for the remaining evacuees who had not otherwise adjusted
status and were unable to do so. The legislation was done as a private bill rather than as a public
law because, under private bill procedures, a request for information from the I.N.S. would result
in a stay of any further action regarding deportation of the evacuees until negative action on the
bill.
Private Law No. 106-10
H.R. 848
Title: Private Bill; For the relief of Sepandan Farnia and Farbod Farnia.
Sponsor: Rep. Istook, Ernest J., Jr. [R-OK-5] (introduced 2/24/1999)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 106-894
Latest Major Action: Enacted 11/9/2000.
Aliens Brought to U.S. as Children with Only U.S. Family and Ties Remaining. This private
law granted permanent residence to two young adult beneficiaries who were brought to the
United States as young children by their mother. The mother and her two sons had fled Iran after
the execution of the father and being in hiding for one year. Their asylum claims had been denied.
In the meantime, the brothers had grown up and their mother had died. The factors favoring relief
appear to have been the tragic circumstances and the fact that the two brothers were law-abiding,
employed college students raised in the United States by extended family and had no familial,
cultural, or linguistic ties to their native country.

Private Law No. 106-11
H.R. 3184
Title: Private Bill; For the relief of Zohreh Farhang Ghahfarokhi.
Sponsor: Rep. Waxman, Henry A. [D-CA-29] (introduced 10/28/1999)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 106-893
Latest Major Action: Enacted 11/9/2000.
Former Wife of Lawful Permanent Resident Needed Lawful Status to Remain in the United
States with Children. This private law granted permanent residence to the beneficiary to prevent
extreme hardship to her two daughters, the younger of whom was a U.S. citizen aged 11 years at
the time of the law’s enactment, if they were deprived of her support. The beneficiary had been
recently divorced from her husband who according to the House Report had used the laws in their
home country of Iran to prevent the beneficiary from returning to the United States after a visit
there and had removed her name from his application for lawful permanent residency on behalf of
himself, his wife, and their non-U.S. citizen elder daughter. Without the private law, the recently
divorced beneficiary would have had no way to remain lawfully in the United States for the near
future, since her U.S. citizen daughter was too young to file a petition for her mother and her
elder daughter would not be eligible to become a citizen for several years.
Private Law No. 106-12
H.R. 3414
Title: Private Bill; For the relief of Luis A. Leon-Molina, Ligia Padron, Juan Leon Padron, Rendy
Leon Padron, Manuel Leon Padron, and Luis Leon Padron.
Sponsor: Rep. Moran, Jerry [R-KS-1] (introduced 11/16/1999)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 106-892
Latest Major Action: Enacted 11/9/2000.
I.N.S. Error re Diversity Program. This private law deemed the Leon family to have been
selected for diversity visas under the FY2001 diversity visa program to correct an error by the
I.N.S. Although the beneficiaries had been denied asylum after their arrival from Ecuador, the
head of the family was selected for a diversity visa under the program for FY1996. According to
the House Report, although the family’s applications for adjustment of status were approved and
they were slated for the allocation of visas, the final processing of their visas was interrupted by
the shutdown of the Federal Government in December 1995 and their file was misplaced without
further action by the time the Diversity Visa Program for that fiscal year had expired.
Private Law No. 106-13
H.R. 5266
Title: Private Bill; For the relief of Saeed Rezai.
Sponsor: Rep. Cannon, Chris [R-UT-3] (introduced 9/21/2000)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 106-905
Latest Major Action: Enacted 11/9/2000.

Chronic Serious Illness of U.S. Citizen Spouse. This private law provided for LPR status for the
beneficiary because of the serious illness of his spouse. The I.N.S. had denied a petition by his
second wife for adjustment of status for the beneficiary due to marriage fraud concerns with
respect to his first marriage. The I.N.S. acknowledged that the second marriage was valid. The
House Report noted:
^Ms^{. R}^{ezai h}^a^s^been^diagn^o^s^e^d^wⁱ^t^h^m^u^l^{tiple s}^c^lerosⁱ^s^.^{Her doctor h}^a^sⁱⁿ^{dicated th}^a^t^s^h^e^m^a^y
^rapidly^{deteriorate as}^{a res}^u^lt^of^aⁿ^y^t^y^pe^of^s^e^v^e^re^s^t^res^s^{.... T}^h^{e s}^t^an^{dard f}^o^{r a priv}^a^t^e
ⁱ^m^mⁱ^g^r^atioⁿ^b^{ill b}^eⁱⁿ^g^ap^p^r^o^p^rⁱ^{ate is th}^{at th}^{e case in}^v^o^lv^e^s^an^alien^w^h^o^h^a^{s an}^uⁿ^u^s^u^a^l
^problem^t^h^at^w^o^u^l^{d res}^u^ltⁱⁿ^e^x^tre^m^e^h^a^rds^h^{ip to a Un}ⁱ^t^{ed S}^t^ates^citizeⁿ^s^pous^{e, paren}^t^or
^ch^ild^o^r^to^th^{e alien}^b^eⁿ^e^fⁱ^ciar^{ies th}^e^m^sel^v^es^{. B}^ecau^{se o}^f^Mr^{s. Rezai’s co}ⁿ^d^itioⁿ^,^thⁱ^s^case
^m^eets^t^h^{at s}^t^an^dard.
Private Law No. 106-14
S. 11
Title: Private Bill; A bill for the relief of Wei Jingsheng.
Sponsor: Sen. Abraham, Spencer [R-MI] (introduced 1/19/1999)
Cosponsors: 10
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-955
Latest Major Action: Enacted 11/22/2000.
Pro-Democracy Activist. This law provided for LPR status for the beneficiary, an internationally
recognized pro-democracy and human rights activist from the People’s Republic of China who
served 18 years in prison and labor camps there for his pro-democracy political activities until he
was released to seek medical treatment in the United States. He was a visiting scholar at
Columbia University and had a pending employment-based immigration petition at the time this
private legislation was under consideration.
Private Law No. 106-15
S. 150
Title: Private Bill; A bill for the relief of Marina Khalina and her son, Albert Mifakhov.
Sponsor: Sen. Wyden, Ron [D-OR] (introduced 1/19/1999)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-956
Latest Major Action: Enacted 11/22/2000.
Chronic, Serious Medical Condition Requiring Ongoing Treatment. This private law
provided for LPR status for the beneficiaries, a Russian woman and her son, who had cerebral
palsy with spastic diplegia and was undergoing medical treatment in the United States which was
unobtainable in Russia. The beneficiaries originally entered the country on visitor visas, which
were extended, but deportation proceedings were initiated upon the expiration of all possible
extensions and other avenues for relief. The son needed continued medical treatment including
additional surgeries until he reached physical maturity between 18 and 21 years of age. The
beneficiaries had no other avenue for staying in the United States on a more permanent basis, had
successfully assimilated in the United States and had no ties to Russia other than the mother’s
parents.

Private Law No. 106-16
S. 276
Title: Private Bill; A bill for the relief of Sergio Lozano.
Sponsor: Sen. Feinstein, Dianne [D-CA] (introduced 1/21/1999)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-958
Latest Major Action: Enacted 11/22/2000.
Death of Parent Sponsor Before Arrival of Immigrant Children in the United States. This
private law provided for LPR status for the oldest of three siblings who arrived in the United
States from El Salvador after the death of their mother. The three had been approved for
immigrant visas to join their mother, a lawful permanent resident. While she was making final
preparations to bring them to the United States, she passed away. The maternal grandmother
instructed the children to board an airplane bound for the United States. Upon arrival, the
immigration authorities determined that, due to the death of the mother, the immigrant visas of
the children were invalid. They were paroled into the United States. The younger siblings became
wards of the court, which applied for special immigrant juvenile visas on their behalf. Sergio
Lozano, who turned 18 years old shortly after arrival in the United States, could not receive a visa
in the manner his siblings had. He has no family in El Salvador and separation from his younger
siblings would have been an extreme hardship for them. The private law was his only avenue for
relief.
Private Law No. 106-18
S. 869
Title: Private Bill; A bill for the relief of Mina Vahedi Notash.
Sponsor: Sen. Feinstein, Dianne [D-CA] (introduced 4/22/1999)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-960
Latest Major Action: Enacted 11/22/2000.
Former Battered Wife Needed Lawful Status to Remain in the United States and Dispute
Child Custody. The private law provided for LPR status for the beneficiary, who otherwise
would have been unable to remain in the United States to seek custody of her children. The
beneficiary was brought to the United States illegally by her ex-husband, who abused her
physically and threatened her with deportation. After their two children were born, he told her he
would petition for her legal status, but that she had to return to Iran first. When she did so, he
divorced her under Iranian law, which meant that she could not dispute the divorce or the custody
in Iran. She returned to the United States on a fiancée visa, but her engagement ended when her
fiancé learned that she wished to regain custody of her children. The beneficiary had no visitation
rights with her children and was concerned that they might be suffering physical abuse. Without
the private law, she would have been unable to remain in the United States to dispute custody and
might never have seen her children again.

Private Law No. 106-19
S. 1078
Title: Private Bill; A bill for the relief of Mrs. Elizabeth Eka Bassey, Emmanuel O. Paul Bassey,
and Mary Idongesit Paul Bassey.
Sponsor: Sen. Helms, Jesse [R-NC] (introduced 5/19/1999)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-961
Latest Major Action: Enacted 11/22/2000.
Death of the Primary Visa Recipient (State Department Career Employee) Prior to Family
Immigration. Paul Bassey, the husband and father of the beneficiaries, was a Nigerian national
who was a career employee of the U.S. State Department. In 1991, he received special immigrant
status from the State Department in recognition of his service to the U.S. Government and was ^th
later approved for an employment 4 preference visa petition as a result of his special immigrant
status. However, that same year, civil war broke out in Zaire and the U.S. Embassy there asked
Mr. Bassey to delay his retirement for a year to assist them during this crisis. In 1992, Mr. Bassey
passed away before he and his family could emigrate to the United States. His family was
informed that they were not eligible to receive special immigrant status on their own, although
they all would have been eligible as his accompanying immediate family. At the time of the
private law enactment, the widow and one of the children had been paroled into the United States
for humanitarian reasons; the other children were in the United States on student visas. The
private law enabled them to adjust to LPR status.
Private Law No. 106-20
S. 1513
Title: Private Bill; A bill for the relief of Jacqueline Salinas and her children Gabriela Salinas,
Alejandro Salinas, and Omar Salinas.
Sponsor: Sen. Thompson, Fred [R-TN] (introduced 8/5/1999)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-962
Latest Major Action: Enacted 11/22/2000.
Serious Medical Condition Requiring Ongoing Treatment. This private law provided LPR
status to the beneficiaries, a mother and three of her children, because of the extreme hardship
they would otherwise suffer, particularly the child with a serious illness for which treatment could
not be obtained in their home country. The child with a rare bone cancer came to the United
States with her father from Bolivia. St. Jude’s Children’s Hospital offered treatment at no cost to
the family. The rest of the family joined them in the United States. A car accident resulted in the
death of the father, one child, and the permanent paralysis of the mother from the waist down.
The mother, who was pregnant at the time of the accident, gave birth to a U.S. citizen child. The
Hospital offered complete financial support to enable the family to reside permanently in the
United States. The disability of the surviving parent and the need for ongoing cancer treatment for
the sick child would have caused the family an extreme hardship if they had had to return to
Bolivia. The private law was the only avenue by which they could obtain LPR status and a waiver
for the public charge ground for inadmissibility.

Private Law No. 106-21
S. 2000
Title: Private Bill; A bill for the relief of Guy Taylor.
Sponsor: Sen. Feinstein, Dianne [D-CA] (introduced 1/24/2000)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-963
Latest Major Action: Enacted 11/22/2000.
Permanent Residency for a Young Adult Paroled into the United States as a Minor. This
private law provided for permanent resident status for a young adult who was the orphaned child
born abroad to a U.S. citizen mother and a father of unknown citizenship and raised primarily in
the United States, first by his mother and later by his maternal grandmother as guardian. The
young man wished to enlist in the U.S. military, but needed to have LPR status to do so. He had
been paroled into the United States, but was too old to qualify as a dependent of his grandmother
at the time of his mother’s death. The private legislation was necessary to enable him to enlist in
the military and reside in the United States permanently. It is not clear from the legislative history
why the beneficiary was not considered a U.S. citizen-at-birth through his mother.
Private Law No. 106-22
S. 2002
Title: Private Bill; A bill for the relief of Tony Lara.
Sponsor: Sen. Feinstein, Dianne [D-CA] (introduced 1/24/2000)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-964
Latest Major Action: Enacted 11/22/2000.
Permanent Residency for a Young Adult Who Had Been Abandoned as a Minor. This private
law provided for LPR status for the beneficiary, who was brought to the United States from El
Salvador illegally by his parents when he was a young child. The mother drowned while trying to
reenter the United States after being deported; the father was deported after several drug arrests
and had no contact with the beneficiary. The beneficiary and his sister were eventually taken in by
U.S. family friends who could only afford to adopt the sister. The beneficiary eventually moved
in with the family of his high school wrestling coach; he became a champion wrestler. Although
he wished to apply for permanent residency earlier, he was incorrectly advised that he would be
deported. While he was a minor, he could have become a ward of the court and become a special
juvenile immigrant. He had no ties with El Salvador, maintained ties to his sister, and was
supported in his efforts by his wrestling coach and the coach’s spouse. The private law was the
only avenue by which the beneficiary could lawfully remain permanently in the United States
since he was no longer a minor.
Private Law No. 106-23
S. 2019
Title: Private Bill; A bill for the relief of Malia Miller.
Sponsor: Sen. Kyl, Jon [R-AZ] (introduced 2/1/2000)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-965
Latest Major Action: Enacted 11/22/2000.

Death of the U.S. Citizen Spouse During Pendency of Conditional Permanent Resident
Petition. Through no fault of the beneficiary she was unable to satisfy the marriage requirements
for an alien spouse petition because her U.S. citizen spouse was killed in a helicopter crash
abroad before her petition for conditional permanent resident status was approved. The
beneficiary had already entered the United States on a visitor visa and given birth to the couple’s
son. She was granted humanitarian parole to leave the United States to make arrangements
concerning her husband’s funeral and to reenter the United States. Immigration regulations only
permit approval of a widow’s self-petition where the couple has been married at least two years
and a waiver of the two-year requirement is given only where the approval had already been
granted at the time of the spouse’s death. Therefore, the private law was necessary to enable the
beneficiary to be granted permanent resident status. The House Report noted the recent precedent
of Private Law 105-7 and the additional factor of a U.S. citizen child. It also emphasized the
hardship that would be suffered by the child if he had to leave the United States and break the
bond already established with his paternal grandparents and other family/friends in his
community.
Private Law No. 106-24
S. 2289
Title: Private Bill; A bill for the Relief of Jose Guadalupe Tellez Pinales.
Sponsor: Sen. Grassley, Chuck [R-IA] (introduced 3/23/2000)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 106-966
Latest Major Action: Enacted 11/22/2000.
Permanent Residency for a Young Adult Brought to the United States Illegally as a Child.
The beneficiary’s father had been killed in an accident and his mother was unable to support him
in addition to another child. Therefore, he was brought into the United States from Mexico
illegally by his great uncle when he was toddler and raised by his great uncle and his first wife,
whom he believed to be his parents. The great uncle became a naturalized citizen and erroneously
believed that the beneficiary derived citizenship through his naturalization. When the beneficiary
was 15 years old, the uncle’s second wife discovered that there had been no formal adoption, by ^th
which time it was too late to complete a formal adoption before the beneficiary’s 16 birthday.
The House Report noted:
^J^o^s^e^wⁱ^s^h^ed^{to j}^oⁱⁿ^t^h^e^U.S.^Marin^e^C^o^rps^,^bu^t^f^o^uⁿ^d^th^a^t^h^e^{could n}^o^t^becaus^e^h^e^h^a^s^no
^l^e^g^a^l^st^at^us^{. It}^w^o^u^l^{d be an}^e^x^t^r^e^m^e^h^a^rdshⁱ^p^t^o^Jos^e^t^o^be^deport^e^{d t}^o^Mexⁱ^{co. H}^e^h^a^s
^resⁱ^{ded in}^th^{e U.S. s}ⁱⁿ^{ce t}^h^{e age of}^th^{ree, does}ⁿ^o^{t s}^p^eak^Span^is^h^,^an^{d b}^y^{all accoun}^ts^h^a^s^l^e^d
^an^ex^e^m^p^l^ar^y^lif^{e. I}^tⁱ^s^t^h^r^o^u^g^hⁿ^o^f^a^u^{lt o}^f^hⁱ^{s o}^wⁿ^t^h^{at t}^h^e^ad^u^{lts i}ⁿ^hⁱ^{s li}^f^e^dⁱ^dⁿ^o^{t ta}^k^e
^appro^p^{riate action}^s^{to pr}^ov^{ide h}ⁱ^m^le^g^a^{l s}^t^at^u^sⁱⁿ^th^{e U}ⁿ^it^{ed States}^{. He h}^a^sⁿ^o^av^eⁿ^u^e
^av^ailab^l^{e to}^hⁱ^mⁿ^o^w^to^g^e^{t th}^{at statu}^s^.

Private Law No. 107-1
S. 560
Title: Private Bill; A bill for the relief of Rita Mirembe Revell (a.k.a. Margaret Rita Mirembe).
Sponsor: Sen. Hatch, Orrin G. [R-UT] (introduced 3/19/2001)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 107-129
Latest Major Action: Enacted 7/17/2001.
Terminal Illness Made it Impossible to Satisfy the Requirements for an Orphan-adoption
Immigrant Petition. Mr. Dennis Revell and Ms. Maureen Reagan would have adopted Rita
many years earlier if they had been given the opportunity. Ms. Reagan’s terminal illness
prohibited her from ever traveling to Uganda to adopt Rita. The only way Mr. Revell and Ms.
Reagan could assure that Rita remained a part of their family in the United States was through a
private bill. The combination of Uganda’s adoption restrictions early in their relationship with
Rita and Ms. Reagan’s subsequent cancers had made it virtually impossible for Rita to be adopted
under the adoption laws of Uganda and in accordance with U.S. immigration law. But for those
factors, Rita would have been the adopted daughter of the only two people she had ever known to
be her parents. The uniqueness standard and extreme hardship standard for approval of private
bills was met through the combined facts of: (1) Ugandan adoption law prohibiting adoption of
Rita prior to February 2000; (2) Ms. Reagan’s illness being prohibitive of ever completing an
adoption; (3) Mr. Revell’s and Ms. Reagan’s total support of Rita since the age of 3; and (4) the
fact Rita had lived with Mr. Revell and Ms. Reagan since the age of 8 and they were the only
parents she had ever known.
Private Law No. 107-5
H.R. 2245
Title: Private Bill; For the relief of Anisha Goveas Foti.
Sponsor: Rep. Lantos, Tom [D-CA-12] (introduced 6/19/2001)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 107-579
Latest Major Action: Enacted 11/5/2002.
Death of the U.S. Citizen Spouse Who Was a Foreign Service Officer During Pendency of
Conditional Permanent Resident Petition. The beneficiary, Mrs. Goveas Foti, was married to a
United States citizen, Seth Foti, who perished in an airplane crash while performing official
duties for the United States Government. I.N.A. regulations concerning the untimely death of a
sponsoring spouse permit a waiver of the two-year marriage requirement only if the individual’s
petition for conditional permanent residence was approved prior to the death. The interview for
approval of Mrs. Foti’s petition for conditional permanent residence had not been scheduled
before Mr. Foti was killed on August 23, 2000. Had the interview occurred, Mrs. Foti would have
been eligible for that waiver. Although the occurrence of death prior to two years of marriage is
rare, the waiver is routinely given for humanitarian reasons in a case of this type if the petition for
conditional permanent residence has been approved. The House Report noted that, “By all
accounts this was a legitimate marriage, and it is through no fault of her own that Mrs. Foti has
not met the marriage requirements of the I.N.A. This case mirrors several other private laws
enacted in the last few years.”

Private Law No. 107-6
H.R. 3758
Title: Private Bill; For the relief of So Hyun Jun.
Sponsor: Rep. McCrery, Jim [R-LA-4] (introduced 2/13/2002)
Cosponsors: (none)
Committees: House Judiciary
H.Rept. 107-729
Latest Major Action: Enacted 12/2/2002.
Adoption Final after 16^th Birthday. According to the House Report, “The precedent concerning
adoption cases is well-established. Precedent dictates that in order for favorable consideration of a
private bill that allows an adoption to be considered legitimate for immigration purposes, the
adoption must have been initiated prior to the child’s turning 16 and must be finalized.”

Private Law No. 108-1
S. 103
Title: Private Bill; A bill for the relief of Lindita Idrizi Heath.
Sponsor: Sen. Nickles, Don [R-OK] (introduced 1/7/2003)
Cosponsors: (none)
Committees: Senate Judiciary; House Judiciary
H.Rept. 108-532
Latest Major Action: Enacted 7/22/2004.
Adoption Final after 16^th Birthday. As for Private Law 107-6, private bill precedent dictates
that in order to make an adoption legitimate for immigration purposes, the adoption must have
been at least initiated prior to the child’s turning age 16.
Private Law No. 108-3
H.R. 712
Title: Private Bill; For the relief of Richi James Lesley.
Sponsor: Rep. Wicker, Roger F. [R-MS-1] (introduced 2/11/2003)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 108-530
Latest Major Action: Enacted 10/30/2004.
Adjustment of Status for an Orphan Adoptee. The beneficiary was adopted abroad before his ^th
16 birthday (as an infant), but his parents apparently never complied with immigration
requirements, perhaps not knowing that they had to apply for an immigrant visa and/or
adjustment of status and, later, naturalization. The beneficiary thought he was a citizen until he
belatedly discovered otherwise.

Private Law No. 108-4
H.R. 867
Title: Private Bill; For the relief of Durreshahwar Durreshahwar, Nida Hasan, Asna Hasan, Anum
Hasan, and Iqra Hasan.
Sponsor: Rep. Holt, Rush D. [D-NJ-12] (introduced 2/13/2003)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 108-531
Latest Major Action: Enacted 10/30/2004.
Death of Petitioner from a 9/11-related Hate Crime During the Pendency of a Petition for
Adjustment to Permanent Resident Status for Immediate Relatives. On September 15, 2001,
in reaction to the events of September 11, an unstable man killed Mr. Hassan. Because Mr.
Hassan was the petitioner for the family’s adjustment, that petition became invalid upon his death.
Therefore, under the I.N.A. and its regulations, his wife and four daughters who lived in suburban
New Jersey faced removal from the United States. According to the House Report, “This private
bill, on behalf of the family, would not set any bad precedent. Though he did not die at the World ^th
Trade Center or the Pentagon, Mr. Hassan was indeed a victim of the events of September 11.
The Committee is preceding with this bill only because the murder is linked to 9/11. [emphasis
added] It is inappropriate, generally, for Congress to pass private bills to give status to the
families of noncitizens because those noncitizens were killed while in the United States.” A
minority comment was that the public law should be amended to permit family-unification
petitions to survive the death of the petitioner through no fault of the beneficiaries.
Private Law No. 108-6
H.R. 530
Title: Private Bill; For the relief of Tanya Andrea Goudeau.
Sponsor: Rep. Baker, Richard H. [R-LA-6] (introduced 2/4/2003)
Cosponsors: (none)
Committees: House Judiciary; Senate Judiciary
H.Rept. 108-529
Latest Major Action: Enacted 12/23/2004.
Adoption Final after 16^th Birthday. According to private bill precedent, in order to make an
adoption legitimate for immigration purposes, the adoption must have been at least initiated prior
to the child’s turning age 16. The beneficiary satisfied this condition; the adoption process was ^th
begun before her 16 birthday, but was not finalized until she had aged out of eligibility for an
adopted orphan visa.

P.L. 109-149, § 518
S. 103
Title: Departments of Labor, Health and Human Services, and Education, and Related Agencies
Appropriations Act, 2006.
Sponsor: Rep. Regula, Ralph [R-OH-16] (introduced 6/21/2005)
Cosponsors: (none)
Committees: House Appropriations; Senate Appropriations
H.Rept. 109-143; S.Rept. 109-103; Conference Report: H.Rept. 109-337
Latest Major Action: Enacted 12/30/2005.

Naturalization of Athletes for International Competition. Although no private laws for ^th
immigration relief were enacted in the 109 Congress, this provision enacted as part of a public
law was intended for the relief of a couple of award-winning athletes (Tanith Belbin and Maxim
Zavozin) who wished to represent the United States with their respective partners in the figure
skating events of the 2006 Winter Olympics. Under the Olympics rules, both partners in the ice
dancing or pairs events must be citizens of the country they are representing by the deadline for
submitting the final list of competitors representing a country. The athletes involved had not been
lawful permanent residents for the five years required to become naturalized U.S. citizens. They
could not benefit from changes in the processing of employment-based immigrant visas and
adjustment of status to permanent residence that would have enabled them to naturalize by the ⁴⁵
deadline if the new rules had been in effect when they had applied for visas. The relief provision
reduced the period of time required from five years to three years, which the athletes could
satisfy, and was limited to aliens of extraordinary ability who requested expedited naturalization
as necessary to represent the United States at an international event and who paid a premium
processing fee of $1,000. The provision, although of general application, was widely known to be
intended for the relief of these athletes and sunsetted on January 1, 2006, having been signed into
law by the President on December 30, 2005. Zavozin and Belbin completed the naturalization
process and were sworn in as citizens respectively on December 30 and 31, 2005. As noted
above, the House Subcommittee Rules disfavor the naturalization of an athlete for international
competition purposes, which may have been the reason for accomplishing the relief through a ^th
public law. Also, private immigration bills generally were not favored during the 109 Congress, ⁴⁶
as reflected by the fact that none were enacted, which had not occurred in at least 70 years.
Table A-1. Private Immigration Bills Introduced and Enacted, 104^th-110^th Congresses
^Cong^{ress Introdu}^ced^Enacted
¹⁰⁴^th²⁹²
¹⁰⁵^th⁶³⁹
¹⁰⁶^th¹²²¹⁸
¹⁰⁷^th⁶⁶³
¹⁰⁸^th⁹⁸⁴
¹⁰⁹^th¹¹⁷⁰
¹¹⁰^th²¹⁰
^Source:^{Congressional Researc}^h^{Service, based on information fr}^{om the Legislative Information Sy}^{stem of the}
^{U.S. C}^{ongress (LIS) and p}^{rivate laws from the}^{Statutes at}^Large.

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^statu^s^to^law^f^u^l^p^e^rm^an^en^{t resid}^eⁿ^t^{s u}ⁿ^til^th^e^uⁿ^d^e^rlyⁱⁿ^g^vⁱ^{sa p}^e^titioⁿ^s^h^a^d^b^een^ap^p^r^o^v^ed^{; receip}^t^o^f^su^ch^statu^s^to^o^k
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^Coⁿ^g^{ress an}^d^at^l^east^on^{e w}^a^{s en}^a^c^t^e^d^f^o^{r t}^h^{e 10}¹^to^th^e¹⁰⁸^Co^ngresse^s.

^Marg^{aret Miky}^ung^L^ee
^L^e^gⁱ^s^l^at^iv^{e A}^t^torn^e^y
^mm^l^e^e^@^crs^.^l^o^c.g^o^v^,^7-²⁵⁷⁹