Northgate Office Building
9750 Third Avenue NE, Suite 375
Seattle, Washington 98115
Tel: 206-624-9480
Fax: 206-223-1325
Email: david@davidwmerrell.com
Perspectives on Immigration Law

“The Immigration and Nationality Act is a bewildering and complex statute[.]” (1)

“[A]n almost overwhelmingly complex legal regime … ” (2)

“Congress … has enacted a baffling skein of provisions for the INS and courts to disentangle.” (3)

“Immigration and naturalization law has grown exceedingly complex in recent years as Congress tightens the law against aliens. … Intricacy is bound to increase post-September 11, 2001.” (4)

“Every immigration benefit has its own set of rules, regulations, and procedures. Many are complex and time-consuming to adjudicate. Some are so difficult to process that specialists must handle them.” (5)

“[I]nspectors at ports of entry, border patrol agents, immigration agents, immigration benefits adjudicators, and immigration attorneys and judges, were all stymied by rules that were fuzzy and time-consuming to implement.” (6)

“We are saddled with administering what my legal friends tell me is the most complicated set of laws in the nation. I am told it beats the tax code. … Six million to seven million applications have to be administered – adjudicated – against a body of law that is very complex and sometimes contradicting each other [sic].” (7)

“[W]e are in the never-never land of the Immigration and Nationality Act, where plain words do not always mean what they say.” (8)

“Although the density and complexity of the Act has been subjected to literary and mythological analogy, … (likening the immigration laws to King Minos’ labyrinth in ancient Crete), this is not a Lewis Carroll story and we are not in Wonderland.” (9)

“We’ll leave that to the lawyers to sort out.” (10)


1. Perez-Funez v. District Director, INS, 611 F. Supp. 990, 1002 (D. Ct. C.D. Calif. 1984).
2. Guyadin v. Gonzales, 449 F. 3d 465, 470 (2nd Cir. 2006).
3. Lok v. INS, 548 F. 2d 37, 38 (2nd Cir. 1977).
4. United States v. De Jesus Perez, 213 F. Supp. 229, 235 (D. Ct. E.D. N.Y. 2002).
5. Staff Report of the National Commission on Terrorist Attacks Upon the United States, at p. 98, (Aug. 21, 2004).
6. Testimony of Janice L. Kephart, former counsel for the National Commission on Terrorist Attacks Upon the United States, before a House Judiciary subcommittee. 109th Cong. (May 2005).
7. Testimony of Eduardo Aguirre, director of U.S. Citizenship and Immigration Services, before the House Appropriations Subcommittee on Homeland Security. 109th Cong. (March 2005).
8. Yuen Sang Low v. Attorney General, 479 F. 2d 820, 821 (9th Cir. 1973).
9. Matter of Ruiz-Romero, 22 I&N Dec. 486, 502 (Board of Immigration Appeals 1999).
10. Department of State’s Foreign Affairs Manual for consular visa officers, 9 FAM §40.26 Note 1, on an issue of statutory interpretation.