The Contested Politics

of Mobility
Borderzones and irregularity

Edited by Vicki Squire

@.011

I~ ~~o~!~~n~~~up
LONDON AND NEW YORK

Contents

Notes on contributors
Acknowledgements

The contested politics of mobility:

politicizing mobility, mobilizing politics

XVII
XX

VICKI SQUIRE

PART I

Politicizing mobility
Politicizing mobility

27
29

VICKI SQUIRE

2 Freedom and speed in enlarged borderzones

31

DIDIER BIGO

3 Rezoning the global: technological zones, technological

work and the (un-)making of biometric borders

51

WILLIAM WALTERS

f7~orderzones of enforcement: criminalization,

~orkplace raids, and migrant counterconducts

74

JONATHAN XAVIER INDA

5 Alien powers: deportable labour and the spectacle of security

91

NICHOLAS DE GENOVA

PART II

Mobilizing politics
Mobilizing politics
VICKI SQUIRE

117
119

xvi

Contents

6 The gaze of autonomy: capitalism, migration and social struggles

121

SANDRO MEZZADRA (TRANSLATED BY RODRIGO NUNES)

7 Governing borderzones of mobility through e-borders:

the politics of embodied mobility

143

KIM RYGIEL

8 Legal exclusion and dislocated subjectivities:

the deportation of Salvadoran youth from the United States

169

SUSAN BIBLER COUTIN

9 Forms of irregular citizenship

184

PETER NYERS

10 Citizens despite borders: challenges to the territorial order ofEurope

199

ENRICA RIGO

Epilogue
The movements of politics: logics, subjects, citizenships

216

ENGIN !SIN

Index

232

Borderzones of enforcement
Criminalization, workplace raids,
and migrant counterconducts 1
Jonathan Xavier Inda

'\.

On December 12, 2006, US Immigration and Customs Enforcement (fCE) raided

Swift & Company meatpacking plants in six states: Colorado, Nebraska, Texas,
Utah, Iowa, and Minnesota (US ICE 2006). Taken into custody were 1,282 suspected undocumented migrants, most of whom were Latino (that is, of Latin
American origin). A majority of these individuals simply faced deportation for
being present in the United States without authorization (see Bibler Coutin, this
volume). However, 65 were charged with criminal violations related to identity
theft or other infractions (i.e. re-entry after deportation). Not only were these
migrants looking at deportation, they also potentially faced time in prison.
The arrestees were not the only ones affected by the raid. There was plenty of
collateral damage. Migrant families were particularly hard hit. Many lost their
primary breadwinner. Husbands were separated from wives, parents from children, and siblings from each other. The broader migrant community in the towns
where the raids took place also suffered. The city of Marshalltown, Iowa, for
example, witnessed a decrease in its Latino population as a result ofiCE's operations (Perkins atid Piller 2007). Not only did the arrestees leave, but so did other
migrants who were fearful of further raids. Some left Marshalltown to pursue jobs
in other states, while others returned to their home countries, mainly Mexico and
various Central American nations. These departures greatly impacted on those
migrants who stayed behind. For example, Latino businesses suffered heavily. As
Marcela Hernandez, an employee at La Guadalupana bakery, put it:
[The raid has] affected the restaurants, the stores and other businesses ....
People keep leaving, even a year later.... People have fear because they don't
know what will happen. They don't have any security. Every day, they hear
about more raids in other states and they are reminded of the raid last year.
(Cited in Perkins and Piller 2007)
The raids that took place against Swift & Company are not unique. In fact, raids
became rather commonplace in the United States during the presidency of George
W. Bush, and they have continued, to some extent, under the new Obama administration. In this chapter, I focus on the increased salience of workplace raids in
the management of irregular migrants in the US. Specifically, I locate such raids

Borderzones of enforcement

75

as part of a broader practice of government that has aggressively criminalized

undocumented migrants (see De Genova 2002; Coutin 2005; Rosas 2006; Inda
2006a; Hernandez 2008; Heyman 2009). I call this practice governing immigration through crime. Basically, to govern immigration through crime is to make
crime and punishment the institutional context under which the efforts to guide
the conduct of migrants takes place. The objective is to shape the comportment of
the undocumented in such a way as to incapacitate them and contain the 'threa~'
they and their actions putatively pose to the security the nation. The most notable
form that this way of ~overning has assumed over the last 20 years or so is that of
intensified law enforcement at the nation's borders. More recently, however, governmental authorities have also placed a strong emphasis on the interior policing
of the United States. Since the early 2000s, for example, criminal prosecutions of
immigration violations have increased; local and state law enforcement agencies
have become progressively more involved in policing immigration matters; the
number of undocumented migrants incarcerated in county jails, federal prisons,
and immigration detention centers has surged; and, most significantly for our purposes, immigration raids have become commonplace. What we have witnessed,
then, is the progressive criminalization of migrants and a significant expansion
in the space of policing. Essentially, the boundaries of immigration policing have
migrated inwards, turning countless spaces in the interior of the United States
-from workplaces and homes to public spaces- into borderzones of enforcement
where governmental authorities endeavor to regulate 'dangerous' cross-border
illegalities.
I also want to propose, however, that interior borderzones are not simply spaces
of criminalization and policing. They are also political sites of struggle. Indeed,
while workplace raids and the policing of immigrants may have escalated, the
undocumented have not simply accepted the new status quo. Rather, the effort
to govern immigration through crime has been actively resisted by migrants and
their allies. They have engaged in what could be called migrant 'counter-conducts'
(Gordon 1991; Foucault 2007). These are acts or forms of comportment that contest the criminalization and exclusion of irregular migrants. The counterconducts
that migrants have been involved with include labor strikes, hunger strikes for
justice, advocacy for legalization and political rights, the occupation of churches
as a way of gaining sanctuary, public demonstrations, and fights for legal redress
for unpaid wages (McNevin 2009). Here I specifically examine antiraid public
protests and legal challenges to the criminalization of migrants. Such counterconducts, I suggest, ultimately speak to the political becoming of irregular migrants
and their enactments of citizenship.

nt (ICE) raided
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Governing immigration through crime

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Since the 1970s, crime and punishment have become an increasingly central means
through which political authorities in the United States seek to govern the conduct
of individuals and populations, a development that Jonathan Simon (1997) refers
to as 'governing through crime'. This way of governing is intimately connected

', \ I ,

76

Jonathan Xavier Inda

to the decline of the social and the rise of neo-liberal rule (see Inda 2006a; Pratt
2005). Put briefly, the ideal of the social-welfare state, dominant for much of the
twentieth century in the US, has generally yielded to that of the neo-liberal state.
This new ideal is such that the political apparatus no longer appears obligated to
safeguard the well-being of the population through maintaining a sphere of collective security. Social insurance- as an ensemble of state mechanisms that sought
to insure individuals against the insecurities of social life- has thus largely given
way to the privatized and individualized government of risk. Individuals afe now
asked to take upon themselves the primary responsibility for managing their own
security and that of their families. They are expected to adopt an entrepreneurial
disposition towards life and insure themselves (using market mechanisms) against
the vicissitudes of ill health, accidental loss, unemployment, and anything else
that could potentially threaten their contentment. Significantly, in placing such a
strong emphasis on individual responsibility, neo-liberal rule has tended to draw
a rather marked distinction between the proper neo-liberal citizen who secures
his/her own well-being through active self-promotion and the deviant anticitizen
- the criminal, the homeless, the welfare recipient- who is deemed incapable of
managing his/her own risks and thus lies outside the nexus of responsible activity.
While the government of the former has largely taken place through the mechanisms of market and outside the formal political apparatus, the regulation of the
latter has increasingly occurred through the widening reach of the repressive arms
of the state. Indeed, law and order measures have become the preferred institutional contexts through which the government of marginal subjects is effected.
Governing through crime in the United States has come to be instantiated in a
number of specific practices. This facet of neo-liberal rule is clearly visible, for
instance, in the widespread popularity of tough-on-crime sentencing regimes of
just desserts, deterrence, and retribution. These regimes include such measures
as quality of life campaigns and zero tolerance policing, harsher penalties and
the extensive utilization of imprisonment, three strikes and compulsory minimum
sentencing policies, redress in juvenile court and the incarceration of minors, and
more extensive parole restrictions (Garland 2001: 12). Governing through crime
is further visible in the common practice of securitizing private spaces as a way
of dealing with crime risks and insecurities. The most notable manifestations of
this practice are undoubtedly fortified enclaves (i.e., gated communities) (Blakely
and Snyder 1997). These enclaves are segregated spatial enclosures designed to
provide a safe, orderly, and secure environment for those who dwell within them.
The rationale for governing through crime seems to be twofold. On the one hand,
the thinking is that irresponsible individuals must be held accountable for their
misdeeds and that they must be made to shoulder the burden of their lifestyle
decisions. The calculus of punishment thus serves to press upon the offending
(and potentially offending) agent the importance of being prudent and governing
oneself responsibly. And on the other hand, it is that responsible citizens must
protect themselves and be protected from the hoards of anticitizens who threaten
their security and quality of life. The containment of the few therefore becomes a
prerequisite for the freedoms of the many.

Borderzones ofenforcement

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77

This neo-liberal emphasis on governing through crime has had a significant

impact on how irregular migration is problematized and managed. In fact, irregular
migration has come to be seen largely as a law and order issue in the contemporary
United States. Since the early 1990s, the US has witnessed a rather strong wave of
anti-immigrant sentiment- a trend that has only intensified in the post-September
11, 2001 (9/11) context. From social scientists, immigration officials, and policy
analysts to immigration reform organizations and the public at large, it has been
common for individuals and groups to cast irregular migrants- typically imagined
as Mexican - as threats to the overall well-being and security of the social body
(Inda 2006a; Chavez 2008). The fundamental problem with the undocumented has
been deemed to be their illegality. For some, to be an 'illegal immigrant' is to inherently be a lawbreaker; it is to be necessarily a criminal. The criminality of irregular
migrants is generally attributed to the idea that they do not have a legal right to be
in the United States. Take, for example, a basic government definition of unauthorized persons: 'An illegal alien is a person who is in the United States in violation
of US immigration laws' (US GAO 1995: 1). Or consider the following statements
drawn from policy and mass media documents: 'Illegal aliens are of concern to law
enforcement officials, urban planners, and policymakers, first, because they are
lawbreakers' (US GAO 1993: 10); 'The effect illegal immigration has on the economy is irrelevant. Whether illegal immigration stimulates or burdens economic
growth is of no importance to the residual fact that the law is being broken. Illegal
immigration is illegal. Period' (Olson 1994: Commentary 5):

I
I

One of the most common and devastating crimes committed in America is

committed by people who are not even American citizens. To many, it is not
even considered a crime, even though its name, illegal immigration, makes
it clear that it is .... People who enter or stay in this country illegally are
criminals by definition.
(Coleman 1994: B11)
In addition to being constructed as lawbreakers, irregular migrants have routinely
been linked to a host of other problems. For example, they have been associated with such cultural, social, and economic maladies as overpopulation, deteriorating schools, urban crime and decay, energy shortages, and national disunity.
Furthermore, they have been accused of displacing American workers, depressing
wages, spreading diseases, and burdening public services. All of these 'problems'
are seen as compounding the fundamental problem of immigrant criminality (see
Bibler Coutin, this volume).
In the wake of 9/11, while irregular migrants continue to be constructed as
criminals, the threat they represent has come to be refigured in terms of homeland
security (see De Genova, this volume). 'Homeland security' is a way of thinking
and acting that developed in the wake of the 9111 'terrorist' attacks. It has been
defined as 'a concerted national effort to prevent terrorist attacks within the United
States, reduce America's vulnerability to terrorism, and minimize the damage
and recover from attacks that do occur' (OHS 2002: 2). What has basically

,.

78

Jonathan Xavier Inda

happened is that, subsequent to the 9/11 attacks, terrorism has generally become
regarded as the greatest threat facing the nation. Focusing on the fact that the 9111
hijackers were foreigners who somehow managed to get into the United States,
the movement of people in and out of the country has been seen as indissociable
from this threat. It is thus commonly expressed in policy and public rhetoric that
there is an ever present possibility that foreigners might seek to enter the US in
order to commit acts of terrorism. Moreover, this discourse strongly articulates
the need to protect against the threat of terrorism and safeguard the homeland.
Notably, the attitude of protecting the homeland has significantly influenced the
governing of immigration; whether terrorists or not, migrants have generally come
to be seen as threats to the security of the homeland. Protecting the nation thus not
only involves preventing terrorist attacks, but also mitigating the dangers posed
by irregular migrants (defined as 'illegal immigrants'). Indeed, the undocumented
have come be seen as threats to national security. The homeland on this reading
must be protected from these irresponsible 'criminals'.
Given that irregular migrants have largely been constructed as criminal 'illegal
immigrants' who harm the well-being of American citizens and threaten the security of the nation, the measures employed to govern them have been extremely
exclusionary and punitive. Put otherwise, irregular migrants have come to be governed through crime. Governing immigration through crime has taken numerous
forms in the United States. The most notable form it has undoubtedly taken is that
of enhanced border policing (Inda 2006b ). Since the early 1990s, the US federal
government has undertaken a major boundary control offensive, one that aims to
shape the conduct of 'illegal immigrants' in such as way as to deter them from
entering the US. Federal authorities have essentially determined that one of the
best ways to deal with the 'problem' of illegal immigration is through expanding
its border policing operations. The expansion of the border policing as a way of
governing illegal immigration has been most conspicuous along the US-Mexico
border. It is this border that has historically been seen as the primary source of
the undocumented immigrant problem. This expansion actually dates back to late
1970s, but it really burgeoned in the early 1990s. That is when the Immigration
and Naturalization Service (INS) put into effect a broad plan to gain control of
the southwest border and reduce the flow of illicit immigration. As articulated in
the Border Patrol Strategic Plan: 1994 and Beyond, National Strategy, this comprehensive border control scheme was based on a strategy of 'prevention through
deterrence' (US Border Patrol1994). The objective was to increase fencing, lighting, personnel, and surveillance equipment along the main gates (or hot spots) of
illegal entry (e.g., San Diego, California, and El Paso, Texas) in order to raise the
probability of apprehension to such a high level that unauthorized aliens would
be deterred from crossing the border. Now, in the post-9/11 context, the policing
of the border as a way of managing unauthorized migration has only accelerated
as the fight against immigrant illegality has become conflated with the 'war on
terror'. A primary solution to the illegal immigration 'problem', then, has been to
turn the US into a fortified enclave of sorts. It has been to cast a wide net of control and surveillance over the border in order to discourage illegal incursions and

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Borderzones of enforcement

79

thus keep troublesome individuals out of the body politic. As with the government
of crime more generally, the rationale for managing irregular migrants through
police measures is that the public must be protected from the would-be criminals
who threaten their security and contentment.
While the policing ofthe border continues unabated, the federal government has,
since the early 2000s, intensified its policing of the nation's interior. Indeed, interior
policing, led by the Department of Homeland Security (DHS)'s ICE, has become a
central component of the border fight against 'terror' and illegal immigration. What :..
has basically happened is that the border, as a regime of security and immigration control (Cunningham 2009), has been deterritorialized and projected into the
nation's interior (Euskirchen, Lebuhn, and Ray 2009). As part of this border respatialization, certain spaces of everyday life- most notably workplaces but also individual homes and variety of public spaces- have been identified as strategic sites
and become subject to intensified policing. As such, numerous locales across the
interior of the United States have been turned into borderzones of enforcement.
The increased preoccupation with policing the interior of the United States was
notably signaled with the DHS's publication of Endgame: Office ofDetention and
Removal Strategic Plan, 2003-2012 (US DHS 2003). The Office of Detention
and Removal (ORO) is the primary enforcement arm ofiCE. It is responsible for
promoting 'public safety and national security' through the 'identification, apprehension, and removal of illegal aliens from the United States' (US ICE 2009).
Endgame essentially lays out ORO's vision for a secure homeland. The stated
goal is to develop 'the capacity and capability to remove all removable aliens'
(US DHS 2003: 1.3), focusing on those with criminal records and/or outstanding
orders of deportation. The rationale here is that striving for 100 percent removal
allows ICE to provide the level of immigration enforcement necessary to 'thwart
and deter continued growth in the illegal alien population' (2003: 4.4) and thus 'to
keep American secure' (2003: 2.9). This prioritization of removing aliens from the
country was reiterated in the DHS 's master plan for controlling the border, Secure
Border Strategic Plan (US DHS 2006). This text places a strong emphasis on
enhancing 'interior enforcement and compliance with immigration and customs
law' (2006: 6) as a way to stop the illicit flow of people into the US. In line with
Endgame, one of the goals articulated in the Strategic Plan is the need 'to identify,
apprehend, and expeditiously remove the criminal alien and fugitive population'
(2006: 6). However, this text goes further and also highlights the importance of
investigating and punishing 'employers who systematically employ or exploit
aliens unauthorized to work' (2006: 6). ICE's targets would thus be not just individual aliens but also places of work.
One of the main mechanisms ICE has employed to carry out its interior policing
mission is the raid. A raid is a practice whereby immigration authorities, sometimes with the help of other policing agencies, descend en masse on homes, places
of work, and other spaces with the express purpose of apprehending individuals believed to be in the country without authorization. Like border policing, the
raid is a practice that seeks to securitize the nation through the abjection and
exclusion of individuals and populations deemed threatening to the social body.

80

Jonathan Xavier Jnda

ICE's initial targets were people whose criminal or other actions had rendered
them deportable (see US ICE 2008a; Mendelson, Strom, and Wishnie 2009).
But more recently it has also focused on worksite enforcement. Indeed, over the
last few years, this agency has pursued an aggressive program of policing of the
nations workplaces. Between 2006 and 2008, ICE apprehended about 14,000
irregular migrants through worksite raids (US ICE 2008b: 3). This compares to
only about 2,700 arrests between 2002 and 2005 (US ICE 2008b: 3). Worksite
enforcement is a priority, according to ICE, because: 'Employment is a primary
driving force behind illegal immigration. By working with employers to ensure
a legal workforce, ICE is able to stem the tide of those who cross our borders
illegally or unlawfully remain in our country to work' (US ICE 2008b: 2). ICE
deems the hiring of undocumented migrants a problem for several reasons. First,
the agency suggests that 'illegal aliens often turn to criminal activity: including
document fraud, Social Security fraud or identity theft, in order to get jobs' (US
ICE 2008b: 2). Such crimes are seen to negatively impact the lives of the US
citizens and legal residents whose identities are stolen. Second, the need of irregular migrants for fraudulent documents is said to create thriving criminal markets.
Third, there is a perception that every job taken by an undocumented migrant
means one less job for lawful US residents. Fourth, employers are believed to
exploit undocumented workers through ignoring wages laws and safety standards.
And finally, irregular migrants are seen 'as easy targets for criminals who want to
use them to gain access to sensitive facilities or to move illegal products' (US ICE
2008b: 2). Worksite enforcement, then, is deemed necessary in order to stem the
tide of illegality purportedly produced by undocumented migrants. The conviction
seems to be that 'illegal immigration' generally erodes respect for authority and
that the toleration of lawlessness undermines consideration for law and order. For
not only do the undocumented fail to conduct themselves responsibly, they also
compel others to follow suit. As such, they are seen to represent a danger to the
social body. Their disregard for the rule oflaw is understood to pose a threat to the
general welfare of the population.
The workplace raids conducted by ICE have focused on both large and small
businesses. On the larger side, I have already mentioned the raids targeting Swift
& Company meatpacking plants. But there have been plenty of others (US ICE
2008c). On April 19, 2006, for example, ICE agents apprehended over 1,100
employees of IFCO Systems North America at more than 40 locations across the
nation. On March 6, 2007, ICE raided Michael Bianco, Inc., a textile product
company in New Bedford, Massachusetts. This action resulted in over 300 arrests.
On May 12, 2008, ICE raided the Agriprocessors kosher meatpacking plant in
Postville, Iowa (Rhodes 2008). Around 389 undocumented migrants were arrested
that day. And the list goes on .... On the smaller side, there have also been plenty
of raids. David Bacon, a writer for The Nation, gives the following snapshot of
select small-scale raids that took place over a three-month period in 2008:
In June among those arrested were 160 workers at Action Rags in Houston,
32 farm workers for Boss 4 Packing in Heber, California, and nine workers

Borderzones ofenforcement

s had rendered
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81

at water parks in Arizona. In May 'cops and guns and badges and everything' were used to detain 16 workers at San Diego's French Gourmet bakery, according to Rod Coon, company vice-president. The same month, 25
construction laborers were picked up in Florida working on the Lee County
Jail. April saw raids detaining 28 landscapers in El Paso, 24 construction workers in Little Rock, 63 taco makers at El Balazo restaurants in the
San Francisco Bay area, 22 restaurant workers on Maui, 33 laborers on the
federal courthouse project in Richmond, Virginia, 20 workers at Shipley'$-Do-Nuts in Texas, and 45 workers at a Mexican restaurant chain in several
states.
(Bacon 2008)
Large or small, then, it appears that no worksite is safe. And thus irregular migrants
cannot be completely sure that they will escape ICE's attention.
Typically, irregular migrants apprehended by ICE are sent to detention centers
and processed for deportation. Depending on the particular case, an individual
may spend days, weeks, months, or even longer in custody before being removed
from the United States. ICE reports that the average stay in 2008 was 30.49 days
(US ICE 2008d). Not all migrants are sent to detention centers, however. In some
cases, those arrested are placed into removal proceedings and then released on
humanitarian grounds (pending their eventual deportation). These migrants are
most often sole caregivers or women with young children. It is also important
to note that while the majority of ICE apprehensions are simple administrative
arrests (meaning that individuals are only accused with being unlawfully present
in the US), some apprehended migrants have also faced criminal charges. Until
a 2009 Supreme Court decision rendered the practice unconstitutional (see
below), migrants were sometimes charged with aggravated identity theft and
Social Security fraud. In 2008, more than 960 migrants were charged with such
criminal offenses, including 306 people apprehended at the Agriprocessors meatpacking plant (US ICE, 2008b, 3). Speaking in reference to the Agriprocessors
raid, Deborah Rhodes, Senior Associate Deputy Attorney General for the US
Department of Justice, articulates the rationale for criminally charging immigrants
as follows:
Most - but not all- of the 306 workers faced charges of aggravated identity
theft because they were using immigration or Social Security cards with a
number belonging to somebody else. These were not victimless crimes; there
were real people whose identities were stolen. The Federal Trade Commission
estimates that since 2005, 8.3 million Americans have been victims of identity theft. Even in cases in which an identity theft victim does not suffer outof-pocket losses, significant time and frustration can be spent in re-securing
one's personally identifying information. Identity theft strikes at one's sense
of security and privacy. Post 9/11, we also recognize that identity theft poses
a security risk to all of us. Because of the concern for identity theft, the harm
it causes to individuals and the risk to our security as a nation, Congress

82

Jonathan Xavier Inda

has mandated a two-year or five-year sentence for anyone who knowingly

transfers, possesses or uses the identification of another person in relation to
certain specified felonies.
(Rhodes 2008: 49)
For a time, then, migrants were not simply apprehended and deported. They also
faced time in prison for using false or stolen identities.
While the number of migrants caught in worksite raids, including the figure on
those who face criminal charges, is rather small in relation to the estimated I 0.8
million undocumented migrants residing in the United States (Hoefer, Rytina, and
Baker 2010), the effects of the raids have nevertheless been rather profound. The
most palpable impact of the raids has been on the families, particularly the children
of the individuals who have been apprehended and deported. Recently, The Urban
Institute released a report titled Paying the Price: The Impact ofImmigration Raids
on Americas Children (Capps et al. 2007). The report focused on the aftermath
of large-scale ICE raids in three communities: Greely, Colorado; Grand Island,
Nebraska; and New Bedford, Massachusetts. Greely and Grand Island were two of
the sites hit as part of the Swift & Company meatpacking raids. New Bedford was
the location of the raid on Michael Bianco, Inc. The authors detail how the children and families of apprehended immigrants experienced significant hardship,
'including difficulty coping with the economic and psychological stress caused by
the arrest and the uncertainty of not knowing when or if the arrested parent would
be released' (2007: 3). Moreover, they note that:
Hardship increased over time, as families' meager savings and funds from
previous paychecks were spent. Privately funded assistance generally lasted
for two to three months, but many parents were detained for up to five or six
months, and others were released but waited for several months for a final
appearance before an immigration judge- during which time they could not
work. Hardship also increased among extended families and nonfamily networks over time, as they took on more and more responsibility for taking care
of children with arrested parents.
After the arrest or disappearance of their parents, children experienced
feelings of abandonment and showed symptoms of emotional trauma, psychological duress, and mental health problems. Many lacked stability in child
care and supervision. Families continued hiding and feared arrest if they ventured outside, increasing social isolation over time. Immigrant communities
faced the fear of future raids, backlash from nonimmigrants, and the stigma
of being labeled 'illegal'. The combination of fear, isolation, and economic
hardship induced mental health problems such as depression, separation anxiety disorder, post-traumatic stress disorder, and suicidal thoughts. However,
due to cultural reasons, fear of possible consequences in asking for assistance,
and barriers to accessing services, few affected immigrants sought mental
health care for themselves or their children.
(2007: 3-4)

Borderzones ofenforcement

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gration Raids
the aftermath
::irand Island,
d were two of
Bedford was
how the chil:ant hardship,
ess caused by
parent would

d funds from
nerally lasted
'to five or six
:hs for a final
hey could not
onfamily netor taking care
t experienced
trauma, psytbility in child
st if they vencommunities
nd the stigma
md economic
paration anxihts. However,
for assistance,
:ought mental
(2007: 3-4)

83

By removing a parent and breadwinner from the home, then, worksite operations
have significant consequences for families and children. Not only does the removal
of a breadwinner reduce a family's income and increase their material hardship,
it also creates a rather unstable home environment. Moreover, the fear and stigma
produced by a raid can lead to the social isolation of immigrant families and have
an adverse psychological effect on children.
Worksite raids, and the broader anti-immigrant climate that has spawned them,
have also had a significant impact on the larger migrant community (on Latinos in '<
particular) in the United States. A recent survey by the Pew Hispanic Center paints
a rather grim picture of the psychological state of US Latinos - legal residents,
US citizens, and irregular migrants alike (Lopez and Minushkin 2008). Latinos
generally report feeling anxious and discriminated against amid public immigrant
bashing and enhanced immigration enforcement. Among the survey's general
findings were the following: one in ten Latinos reported being stopped by the
police or other authorities in the past year to be asked about their immigration status; one in seven said that they have had trouble finding or keeping a job because
they are Latino; and one in ten reported difficulties finding or keeping housing.
Significantly, the survey also found that a majority of Latinos worry about deportation. Approximately 40 percent report being worried a lot that they, a family
member, or a close friend could be deported, while 17 percent say they worry
some. Not surprisingly, immigrants are particularly concerned about deportation,
with 72 percent reporting being worried either a lot or some. Immigrant raids,
then, and immigration enforcement more generally, have helped to create a sense
of unease among Latinos, and Latino migrant communities in particular. As such,
the efficacy of raiding, as well as of other policing mechanisms deployed against
migrants, resides not in the number of migrants being arrested, but in the creation
of apprehension and fear amongst migrant communities. This is a policy of attrition through enforcement. It is 'aimed at wearing down the will of immigrants to
live and work in the United States' (Immigration Policy Center 2008: 1).

Migrant counterconducts
There is no doubt that the respatialization of the border (i.e., the expansion of
immigration policing into the interior of the United States) has had a negative
impact on the conduct of irregular migrants. Indeed, it is clear that one of the
effects of raiding has been to incapacitate undocumented migrants through expulsion, induction of fear, and so forth. But interior borderzones of enforcement cannot be reduced to mere spaces of policing. They are also most certainly sites of
political struggle, as indicated in Chapter I. Migrants have not stood idly by and
accepted the highly punitive treatment to which they have been subjected. Rather,
they and their allies have actively sought to challenge the practice of raiding and
the governing of immigration through crime. In his College de France lectures on
security, territory, and population, Michel Foucault suggests that there is a strategic
reversibility to power relations such that any governmental effort to shape the conduct of individuals and populations is interwoven with dissenting counterconducts

84

Jonathan Xavier Inda

(Gordon 1991: 5), that is, with 'struggle[s] against the processes implemented for
conducting others' (Foucault 2007: 201 ). This is precisely the case with respect to
the government of immigration through crime. This way of governing immigrants
has elicited dissenting counterconducts, or what I have called migrant or immigrant counterconducts. These struggles against the punitive practices employed to
direct the conduct of migrants range from street protests and marches to legislative
interventions and court challenges. Such counterconducts seek to call into ques
tion the criminalization and marginalization of irregular migrants.
One of the most visible counterconducts that irregular migrants and their allies
have engaged in is public protesting (see De Genova, Mezzadra, Nyers, and Rigo,
this volume). Across the country, unions, religious institutions, immigrant rights
groups, Latino organizations, and the general public have banded together in varying assemblages to publicly protest the raids and their drastic effects on migrants
and their communities. Irregular migrants themselves have played an active role
in these acts of protest. Take the case of Postville, Iowa, for example. Postville
was the site of the raid on the Agriprocessors kosher meat packing plant. At that
raid, ICE apprehended about 389 suspected undocumented migrants, mainly of
Guatemalan and Mexican origin (Rhodes, 2008). A 'lucky' few, mostly mothers,
were released on humanitarian grounds pending their removal from the United
States. The vast majority however, 306 people, were detained on criminal charges.
They were accused of using fraudulent Social Security documents and false or
stolen identities. Ultimately, most of these individuals pleaded guilty to Social
Security fraud and were sentenced to five months in prison. Following their jail
sentences, they were to be deported. The effects of the raid proved to be highly
disruptive. Not only were the lives of numerous migrants shattered, but the larger
community of Postville also suffered. In the immediate aftermath of the raid, the
town (with a population of2,273) lost about a third of its population. As a consequence, businesses were virtually empty, schools were littered with unfilled seats,
and those still left were asking themselves, 'What happened?'. A whole community was in a shambles. As one observer put it, 'The humanitarian impact of this
raid is obvious to anyone in Postville. The economic impact will soon be evident'
(cited in Camayd-Freixas, 2008).
A couple of months after the raid, on Sunday, July 27, 2008, over 1,000 people
marched down the streets ofPostville to protest against ICE's actions. The protestors were mainly Latino migrants, local citizens, immigrant rights advocates, and
members of the Jewish, Catholic, and Lutheran communities (AFP 2008; Standing
Firm 2008). They were marching in Postville not only to speak out against the
raid, which tore apart the local community and devastated migrant families, but
also to call for the just treatment of workers and for comprehensive immigration
reform legislation that included a path to citizenship for irregular migrants (Bobo
2008). They marched carrying signs saying: 'An injury to one is an injury to all.
Immigrant Rights Now!'; 'Born in the USA. Why are you taking our families
away?'; and 'Stop destroying families'. And they chanted: 'No more raids!'; 'No
justice, no peace'; and' Yo no soy terrorista, ni criminal. Y ningun ser humano es
illegal. Basta, basta!' ('I'm neither a terrorist nor a criminal. And no human being

Borderzones of enforcement
nplemented for
:with respect to
1ing immigrants
igrant or immi:es employed to
es to legislative
' call into quesand their allies
ryers, and Riga,
nmigrant rights
)gether in varycts on migrants
d an active role
mple. Postville
tg plant. At that
ants, mainly of
nostly mothers,
rom the United
imina! charges.
1ts and false or
~uilty to Social
owing their jail
ed to be highly
i, but the larger
of the raid, the
on. As a conseh unfilled seats,
whole commu1 impact of this
oon be evident'
er I ,000 people
ms. The pratesadvocates, and
2008; Standing
out against the
nt families, but
ve immigration
nigrants (Bobo
an injury to all.
1g our families
xe raids!'; 'No
ser humano es
10 human being

85

is illegal. Enough, enough!'). Significantly, among the marchers were 43 women

who had been apprehended during the raid but released on humanitarian grounds
to take care of their children (APF 2008). Still under house arrest, these women
wore electronic monitoring bracelets around their ankles. Two of them spoke at
a rally. Maria L. Gomez bore witness to the postraid suffering of her family and
of her sister's detention and the painful trips to visit her in prison (Cullen 2008:
I). And Cruz Rodriguez asked everyone to 'Stand together for our families, be a
voice for those who cannot speak, who are detained .... Remain with us through~
this process' (Cited in Cullen 2008: 1).
As well as being involved in such protests, migrants have been engaged in legal
challenges to the practice of raiding and the criminalization of the undocumented.
Examples of such counterconduct abound. For instance, as a result of the Swift &
Company raids, the United Food and Commercial Workers International Union
(UFCW) filed a lawsuit on behalf of several members, including migrants, to put
a stop to workplace raids. The complaint contended that during
the December 12th raids workers were denied access to telephones, bathrooms and legal counsel. Citizens and legal residents also were deprived of the
opportunity to retrieve documents to establish their legal status. Some workers were handcuffed. Others were shipped out on buses. Families, schools and
daycare centers could not be contacted to make arrangements for the children
of detained workers. Families were left divided and scared- not knowing
where or when they might see a missing family member again.
(UFCW2007)
At a press conference announcing the lawsuit, UFCW International President Joe
Hansen stressed the importance of protecting the constitutional rights ofworkers.
'Work is not a crime, and workers do not leave their constitutional rights at the
plant gate,' Hansen said. 'To inflict this kind of enforcement on innocent workers -to arrest and illegally detain massive numbers of people against their will,
to treat them as criminals - is not just unacceptable, it is un-American' (UFCW
2007). At the time of writing this lawsuit was still pending.
Similarly, we can take the case of Ignacio Flores, an undocumented migrant
from Mexico. In 2000, he used a false name, birth date, Social Security number,
and alien registration card in order to secure employment at a steel plant in Illinois
(Liptak and Preston 2009). Neither the Social Security number nor the alien card
belonged to real people. A few years later, however, in 2006, Flores informed
his employer that he wanted to use his real name and provided a new Social
Security number and alien registration card. The employer reported this change
of name request to US Immigration and Customs Enforcement. ICE discovered
that Flores's new documents actually belonged to other people. The United States
government consequently indicted Flores with, among other things, aggravated
identity theft. Flores was charged under Federal statute 18 U.S. C. 1028A (a)( I),
which imposes a mandatory two-year prison term on any person convicted of
certain predicate crimes if, during or in relation to the commission of those other

86

Jonathan Xavier lnda

crimes, the offender 'knowingly ... uses, without lawful authority, a means ofidentification of another person' (Fernandez 2009). The Jaw was meant to stop credit
card thieves and would-be 'terrorists', but the Bush administration interpreted it
broadly and used it to criminally charge migrants caught using a Social Security
number or identity belonging to someone else. They were charged regardless of
whether or not they had intent to defraud another individual. Rather than accepting the identity theft charge, Flores fought to be acquitted. He argued that the US
government needed to prove that he knew the numbers on his documents belonged
to other people. Flores was initially convicted of identity theft, but he appealed
his case all the way to the US Supreme Court. The Court determined that it was
not okay to eliminate the element of intent in the law. In other words, it was not
enough to simply catch a person with a stolen identity or Social Security number.
The government also had to show that migrants were knowingly (and with the
intent to defraud) using someone else's identity. As a consequence, Flores was
acquitted of the aggravated identity theft charge. And since most migrants who use
a false Social Security number are simply looking to procure a job and are not out
to defraud others, ICE is no longer able to indiscriminately charge undocumented
migrants with identity theft.
The counterconducts in which migrants and their allies have engaged are significant in various respects. First, they speak to the political becoming of irregular
migrants. As Peter Nyers (2006) has pointed out, there is an expectation of docility
on the part of refugees and the undocumented. Their life tends to be represented
in popular and legal discourse as the inverted image of political life. Whereas the
citizen is expected to speak and act politically, the irregular migrant is supposed to
remain silent. But in the context of the raids, irregular migrants have refused to be
quiet. They have spoken out against the dehumanizing effects of raiding. And they
have demanded dignity and recognition, asking to be seen not as criminals who
harm the larger society but as human beings who contribute to it (Beltran 2009).
The fact that irregular migrants stand up and speak thus represents an important act
of symbolic resistance. They are speaking out in a context that does not recognize
migrants, in particular irregular or undocumented migrants, as legitimate speaking
subjects. Second, migrant counterconducts amount to noncitizen 'acts of citizenship' (Nyers 2003; Isin 2008). Irregular migrants are not simply speaking out, they
are actually claiming and exercising rights. A main message of the antiraid public protests, as well as of the legal challenges to the criminalization of migrants,
is that irregular migrants are legitimate members of US society and deserve the
right to work, to raise families, and to be free from the fear of persecution
(see Mezzadra and Rigo, this volume). In other words, they are asking to be
recognized as legitimate political subjects with social, civil, and political rights. In
making such claims, irregular migrants are, in effect, enacting citizenship. Indeed,
through their engagement in a variety of democratic processes, from collective
protesting and campaigning for rights to court battles, the undocumented are basically acting as citizens. In the process, citizenship is transformed from a strictly
juridical condition to a practice in which one can engage regardless of legal
status.

Borderzones of eliforcement

87

Conclusion

'leans ofidento stop credit

interpreted it
)Cial Security
regardless of
r than accept:d that the US
~nts belonged
t he appealed
ed that it was
ds, it was not
urity number.
(and with the
~. Flores was
rants who use
nd are not out
ndocumented

To the extent that irregular migrants have been constructed as subjects who harm
the well-being ofAmerican citizens, the measures employed to govern them have
become extremely exclusionary and punitive. Much like the government of the
poor and of other anticitizens, undocumented migrants have increasingly been
regulated through crime and police measures. Indeed, crime and punishment have
become the occasions and the institutional contexts in which the undocumented .,..
are governed. Irregular migrants, in short, have effectively been criminalized and
treated as delinquent subjects- with rather unfortunate (if not downright horrific)
consequences for many migrant families and communities.
The picture is not all bleak, however. Migrants and their allies have forcefully fought back against the practice of raiding and the expanded boundaries of
enforcement. For one, they have gone to court and filed lawsuits to stop ICE from
conducting large-scale raids like the ones that took place at Swift & Company, as
well as to end the practice of charging undocumented workers with identity theft.
Furthermore, irregular migrants themselves have taken to the streets and marched
to claim rights and voice their rejection of the dehumanizing effects of workplace
raids. While the border might have been respatialized and the enforcement climate
stepped up, then, migrants and their allies have kept hope alive and mounted political campaigns bent on gaining rights and recognition for the undocumented. The
workplace as a borderzone of governing immigration through crime is, in other
words, also a site around which exclusionary and punitive techniques of control
are subject to resistance and contestation.

:aged are sigtg of irregular

on of docility
e represented
. Whereas the
s supposed to
refused to be
ing. And they
riminals who
leltnin 2009).
important act
not recognize
nate speaking
~ts of citizenking out, they
antiraid pub' of migrants,
d deserve the
f persecution
asking to be
:ical rights. In
1ship. Indeed,
)m collective
nted are basi~om a strictly
lless of legal

Note
Special thanks go to Leo Chavez, Julie Dowling, the anonymous reviewer, and my
colleagues in Latina!Latino Studies at the University of Illinois, Urbana-Champaign.
They ali, in different ways, contributed greatly to this chapter. I would also like to thank
audiences at the institutions and conferences where I presented versions of this work:
the Department of Women's and Gender Studies at the University of Missouri, the 2008
American Anthropological Association Annual Meeting, and the 2010 International
Studies Association Annual Convention. Finally, many thanks go to Vicki Squire for her
wonderful suggestions and for all her hard work in putting this volume together.

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