Undocumented Students: History and Implications for Higher Education Administrators

Abstract

Spanish

This article provides a brief history of undocumented students and higher education, from the landmark case of Plyler v. Doe to the examination of Deferred Action for Childhood Arrivals. As lawmakers engage in debate regarding undocumented immigrants, states have attempted to provide educational clarity. In addition, academic institutions such as The University of California, Berkeley through their Undocumented Student Program (USP) have taken measures to address the needs of undocumented students in higher education.

Keywords

higher education Latina/o inclusion undocumented student support retention Hispanic

An estimated 11.3 million undocumented immigrants live in the United States (Krogstad, Passel, & Cohn, 2017). Of the 11.3 million undocumented immigrants, the Migration Policy Institute, in its analysis of the United States Census Bureau data from 2012 to 2016, estimate that 8.63 million have arrived from Mexico, Central America, the Caribbean, and South America (“Profile of the Unauthorized Population: United States,” 2016). Within the undocumented immigrant population are individuals with the need for postsecondary education options. The landmark Supreme Court decision in Plyler v. Doe (1982) held that states could not deny students free public education based on immigration status. The Court ruled that the Equal Protection Clause of the Fourteenth Amendment applied to all students, including undocumented students. Although the decision in Plyler v. Doe (1982) provided the equal access to education regardless of immigration status, the decision only applied to students in kindergarten through 12th grade.

Approximately 5% to 10% of undocumented students pursue higher education (“Resource Guide: Supporting Undocumented Youth,” 2015). Federal lawmakers have taken steps to outline the specifics of undocumented immigrants’ rights, including access to higher education. The Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA), the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), the Development, Relief, and Education for Alien Minors (DREAM) Act of 2001, and Deferred Action for Childhood Arrivals (DACA) in 2012 have attempted to outline procedures for such a unique population.

States including Texas, California, New York, and Washington have introduced legislation to enact education access policies for undocumented students. The lack of uniform decision-making at the State and Federal level, coupled with the divisiveness of such a controversial issue, has contributed to the confusion for both undocumented students and institutions of higher learning. Current and future leaders in higher education administration must be aware of the history of undocumented students and current state legislation with respect to their state. Furthermore, the role of institutional agents can ease the transition of undocumented students and provide clarity in planning their academic journey. Dissemination of information to all administrative stakeholders regarding current laws can contribute to an inclusive and welcoming environment for undocumented students. Nienhusser (2018) discusses the importance of institutional agents in higher education:

It is imperative that the higher education community—scholars, associations, leaders, institutional agents—continue to understand the manner in which policies are implemented for undocumented and DACAmented students, especially if our collective goal is to expand educational opportunities for these students. (p. 449)

Undocumented students comprise a unique population with challenges that affect entrance and retention in higher education. Knowledge of current legislative acts is needed to create an environment where undocumented student can flourish. In addition, institutions can look at support programs such as The University of California, Berkeley’s Undocumented Student Program (USP) as a model in their efforts to provide equitable access and resources for student success.

Plyler v. Doe (1982)—Equitable Access to Education

In 1975, the Texas Legislature sought to block public school enrollment for students who were not legal residents and attempted to amend education laws to withhold funding for such students. In 1977, the Tyler Independent School District implemented a policy requiring tuition for students who were not born in the United States. To have tuition waived, students were required to provide documentation of legal status or confirmation from officials in federal immigration that active steps were being taken toward citizenship. The education law was in response to the perceived financial burden of immigration and an increase in student population. A class action lawsuit was subsequently filed in 1977 on behalf of a group of students from Mexico who could not provide adequate citizenship documentation. The lawsuit challenged the policy as a violation of the Equal Protection Clause of the Fourteenth Amendment of the Constitution. The United States District Court for the Eastern District of Texas initially reviewed the case.

In 1978, the United States District Court for the Eastern District of Texas held that undocumented students had the constitutional right to public education and that the policy created by the Tyler Independent School District violated the Equal Protection Clause of the Fourteenth Amendment. The District Court dismissed the defendant’s claim that the financial burden of undocumented students was increasing overall enrollment, stating “that the increase in school enrollment was primarily attributable to the admission of children who were legal residents” (“Plyler v. Doe,” 1982, p. 3). Furthermore, the District Court noted that undocumented students may eventually become legal residents and if denied equal access to education could be subject to perpetual low socioeconomic status. The case was subsequently appealed to the Court of Appeals for the Fifth Circuit in 1980 where the Court affirmed the decision of the lower court. That decision was again appealed and reviewed by the United States Supreme Court beginning in 1981.

In 1982, the Supreme Court held that a “statute which withholds from local school districts any state funds for the education of children who were not legally admitted into the United States” and denies enrollment constitutes a violation of the Equal Protection Clause of the Fourteenth Amendment (“Plyler v. Doe,” 1982, p. 1). The Court also held that the law in question harshly punished the children of undocumented immigrants and in doing so, showed a lack of state interest in the betterment of its people. The Court agreed that the state of Texas had a legitimate interest in protecting itself from rising immigration numbers and costs associated with an increased population. However, the Court held there was no evidence of immigrants coming to the state specifically for the purpose of free education.

The decision in Plyler v. Doe (1982) is significant in its recognition of access to education for all students in the United States, regardless of immigration status. As monumental a case as Plyler v. Doe (1982) was, limitations still exist for undocumented students pursuing higher education. The case only outlined a precedent for public education in the kindergarten through 12th grade setting. The issue of undocumented students in higher education persists, as the lack of comprehensive measures contributes to an environment of confusion and uneasiness within the community.

Immigration Law

Undocumented students pursuing higher education simultaneously navigate institutional policies pertaining to application, admission, and acceptance while being subject to ambiguous immigration laws. The perception by part of the public and some law-makers that undocumented students present a burden on legal tax-paying citizens resulted in the the enactment of two specific pieces of legislations which ultimately served to hinder access to higher education opportunities. With the passing of the PRWORA of 1996 and the IIRIRA of 1996, United States Congress reasoned that immigration would be deterred by removing public benefits as an incentive for people wishing to come to the United States (Oas, 2011).

PRWORA

The PRWORA in 1996 prohibits public benefits to all undocumented immigrants and limits benefits for approved immigrants to basic services such as medical assistance for emergency situations, short-term disaster relief, and public health through immunizations. The passing of PRWORA did not explicitly prohibit public universities from admitting undocumented students; however, section 401 of PRWORA articulated that undocumented and illegal individuals are not entitled to the public benefit pursuing of higher education (H.R. 3,734, 1996).

IIRIRA

The Plyler v. Doe (1982) decision has been challenged on several occasions but remains a part of United States education law. However, additional legislative acts have been proposed which have hindered the path toward equality undocumented students. The IIRIRA of 1996 initially sought to address illegal immigration through increased employment eligibility verification, harsher criminal penalties for illegal immigration, and strict review of government aid with regard to undocumented immigrants. Furthermore, “section 505 of IIRIRA prohibits public state universities from giving educational benefits to illegal aliens unless they give the same education educational benefits to the United States citizens without regard to residence” (Oas, 2011, p. 880). State lawmakers would have to provide equitable benefits for all citizens living in their respective states. Oas (2011) outlined the potential reasoning for the support of both PRWORA and IIRIRA:

Those supporting the passage of these two laws probably thought they would prevent illegal aliens from getting a college education at the taxpayer’s expense since no state would be willing to give up out-of-state tuition that it collects from United States citizens in order to give in-state tuition to illegal aliens. (p. 880)

Ultimately both PRWORA and IIRIRA serve to severely limit the access to postsecondary options for undocumented students; however, law-makers continue to take measures to provide a pathway to citizenship and equitable access to higher education.

Pathway to Citizenship and Access to Higher Education

The passing of PRWORA and IIRIRA created barriers to citizenship while hindering the pursuit of higher education for undocumented students. However, efforts to address the issues of equitable access to education and creating a pathway toward citizenship continue to be proposed, all while the undocumented student population remains in limbo. The DREAM Act of 2001 sought to assess the needs of undocumented students and give them opportunities for success. DACA, proposed in 2012, built upon measures proposed in The DREAM Act to provide clarity for undocumented immigrants and allow them to simultaneously pursue education and take steps toward citizenship.

The DREAM Act

Several bills have been introduced seeking to repeal various provisions of IIRIRA, create a pathway to citizenship, and promote access to education for undocumented students in the United States. An initial version of the DREAM Act, also known as the DREAM Act was formally introduced in 2001 as a bi-partisan initiative to address immigration reform during the 107th Congress (Mahatmya & Gring-Pemble, 2014). The purpose of the bill was to allow undocumented children access to higher education and eventual legal status. Eligible children protected under the DREAM Act must meet specific criteria including entry into the United States before the age of 16, 5 years of residence in the United States prior to enactment of bill, completion of high school or General Education Development (GED) exam, or college admission. Under the 2001 proposal, qualified students would be allowed to attend public universities as in-state residents. Since the initial proposal of The DREAM Act, several versions have been introduced providing various pathways to citizenship and opportunities to continue education, yet, as of this writing, none have passed (Kerwin & Warren, 2018).

DACA

In 2012, as a response to the several unsuccessful measures regarding immigration reform and the rights of undocumented immigrants as they navigate paths to citizenship, former United States President Barack Obama signed an executive order implementing DACA. DACA allowed undocumented children the opportunity to apply for provisional legal status. Under DACA, eligible persons would also have the right to work in the United States and pursue higher education but are unable to receive federal aid (Venegas et al., 2017). Although DACA does not provide a permanent legal solution for undocumented immigrants, it has provided temporary relief from deportation and authorization to work in the United States for nearly 690,000 recipients (Zong, Ruiz Soto, Batalova, Gelatt, & Capps, 2017). Meanwhile, DACA recipients are pursuing education beyond the secondary level. Forty-four percent of DACA recipients have completed high school or its equivalent, whereas 18% are currently enrolled in college (Zong et al., 2017). Even with close to half of DACA recipients being ready to pursue higher education, their status remains uncertain as the executive order continues to be evaluated by current United States President, Donald Trump, and his administration. Although Federal lawmakers decide the fate of DACA, states are taking the initiative in providing options for undocumented students to pursue their educational goals.

Power of States—Undocumented Students Pursuing Higher Education

As Federal lawmakers confront the many issues regarding undocumented immigrant rights, representatives at the state level have taken measures to provide clarity for a population in need of answers. Currently, states do not have the power to legalize undocumented immigrants. However, they have the right to address specific issues that affect their populations such as the cost associated with higher education. Undocumented students are often declared nonresidents in their state. This designation requires them to pay out-of-state tuition which creates a financial burden hindering both enrollment and retention. Several states have taken up the issue of affordability and residence requirements to provide a solution for undocumented immigrants. As of September 2017, 18 states have implemented laws that allow undocumented students to receive in-state tuition if they have completed primary or secondary school in their respective state: California, Colorado, Connecticut, Florida, Illinois, Kansas, Maryland, Minnesota, Nebraska, New Jersey, New Mexico, New York, Oklahoma, Oregon, Rhode Island, Texas, Utah, and Washington (“The Dream Act, DACA, and other polices designed to protect dreamers,” 2017). Given that Texas, California, New York, and Washington were some of the first states to provide provisions for undocumented students and make up over 18% of the Hispanic or Latino population in the United States, their measures will be highlighted to provide a snapshot of the current state of undocumented students in higher education (“United States Census Bureau,” 2018). In addition, the four states are home to over half of the designated Hispanic Serving Institutions in the country (“HACU Member Hispanic-Serving Institutions,” n.d.).

Texas DREAM Act

Texas was the first state to enact a policy providing in-state tuition for undocumented students. The passing of House Bill 1403 (HB 1403) in 2001, known as the Texas DREAM Act, also allowed undocumented students to receive state financial aid (Price, 2015). In-state resident tuition is especially crucial to access as undocumented students are still prohibited from receiving federal financial assistance such as loans, grants, scholarships, or work study (Flores, 2010). To be eligible for in-state tuition under HB 1403, undocumented students must have graduated from a Texas secondary institution or received the equivalent of a high school diploma and have resided in Texas for at least 3 years from the date of secondary institution graduation. Eligible students must also “provide to the institution an affidavit stating that the individual will file an application to become a permanent resident at the earliest opportunity the individual is eligible to do so” (Flores, 2010, p. 438).

The in-state tuition benefits in Texas have contributed to increased higher education enrollment, specifically within the Latino/a undocumented student population (Flores, 2010). Although enrollment has affected all higher education institutions, community colleges have seen the most growth (Dickson & Pender, 2013). However, even with increased enrollment, the undocumented student population still represents a small portion of the total Texas student population. The Texas Higher Education Coordinating Board reported for fiscal year 2017 that undocumented students make up 1.5% of the total student population enrolled in Texas public institutions (Texas Higher Education Coordinating Board, 2018). Even with such a small but growing population of undocumented students in higher education, Texas has continued to reap economic benefits through the enactment of the Texas DREAM Act. The Center for Public Policy Priorities (2019) in their analysis of data from the Texas Higher Education Coordinating Board estimate that undocumented students account for US$64 million in tuition and fees while only utilizing US$12 million in state aid.

California DREAM Act

California, also in 2001 followed Texas with Assembly Bill (AB) 540. The law allows undocumented students to be eligible for in-state tuition at California public colleges and universities. AB 540 differs from Texas’s HB 1403 in its lack of available funding for undocumented students. However, the in-state tuition designation provided some relief from the financial burden as “undocumented students no longer pay three to seven times more for tuition than their documented peers” (Abrego, 2008). In 2011, California legislators addressed funding through the passage of AB 130 and AB 131 with implementation taking place in 2013. AB 130 allows students eligible under AB 540 access to scholarships at state public colleges and universities, whereas AB 131 allows undocumented students to apply for state financial aid. The combination of AB 540, AB 130, and AB 131 has come to be known as the California DREAM Act (Negrón-Gonzales, 2017). The California DREAM act has yielded positive results for the undocumented Hispanic student population when compared with U.S. citizens. Ngo and Astudillo (2019) found that undocumented Hispanic students “completed more units in their first quarter of enrollment, had higher attempt-to-completion rations, and were more likely to enroll in a second quarter” (p. 10).

New York Undocumented Students in Higher Education

In the state of New York, Assembly Bill 9612 (2002) and Senate Bill 7784 (2002) give undocumented students the opportunity to attend public colleges and universities and receive in-state tuition (Nienhusser, 2015). AB 9612 has similar conditions to HB 1403 of Texas. Students must have graduated from a New York high school or obtain a GED, show proof of residence, and file an affidavit confirming active steps toward legal citizenship. More recently, in January of 2019, New York legislators passed the José Peralta New York State DREAM Act. The legislation allows for undocumented students to receive state financial, eliminates barriers for college savings programs, and establishes a college scholarship fund (“Senate Majority Passes the José Peralta New York State DREAM Act,” 2019).

Washington State DREAM Act—REAL Hope Act

Undocumented students in the state of Washington can qualify for out-of-state tuition waivers under HB 1079 passed in 2003 (“HB 1079—In-State; Tuition,” 2014). Undocumented must have received a high school diploma, lived in the state for 3 years prior to graduation, and continued residence in the state (Visser, 2018). In addition, in 2014, Washington State Governor Jay Inslee signed the Washington State DREAM Act, also known as the REAL Hope Act which extended state funding in the form of financial aid (Visser, 2018). Similar to the aforementioned states, enrollment of undocumented students in higher education increased as a result of HB 1079. The Washington Student Achievement Council reported an increase of an estimated 5,649 students from 2003 to 2013 (West & Washington Student Achievement Council, 2015).

Implications and Interventions

Although “universities have a responsibility in providing opportunities that foster students’ academic success and must seek innovative ways to support their development,” high school administrators can also take measures to facilitate a culture of success for undocumented students (Borjian, 2018, p. 31). Administrators and support staff must create an environment that is conducive to continuing education through early interventions, building relationships, normalizing conversations, expanding opportunities through outreach, and college preparedness (Murillo, 2017). Guidance counselors can serve as institutional agents and provide assistance with course selection, tuition information, and school choice resources (Lauby, 2017). In addition, all support staff in public schools must be equipped with the proper resources to assist undocumented students. The implementation of additional training, guidelines, and procedures by either state or federal policymakers can aid in the transition to higher education institutions (Lauby, 2017; Teranishi, Suarez-Orozco, & Suarez-Orozco, 2011).

In the higher education community, academic advisors and institutional policy makers can serve as advocates for undocumented students. Given the interaction throughout a student’s academic career and their impact on student retention, advisors can be proactive and intentional in their conversations with undocumented students. For example, Swecker, Fifolt, and Searby (2013) found that for every “meeting with an advisor the odds that a student is retained increases by 13%” (p. 49). Advisors can utilize their interactions and tailor to the needs of undocumented students directly affect undocumented students while highlighting additional support services regarding financial aid, language programs, and career services (Teranishi et al., 2011). At the institutional level, higher education administrators and policy makers can support undocumented students through the creation of support networks and campus specialists versed in policy and procedures directly affecting undocumented students. (Wangensteen, 2017, “Building Undocumented Student Support”). They can also provide outreach and resources through transitional services, informational sessions, legal support, and civic engagement.

Undocumented Student Support—A Model for Action

The growing number of undocumented students pursuing higher education calls for institutions to address their unique needs as they transition into a new community. One such institution is the University of California, Berkeley, and their USP (Sanchez & So, 2015). The USP provides a model for support with buy-in from faculty, staff, and policy makers. Faculty and staff support students “through academic counseling, legal support, financial aid resources, and access to an extensive campus referral network” (Sanchez & So, 2015, p. 466).

Utilizing a holistic approach to student support, staff members communicate with undocumented students from admission to commencement. In addition, students have access to trained counselors “to discuss personal and family challenges as well as strategies to support their navigation of higher education institutions, academic performance, and professional growth” (Sanchez & So, 2015, p. 467). Students and faculty can also participate in workshops on financial literacy, housing and legal support through UC Berkeley School of Law International Human Rights Law Clinic (Sanchez & So, 2015). Finally, training is provided to faculty and staff to promote a better understanding of the challenges that undocumented students face and identify specific support strategies for academic and social integration.

Undocumented students have vocalized the need for continued support services throughout their academic career, including counseling services, funding opportunities, and institutional encouragement (Suárez-Orozco et al., 2015). UC Berkeley and their USP has responded to these needs in their most recent 5-year strategic plan. In the plan, USP stakeholders outlined two specific goals: facilitating student success and the sharing of its model to aid undocumented students nationally (“Five-Year Strategic Plan for Cal’s Undocumented Student Program,” 2016). The creation of such a document indicates the commitment to confront contemporary challenges associated with undocumented students pursuing higher education.

To facilitate student success, USP will continue to embrace the holistic model of support through the strengthening of mental health services, legal services, cocurricular activities, financial literacy, and food security. In addition, they plan to “equitize the Cal campus” through the creation of an environment of support and being a catalyst for institutional change to address any gaps in assistance (“Five-Year Strategic Plan,” 2016, p. 5). Finally, USP plans to explore and implement additional support for graduate students to ensure academic and professional growth.

USP has also identified two strategies to share its model on a national scale. Through the documentation and assessment of all support programs, USP aspires to be a leading example for best practices regarding undocumented student success. Higher education institutions from around the country will be able access data from the USP through conferences, reports, and their website (“Five-Year Strategic Plan,” 2016). Finally, USP is actively taking the lead as the most comprehensive student support program for undocumented students through consultation in implementing similar programs around the United States that aid in improving the access and retention of undocumented students in higher education (“Five-Year Strategic Plan,” 2016).

Conclusion

Undocumented students in the United States continue to face challenges as they pursue higher education. Similar to traditional students, they must navigate the transition to a new community with stressors and barriers, but they also have unique obstacles. While “having to work multiple jobs, support their families, and obtain good grades is not unlike the experience of other groups, doing so under the uncertainty of their immigrant statuses serves to exacerbate pressures on multiple levels” (Gámez, Lopez, & Overton, 2017, p. 156). As evidenced by the Undocumented Support Program at UC Berkeley, supportive faculty and staff can aid in the navigation of the higher education community in an attempt to minimize one component of uncertainty in the lives of undocumented students. With knowledge of the complicated and ever-evolving status of undocumented students, institutional staff must also research opportunities that minimize the financial burden of continuing education. Programs such as UC Berkeley’s USP provide a model for support of undocumented students as they enter, persist, and complete their academic journey. Administrators in higher education are institutional agents and have the responsibility to facilitate the success of all students. Knowledge of immigration history and federal and respective state laws can aid in the creation of an inclusive environment. In doing so, undocumented students can feel welcome, safe, and encouraged to achieve their potential and contribute as productive members of a diverse society.

Footnotes

Declaration of Conflicting Interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) received no financial support for the research, authorship, and/or publication of this article.

ORCID iD

Jeremy Peña

Author Biography

Jeremy Peña is the academic program coordinator for the Center for International Studies at Texas State University in San Marcos, Texas. Most recently, Jeremy served as conference coordinator for The Obama Legacy: Preliminary Perspectives at Texas State. A doctoral student at the University of Mary Hardin-Baylor in their Leadership in Educational Administration program, his primary research includes the identification and assessment of advising practices with regard to first-generation and non-traditional students in higher education.

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