The Senate’s latest effort at comprehensive immigration reform was introduced by the bipartisan Gang of Eight in April 2013, and passed the Senate that June.[1] Titled the Border Security, Economic Opportunity, and Immigration Modernization Act (S. 744), it follows the same broad course as other reform bills that have failed over the past eight years, offering promises of increased border security and interior enforcement in exchange for a “pathway to citizenship” for illegal immigrants. This is not the last time the U.S.