A WORKING-CLASS HISTORY OF FIGHTING DEPORTATIONS

A WORKING-CLASS HISTORY OF FIGHTING DEPORTATIONS
By David Bacon
Jacobin, 12/15/24
https://jacobin.com/2024/12/deportations-unions-immigrants-organizing-trump

The history of working-class organizing in the United States is full of examples of immigrant resistance to mass deportation, sweeps, and other tactics. Time and again, immigrant worker activity has changed the course of society. It has produced unions of workers ranging from copper miners to janitors. It turned the politics of Los Angeles head. And it is this tradition of worker resistance that is the real target of immigration enforcement waves, both current and threatened by the incoming administration.

Organizers of the past fought deportation threats just as we do today, and their experiences offer valuable insights for our present situation. Not only did they show tremendous perseverance in the face of direct threats to migrants, but these organizers also envisioned a future of greater equality, working-class rights, and social solidarity - and proposed ways to get there. Increased immigration repression has a way of making the bones of the system easier to see and the reasons for changing it abundantly clear. These organizations and coalitions defending immigrant workers, their families, and their communities have often been building blocks for movements for deeper social change.

The rich tradition of worker organizing against immigrant repression is a story of courageous struggle and a reservoir of strategic thinking that can help immigrant workers and communities confront the promised MAGA wave of repression. It involves far too many organizations and fights to list here. This article aims to show what people faced, how they fought, and what kind of future they fought for.

RICHMOND, CA - People of faith and immigrant families celebrate Passover and hold a vigil outside the Richmond Detention Center, where immigrants were incarcerated before being deported. An immigrant woman came with her two children to ask for help in getting her husband released.  He was imprisoned in the detention center.


The Old Threat of Mass Deportation

In the outpouring of fear and outrage over Donald Trump's threat to deport millions of undocumented immigrants, many have drawn parallels to the mass deportations of 1932-33. At the height of the Great Depression, with hunger haunting the homes of millions of working-class people, relief authorities denied food to Mexican and Mexican American families. Racist bureaucrats appealed to the government to deport them, claiming that forcing them to leave would save money and open up jobs for citizens. These age-old lies have been recycled over the last century, repeated most recently by the MAGA campaign.

Hunger was the most powerful weapon used to force people to leave. Thousands were swept up in street raids, and many more fled because of the terror these raids produced. Voluntarily or not, people were loaded into boxcars and dumped at the border gates. The euphemism of the '30s was "repatriation." Today's immigration enforcers call it "self-deportation." The idea remains the same, and Trump and J. D. Vance are only the latest proponents of this inhumane policy.

People resisted deportation through the radical organizations of the era, from the Congreso de Pueblos de Habla Española to the unions formed in bloody strikes in mines and fields. The largest farm labor strike in US history, the Pixley cotton strike, erupted in 1933 across the barrios of California's San Joaquin Valley during that peak deportation year. Radical activists were singled out for deportation and defended by communist and socialist defense organizations, including later the Committee for the Protection of the Foreign Born. The Mexican government of the time, only a decade after the revolution, also protested and tried to help deportees.

This history of resistance is as important to remember as the history of the deportations themselves. The organizations created by resistance, and the larger working-class movement of which they were a part, survived the deportation wave. While many groups were put on the attorney general's list of subversive organizations during the Cold War, others emerged during the civil rights era. When the immigrant rights movement peaked again in recent decades, it inherited this legacy.

RICHMOND, CA - People of faith and immigrants at the last vigil in front of the West County Detention Center, where immigrants were incarcerated before being deported. After seven years of vigils, the Contra Costa Sheriff cancelied the contract with Federal authorities under which the jail has housed immigration detainees.  Of the 178 detainees, supporters raised enough money to pay for 21 to be released to their families.  Victor Aguilar and Hugo Aguilar are recently released detainees, in front of the detention center.


Workers Win Over Their Unions

One crucial battle was fought by a small group of workers in wealthy Palm Springs, California. Twenty-three years ago, Maria Sanchez, working at the luxurious Palm Canyon resort for $4.75 an hour, marched into the office of Hotel Employees & Restaurant Employees (HERE) Local 309. There she and her coworkers joined the union. The hotel hired security guards - dressed in uniforms mimicking those of the Border Patrol - and began firing workers. The immigrant housekeepers organized a silent march in the street outside, prayed in the parking lot, and refused to go back to work.

With the support of Local 309, Sanchez and her coworkers stayed out on strike for four months. She lost her house and car, selling personal belongings to survive. The manager swore they'd never work there again.

Despite his threat, the Palm Canyon was finally forced to agree to reinstate the workers with back pay. But when the hotel said only workers with legal immigration status could go back, everyone stayed on strike another month, documented and undocumented together. "I didn't care who had papers and who didn't," Sanchez told me then. "We decided that no one would go back until we all went back. The union didn't back down, and we won."

What makes the Palm Canyon experience important today is not just the inspiring courage of the workers but the strategic ideas that guided them. They organized over the concrete conditions of their lives. Faced with legal repression and firings, they defied efforts to make them suffer. Knowing they couldn't fight alone, they looked for help, and the union supported them. Most importantly, they stuck together. "This is exactly what's leading unions to change their attitude towards immigration," explained John Wilhelm, then the national union's president.

It was no accident that as the strike unfolded, the AFL-CIO highlighted the organizing of immigrant workers at its Los Angeles convention. Rejecting its history of support for anti-immigrant legislation, the union federation adopted a resolution calling for immigration amnesty for the country's then six million undocumented people and the repeal of employer sanctions - the 1986 law that made it illegal for them to work. Palm Canyon strikers were among the many witnesses at the subsequent union hearings organized around the country to expose the violation of immigrant workers' rights.

SAN LEANDRO, CA - Members of ILWU Warehouse Local 6 and community supporters protest an immigration raid in which the company cooperated, during a union organizing drive at the Mediacopy plant.  They confronted company managers in the plant office.


Defending Against Raids in the Workplace

The decades following the Cold War saw workers and unions developing increasingly sophisticated strategies to resist immigration enforcement. From factory floors to union halls, these battles helped shape today's immigrant rights movement.

One of the first post-Cold War battles over immigration enforcement against workers took place at the Kraco car radio factory in Los Angeles in the early 1980s. Workers joining the United Electrical Workers stopped the production lines to force the owner to deny entry to immigration agents and saved one another from deportation. Later that decade, the Molders Union Local 164 in Oakland joined the Mexican American Legal Defense and Educational Fund in suing the Immigration and Naturalization Service over its practice of having agents bar the doors of factories, holding workers prisoner, and then interrogating them and detaining those without papers. The case went to the US Supreme Court, which found the practice unconstitutional.

In one of the last raids of the Bush administration, in 2008, immigration agents took 481 workers at Howard Industries, a Mississippi electrical equipment factory, to a privately run detention center in Jena, Louisiana. They were not charged, had no access to attorneys, and could not get released on bail. Jim Evans, a national AFL-CIO organizer in Mississippi and a leading member of the state legislature's black caucus, said, "This raid is an effort to drive immigrants out of Mississippi and a wedge between immigrants, African Americans, white people, and unions - all those who want political change here." Evans, other members of the black caucus, many of the state's unions, and immigrant communities all saw shifting demographics as the basis for changing the state's politics. They organized the Mississippi Immigrants Rights Alliance (MIRA) as a vehicle for protecting the immigrant part of that constituency.

By the 2000s, these workplace battles had evolved into complex struggles over race, labor rights, and political power in the South. Howard Industries, a rare union factory in the state, paid $2 per hour less than the industry norm. "The people who profit from Mississippi's low wage system want to keep it the way it is," Evans said, charging that the immigration raid was used to keep the union weak. International Brotherhood of Electrical Workers Local 1317's African American business manager, Clarence Larkin, told me that the company "pits workers against each other by design and breeds division among them that affects everyone. By favoring one worker over another, workers sometimes can't see who their real enemy is. That's what keeps wages low."

MIRA activists met the raid with organizing, sitting outside on the grass with the families of those in detention. "When the shift changed, African American workers started coming out and went up to these Latina women and began hugging them," MIRA organizer Victoria Cintra remembered. "They said things like, 'We're with you. Do you need any food for your kids? How can we help? You need to assert your rights. We're glad you're here. We'll support you.'"

In Mississippi fish plants, Jaribu Hill, the director of the Mississippi Workers Center, collaborated with unions to help workers understand the dynamics of race. "We have to talk about racism," Hill said. "Organizing a multi-racial workforce means recognizing the divisions between African Americans and immigrants, and then working across our divides."

The Obama era brought a new tactic: mass firings. In 2011 Chipotle, the chain that made its fortune selling Mexican food made by Mexican workers, fired hundreds of them throughout Minnesota. Their crime was that they worked but had no immigration papers. They joined thousands of other workers fired in the Obama administration's key immigration enforcement program, which undertook to identify workers without papers and then force companies to fire them. With no job or money for rent and food, immigrants would presumably "self-deport." In Minneapolis, Seattle, and San Francisco, over 1,800 janitors lost their jobs. In 2009, over 2000 young women at the sewing machines of American Apparel were fired in Los Angeles. Barack Obama's Immigration and Customs Enforcement (ICE) director John Morton said that ICE had audited over 2,900 companies in just one year, and the number of firings ran into the tens of thousands.

In Minneapolis, Service Employees International Union (SEIU) Local 26 helped Chipotle workers organize marches and demonstrations, cooperating with the Center for Workers United in Struggle, a local workers' center, and the Minnesota Immigrant Rights Action Committee. Supporters were even arrested in civil disobedience at a Chipotle restaurant and mounted a boycott of the chain.

As Trump's presidency approached, unions moved from reactive resistance to proactive protection. In the period before Trump took office in 2017, many unions expected that workplace raids and firings would be a large part of his immigration enforcement program as well. The hotel union in Oakland, California, developed a proactive strategy to keep ICE away from workplaces and asked the Oakland City Council to protect immigrants on the job. The council passed a resolution, noting it has been a "City of Refuge" since the anti-apartheid movement of the mid-1980s: "The City Council ... calls upon all employers to establish safe/sanctuary workplaces where workers are respected and not threatened or discriminated against based on their immigration status."

Trump again threatens, as he did in 2016, to end federal funding to more than three hundred sanctuary cities. Moreover, many cities, and even some states, withdrew from the infamous 287(g) program, requiring police to arrest and detain people because of their immigration status. Trump promises to reinstate it and cancel federal funding to cities that won't cooperate.

Like many unions looking for alternatives, HERE Local 2850 (now part of UNITE HERE Local 2) began negotiating protections into union contracts, requiring managers to notify it if immigration agents tried to enter, interrogate workers, or demand papers. The contract says the hotel has to keep agents out unless they have a warrant. The union then helped workers resist at one hotel where new owners demanded they show their immigration papers to keep their jobs. All the hotel's workers refused, documented and undocumented alike, and the company backed down.

California's janitors' union, SEIU United Service Workers West drafted the Immigrant Worker Protection Act, a state law requiring employers to ask for a judicial warrant before granting ICE agents access to a workplace. It prohibits employers from sharing confidential information, like Social Security numbers, without a court order. The act came after years of fighting workplace raids and immigration-related firings. In 2011, Los Angeles janitors sat down in city intersections to protest terminations by Able Building Maintenance and fought similar firings in Stanford University cafeterias and among custodians in the Silicon Valley buildings of Apple and Hewlett-Packard.

As Trump took office in 2017, the International Longshore and Warehouse Union (ILWU), Filipino Advocates for Justice, and several other groups organized trainings to prepare workers for raids. Union members acted out scenarios that used job action to protect one another. Some were veterans of an earlier organizing campaign among recycling workers, in which they stopped work to keep the company from firing employees for not having papers.

OAKLAND, CA - Immigrants workers, members of the United Food and Commercial Workers and community activists demonstrated in front of the Mi Pueblo market in Oakland against the firing of undocumented workers because of their immigration status.  Thousands of workers around the country were fired as a result of the E-Verify document audits by the federal government.  The Mi Pueblo demonstration was the second day of a three day hunger strike to protest the firings.


Resisting in Working-Class Communities

For decades, immigration enforcement has paired workplace enforcement with community raids and sweeps. Workers have expected labor organizations to oppose immigration enforcement in their communities with the same vigor that unions oppose workplace raids. Unions have often delivered, as have community organizations.

The working-class neighborhoods of Chicago have a long history of huge marches to protest immigration raids. As Obama entered his second term in 2013, activist groups including Occupy Chicago blocked buses going to the immigration courts. Emma Lozano from Centro Sin Fronteras and other labor activists were arrested. Similar direct-action tactics were used in Tucson, Arizona, by young people who chained themselves to busses carrying detainees to the notorious special immigration court.

Trump's 2016 campaign promised to make Chicago a focus for enforcement. As anti-immigrant hysteria promoted by his campaign spread, ICE began detaining people during traffic stops, knocking on apartment doors, and pulling people off the street for interrogation and detention. The enforcement wave, which continued through 2019, included sweeps of the corners and sidewalks near Home Depot and other gathering sites for day laborers looking for work. The public presence of day laborers has historically made them a particular target for immigration street sweeps.

Activists met the Trump threat with actions. In July of 2019, thousands of people marched through the Loop in Chicago chanting "Immigrants are welcome here!" A day earlier, they'd shown up at the Federal Plaza after hearing that ICE agents were about to be deployed.

Unions helped organize the resistance. Don Villar, a Filipino immigrant who headed the Chicago Federation of Labor, told protesters, "Throughout the labor movement's history, immigrants have enriched the fabric of our city, our neighborhoods, our workforce, and our labor movement. Many of the fundamental rights that immigrants struggle to attain are the same rights the labor movement fights to secure for all workers every day." Labor activist Jorge Mujica demanded "an end to the increase in deportations that began with the economic downturn. Instead of spending money on war, we want money spent on schools and mental health clinics that the City of Chicago is shutting down."

Chicago also saw one of the most effective direct actions in the campaign against deportations. As President Obama mounted his 2012 reelection drive, young undocumented migrants, brought to the United States as children, occupied his campaign office. The occupation capped two years of organizing marches, ferociously fighting the detention of activists as they pushed for legislation to grant them amnesty from deportation. After reelection, Obama issued an executive order, Deferred Action for Childhood Arrivals (DACA), deferring their deportation.

DACA has withstood a legal assault for a decade, but right-wing courts and the MAGA administration will undoubtedly attempt again to kill it. Its minimal protections be lost for hundreds of thousands of people, but that's not all: DACA recipients have to provide personal information on their applications, which immigration authorities could use to find and detain them in a new deportation program.

The same problem confronts recipients of Temporary Protected Status, which allows people fleeing from environmental or political danger to stay and work in the United States. If Trump tries to withdraw the protection, even under legal challenge, the information necessary for detaining people is already in the government's hands. Haitian refugees in Springfield, Ohio, the target of J. D. Vance's racist lies about eating pets, undoubtedly feel a similar vulnerability.

SAN LEANDRO, CA - Workers at the recycling sorting facility of Alameda County Industries walked out on strike to protest the company's decision to fire workers accused of not having legal immigration status.   They weere supported by community leaders from a dozen organizations.  Assisted by Local 6 of the International Longshore and Warehouse Union, they blocked the garbage trucks bringing waste material into the plant.


Winning Back May Day

The most effective wave of immigration resistance in recent history hinged on the huge immigration marches of 2006. That year, provoked by the House of Representatives' passage of HR 4425, the Sensenbrenner Bill, people poured into the streets by the millions on May Day. The bill would have made it a federal felony to be in the United States without immigration papers, a danger so extreme that every undocumented family was threatened with severe punishment. The outpouring relied on Spanish-language radio to spread the word. It also depended on the networks of immigrant rights activists and organizations, which brought together people from the same hometowns in their countries of origin.

Unions were prominent among the mobilizers, organizing one of the two marches that took place on the same day in Los Angeles, each of which drew over a million participants. Unions and immigrant networks built marches of hundreds of thousands in cities across the country. The message was made even stronger by a grassroots movement, "A Day Without a Mexican," which urged immigrant workers to stay off the job to show the essential nature of their labor. When some participants were fired on their return, some unions became involved in defending their right to protest.

The movement achieved its short-term goal: HR 4425 died. But the cultural impact was just as important. May Day had been attacked as the "communist holiday" in the Cold War, and celebrations became tiny or disappeared altogether. After 2006, the United States joined the rest of the world in celebrating it, and marches are now held widely every year. While not as large as in 2006, annual May Day marches bring out progressive community and labor activists in large numbers - and could provide a readymade vehicle for challenging a renewed Trump deportation threat.

A similar bill, California's Proposition 187, which would have denied schools and medical care to undocumented children and families, also had unintended consequences. Proposition 187 convinced many Los Angeles immigrants and their citizen children to become voters, and the leftward movement of the city and state's politics owes a lot to that decision. As a result, labor now has a powerful political bloc in LA - in a city that was the "Citadel of the Open Shop" just a few decades ago.

Both May Day and the Day Without Immigrants became a vehicle for protesting Trump's first inauguration. For example, in San Francisco, members of several chapters of the Democratic Socialists of America marked the first May Day after Trump's election with a direct action blocking ICE's garage doors with a human chain, brandishing signs reading "Sanctuary for All" and "We Protect Our Community."

In the mobilizations around May Day and the Day Without Immigrants, labor support grew for immigrant workers facing raids. Four unions (Communications Workers of America, Amalgamated Transit Union, National Nurses United, and the United Electrical Workers) urged workers and labor activists to participate in both. "As leaders of the unions who supported Bernie Sanders for president, we refuse to go down that road of hatred, resentment and divisiveness," they declared in a letter. "We will march and stand with our sister and brother immigrant workers against the terror tactics of the Trump administration."

SAN FRANCISCO, CA - SEIU janitors from San Francisco and Los Angeles demonstrated in support of AB 450, a bill to protect workers during immigration raids and enforcement actions.


Replacing Immigrant Workers

Enforcement, however, doesn't exist for its own sake. It plays a role in a larger system that serves capitalist interests by supplying a labor force that employers require. Immigrant labor is more vital to many industries than ever. Over 50 percent of the country's entire agricultural workforce is undocumented, and the list of other dependent industries is long: meatpacking, some construction trades, building services, health care, restaurant and retail service, and more.

Trump would face enormous resistance from business owners if he tried to eliminate this workforce - an advantage and even a source of potential power for workers. In 2006, growers in California bused workers to the big marches, hoping the Sensenbrenner Bill wouldn't deprive them of labor. Within months of Trump's 2017 inauguration, agribusiness executives were meeting with him to ensure threats of a tightened border and raids would not be used when they needed workers. Just last month, construction companies in Texas were warning Trump that mass deportations would threaten their profits.

But workers, communities, and unions can't depend on employers to battle Trump for them. What companies need is labor at a cost they want to pay. The existing system has worked well for them - but not for workers. The Bureau of Labor Statistics estimates that about eight million of the eleven to twelve million undocumented people in the United States are wageworkers, and most are laboring for the minimum wage or close to it. The abysmal federal minimum of $7.25 per hour produces an annual income of $14,500. Even the higher minimums in states like California render an income of barely twice that.

Social Security estimates that the average US wage is $66,000, but the average farmworker family's income is below $25,000. That enormous difference is a source of enormous profit. If the industries dependent on immigrant labor paid the national average, they would have to pay undocumented workers an additional $250 billion. The pressure is on Trump not only to guarantee workers but to guarantee them at a cost acceptable to corporate employers. Looking at his picks for his cabinet, it is clear that employers' needs come first.

In his 2017 meetings with growers, Trump promised to expand the contract labor system, under which as many as 900,000 people recruited by employers work in the United States each year. These workers can come only to work, not to stay. Visa categories include the notorious H-2A program for farm labor, modeled after the old bracero program of the 1950s. Last year growers were given 370,000 H-2A visa certifications - a sixth of the entire US farm labor workforce. The program is known for abusing workers, and the recent reforms by Secretary of Labor Julie Su are already being targeted by growers and their MAGA allies for repeal. The H-2A program is already huge, but similar ones are growing in hospitality, meatpacking, and even for teachers in schools.

There is no way this many workers can be recruited and deployed without displacing the existing workforce, itself consisting mostly of immigrants already living here. For farmworker unions and advocates, this poses a dilemma, and H-2A's expansion will deepen it. How can they organize and defend the existing workers, including their members, and at the same time defend, and even help recruit, those brought to replace them? H-2A farmworkers themselves, however, are not simply passive victims and have a history of protesting exploitation. Going on strike means getting fired, losing the visa and having to leave, and then being blacklisting from future recruitment. Nevertheless, despite the risks, these workers sometimes act when conditions become extreme.

Unions like Familias Unidas por la Justicia (FUJ) in Washington state have assisted contract workers when strikes break out. Growers keep workers isolated, threatening them to make organizing as difficult as possible. In the meantime, FUJ and other unions protest the displacement, since the loss of jobs in farmworker communities means hunger and evictions. In many farmworker towns, the existing workers increasingly fear replacement, which makes strikes to raise wages risky and less frequent. Nevertheless, at the Ostrom mushroom plant in Washington state, the local workers, members of the United Farm Workers, have been on strike for two years against replacement by H-2A recruits.

According to author Frank Bardacke, in the early 1960s, a growing willingness of braceros to leave their camps and join strikes by local workers cost the program its popularity among growers. That helped lead to its eventual abolition. The Trump program for supplying labor needs will pose these same challenges - but also opportunities for organizing.

SAN FRANCISCO, CA - Migrant farmworkers, domestic workers and their supporters marched through San Francisco's Mission District to call for passage of the Registry Bill, which would allow undocumented people to gain legal immigration status.  The march was organized by the Northern California Coalition for Just Immigration Reform.


Beyond the Deportation Threat

In the civil rights era, fighting the mass deportations of the Cold War and the bracero program that gave growers the workers they wanted created two parallel demands. The leaders of the Chicano civil rights movement in particular - among them Bert Corona, Cesar Chavez, Larry Itliong, and Dolores Huerta - fought to end the program, a demand they won in 1964. But the movement did more than fight the abuse. It proposed and fought for more fundamental change.

Much of this fight this took place on the ground. In 1965, the year after the program ended, Larry Itliong and veteran Filipino farmworker unionists started the great grape strike. That same year, the civil rights movement among Chicanos, Mexicans, and Asian Americans won fundamental change in US immigration law. The family preference system, favoring the reunification of families over the labor needs of employers, became the basis of US immigration policy, at least for a time.

In the stream of people crossing the border, "we see our families and coworkers, while the growers just see money," says farmworker and domestic worker organizer Rene Saucedo. "So we have to fight for what we really need, and not just what we don't want." In other words, the struggle to stop enforcement and deportations requires fighting for an alternative. There have been many such alternative proposals in the past two decades, from the Dignity Campaign to the New Path of the American Friends Service Committee. Today the movement for an alternative is concentrated on the Registry Bill, a proposal that would give legal status to an estimated eight million undocumented people. The bill would update the cutoff date that determines which undocumented immigrants are eligible to apply for legal permanent residence. Right now, only people who arrived before January 1, 1973 can apply for it - a tiny and vanishing number. The proposal would bring the date to the present.

Another, longer-range demand is the extension of voting rights. It is no accident that many of the counties and states where the undocumented workforce is concentrated, and where it produces the most profit for employers, are MAGA strongholds. If the whole working population of Phoenix and Tucson could actually vote, it would likely elect representatives who would pass social protections for all workers. Extending the franchise could add enough people to the political coalition in Mississippi to enable it to finally expel the Dixie establishment. So instead of thinking of the vote as a restricted privilege, as we are taught, we need to think of it as a working-class weapon - and understand how powerful class unity could make us across the lines of immigration status.

By the same token, the political education of the US working class has to include an understanding of migration's roots and how US actions abroad - from military intervention to economic sanctions to neoliberal reforms - make migration a question of survival. When Mexican people fight for the right to stay home rather than coming north and elect a government that promises to move in that direction, they deserve and need the support of working-class people on the northern side of the border. Cross-border solidarity has a long history, but powerful media, cultural, and educational institutions deny us this knowledge. Without an independent effort to educate working people - whether by unions, communities, religious organizations, media workers, or progressive social movements - the door opens for MAGA and closes on our ability to organize in our own interest.

Joining the rest of the world, as we did when we joined the international tradition of celebrating May Day in 2006, means recognizing the direction other countries are moving. With 281 million people living outside their birth countries and children perishing in the Mediterranean or the Rio Grande, the international community sometimes tries to step up. One such step was the United Nations Convention on the Rights of All Migrant Workers and Members of their Families. It supports the right to family reunification, establishes the principle of "equality of treatment" with citizens of the host country in relation to employment and education, protects migrants against collective deportation, and makes both origin and destination countries responsible for protecting these rights. All countries retain the right to determine who is admitted to their territories and under what conditions people gain the right to work. So far, however, only forty-nine migrant-sending countries, like Mexico and the Philippines, have ratified it.

No US administration, Democratic or Republican, has ever submitted it to Congress for ratification.