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The use of national security language to create and defend immigration law is historic. The Immigration and Nationality Act (INA) which Congress enacted in 1952 contains sections to exclude or deport noncitizens for "security and related grounds." A sublayer of this section is aimed at noncitizens who engage in "any other criminal activity which endangers the public safety or national security . . . ." The Executive Branch has published regulations and policies that use national security language in a similar manner. Federal courts have further upheld immigration laws or deferred to Congress or agencies in the name of national security. One tool that has enabled the cohabitation of national security and immigration is the "plenary power doctrine," which originates from a case known as Chae Chan Ping v. United States (alternately, the Chinese Exclusion Case) and refers to the complete power "political branches" have over immigration. As administrative and immigration law scholar Michael Kagan has described, [h]aving chosen an extra-constitutional foundation for immigration law, the Court quickly came to the conclusion that the judiciary had little or no role in reviewing decisions prohibiting foreigners from entering the country . . . ." The practical impact is that legal questions noncitizens raise regarding entry or rights in the United States are limited. Indeed, when the plenary power doctrine is invoked, the courts will not intervene.