Congressional authority over immigration is not explicit in the U.S. Constitution, but generally is considered to derive from several constitutional clauses. The U.S. Supreme Court has noted that, "The Constitution grants Congress the power to 'establish an uniform Rule of Naturalization.' Art. I., § 8, cl. 4. Drawing upon this power, upon its plenary authority with respect to foreign relations and international commerce, and upon the inherent power of a sovereign to close its borders, Congress has developed a complex scheme governing admission to our Nation and status within our borders." Further, the Fourteenth Amendment defines citizens as "[a]ll persons born or naturalized in the United States and subject to the jurisdiction thereof." Amend. XIV, § 1, cl. 1. Although some legal scholars have argued that the phrase "uniform Rule of Naturalization" precludes Congress from enacting legislation granting relief to a specific individual, the courts have interpreted the phrase as simply requiring geographic uniformity throughout the States, meaning that Congress cannot enact legislation applying different rules to different States. The constitutional basis for private immigration bills generally is found in the First Amendment prohibition against Congressional enactments abridging the right of the People "to petition the Government for a redress of grievances" (Amend. I, cl. 3.) and in the power of Congress to pay the debts of the United States (Art. I, § 8, cl. 1). Regardless of academic concerns about the clarity of authority for private immigration legislation, clearly, Congress has a long history of such enactments. When the public laws relating to immigration operate to prevent someone from entering or remaining in the United States or obtaining some other benefit such as citizenship, private immigration bills provide for exceptions for named individuals or small groups of individuals whose circumstances merit special consideration. Private bills are intended to be a last resort for relief after all administrative and judicial remedies are exhausted. Aside from the individual relief granted, the number and type of private bills introduced and of private laws enacted often revealed flaws in the public laws which led to amendments to resolve such problems. Conversely, expansion of immigration restrictions and elimination of relief in the public immigration laws may lead to an increase in private bills. Overall, 7321 private immigration laws have been enacted since the first such law was enacted in 1839. Although the first private immigration laws enacted were related to naturalization, naturalization waivers constitute the lowest percentage of private laws because of the serious ramifications of conferring citizenship and its rights and obligations and of the United States' undertaking the protection of its new citizens. The majority of private immigration bills confer lawful permanent resident (LPR) status by waiving a general law provision which prevents the granting or maintenance of such status, whether that provision concerns grounds of inadmissibility or deportation, numerical allocation limits, definitions of eligible immigrant categories, etc. As noted above, under the rules of both the Senate Subcommittee on Immigration, Border Security and Citizenship and the House Subcommittee on Immigration, Border Security and Claims, no private bill shall be considered or acted upon by the Subcommittee until all avenues for administrative and judicial relief have been exhausted. If the beneficiary is subject to removal/deportation, the mere introduction of a bill does not stay such removal/deportation. A stay will generally be authorized by the U.S. Immigration and Customs Enforcement (ICE) in the Department of Homeland Security (DHS) when it receives a request for a report on information concerning a beneficiary's case from either the Senate or House Subcommittee Chairman. However, this stay is granted as a matter of custom and courtesy by the agency to the congressional subcommittee and thus is purely discretionary, not legally mandated. Under the Senate Subcommittee rules, requests for reports on private bills will be made by the Subcommittee Chairman only upon a written request addressed to the Chairman by the author of the bill. The Senate Subcommittee will not request a report or make other communications to defer deportation of beneficiaries who entered the United States as nonimmigrants, stowaways, in transit, deserting crewmen, or without inspection through the land or sea borders. The Subcommittee may make an exemption from this rule where the bill is intended to prevent "unusual hardship" to the beneficiary or to U.S. citizens related to the beneficiary and the author of the bill has submitted complete documentary evidence to the Subcommittee in support of a request to make an exception to the rule. Under the House Subcommittee rules, the Subcommittee will not intervene in removal/deportation proceedings or request a stay by requesting a report from ICE unless the bill is designed to prevent "extreme hardship" to the beneficiary or a U.S. citizen spouse, parent or child. The distinction between the Senate and House Subcommittee rules is that the Senate Subcommittee will generally request a report upon the request of the author of a bill without an initial consideration of the merits of the case and only requires a showing of hardship for certain disfavored categories, whereas the House Subcommittee will not request a report in any case unless a motion to request a report has been made at a formal meeting of the Subcommittee and a consideration of whether the "extreme hardship" requirement has been met. When ICE has received a request for a report on a private bill beneficiary and granted a stay of removal/deportation, the date established for removal/deportation or voluntary departure under any final order shall be February 1 of the next odd-numbered year, or in other words, of the first session of the next Congress following the one in which the bill was introduced. However, if the beneficiary's continued presence in the United States would be or becomes contrary to the best interests of the United States, removal/deportation may be carried out after consultation with the author of the private bill and the Judiciary Committee that requested a report. If adverse action is taken on a private bill for which a stay of removal/deportation has been granted, ICE will establish a date by which removal/deportation or voluntary departure must be effected; ICE may extend the deadline at its discretion. Exactly what constitutes an adverse action or disposition is not defined in the laws, regulations, or Operations Instructions concerning immigration. It appears that such actions would include a decision by the Subcommittees to not recommend a private bill for action by the full Committee; a decision by the full Committee to not report a bill favorably to the entire Chamber; a negative vote by either Chamber; or a veto by the President. Presumably, adverse dispositions may also include a decision at a formal meeting under the House Subcommittee rules to not request a report because the extreme hardship requirement has not been met or a decision in the Subcommittee or full Committee to table a private bill. If no adverse action or final positive action has been taken on a bill by the end of a Congress, the February 1 deadline affords the author of a private bill time to reintroduce a bill in the following Congress; ICE may extend the deadline at its discretion. ICE notifies the beneficiary if a bill has had an adverse disposition or is not reintroduced and informs them of the new date set for execution of any outstanding order of removal/deportation or deadline for any voluntary departure granted. A complete report on the beneficiary of a private bill is transmitted by ICE to the requesting Subcommittee. If classified or confidential information exists with regard to the beneficiary that ICE is not authorized to transmit, ICE will refer the Subcommittee to the pertinent agency for further information. After the submission of a report, if further material information is received or any material action is taken concerning a beneficiary which may affect congressional consideration of a private bill, a supplementary report shall be submitted to the Committee or Subcommittee. ICE may advise the Committee or Subcommittee informally if the new information concerns the granting of administrative relief or is particularly adverse. If a private bill for which a report was made is reintroduced in the following Congress in the same chamber whose Subcommittee requested the report, any additional material developed from a review of the file and any new background checks or interviews shall be in transmitted to the Subcommittee in a supplemental letter. If the previous report was made to a different chamber in the immediately preceding Congress or to the same chamber in a previous Congress not immediately preceding the one in which the bill has been reintroduced, a new full report shall be submitted to the requesting Subcommittee. If adverse action was taken on a private bill at any time and a new bill is subsequently introduced for the same purpose for the same beneficiary in either chamber, ICE will not honor a request for a report concerning the new bill unless the adverse action on the previous similar bill is reconsidered and ICE is notified of such reconsideration. If a private bill beneficiary holds a nonimmigrant visa status, the introduction of a private immigration bill to confer permanent resident status raises a presumption of termination of such status, which will be handled as described below. Any pending removal/deportation proceedings are conducted to a final determination; any resulting order of removal/deportation may be stayed according to procedural practice described above. If such proceedings are not already pending and the beneficiary had a lawful B (visitor), C (transit), D (crewmen), or H (temporary worker) visa status when the private bill was introduced, ICE will notify the beneficiary of the termination of nonimmigrant status due to the private bill introduction and request a response from the beneficiary within 30 days from receipt of notice about whether he/she desires to have status adjusted through the private bill. If the beneficiary does not desire adjustment by the private bill, nonimmigrant status will likely be restored. If a report has been requested, ICE shall submit the report with an explanation of why the beneficiary does not desire adjustment through the private bill. If adjustment through the private bill is desired, removal/deportation proceedings shall be initiated and conducted to a final determination.