Dependence Without Protection in U.S. Agriculture

by Maggie Traubert, Associate Member, University of Cincinnati Law Review Vol. 94

I. Introduction

The food and agricultural sector in the United States is a trillion-dollar industry,¹ employing more than 22 million workers nationwide.² At the core of food production are roughly 2.6 million farm laborers,³ over three-quarters of whom are immigrants.⁴ These workers are essential to domestic agriculture, yet they occupy some of the most legally vulnerable positions in the workforce.⁵

Roughly half of farmworkers are undocumented, meaning that they lack lawful authorization to work in the United States.⁶ Others hold temporary or employer-sponsored visas, such as H-2A agricultural worker visas, which allow foreign nationals to fill seasonal farm jobs for a specific employer for a limited period.⁷ This precarious legal status places workers in a difficult position: they are essential to agricultural production yet face constant threats of deportation or visa loss. Combined with often hazardous working conditions, limited labor protections, and minimal enforcement, these factors create an environment ripe for exploitation.

This Article explores how U.S. labor and immigration laws operate in structural tension—relying heavily on non-citizen workers to sustain the agricultural economy while simultaneously denying these workers meaningful legal protections and remedies. This paradox creates a legal framework that predictably enables widespread exploitation and leaves migrant laborers uniquely vulnerable within the workforce.

Part II provides a historical background of agricultural labor in the United States, tracing the nation’s long-standing reliance on immigrant workers—from early subsistence farming to racialized labor systems, exclusionary policies, and the Bracero Program—through to the modern agricultural workforce. Part III analyzes the contemporary legal landscape governing farm labor, focusing on statutory exclusions from labor protections, the role of immigration enforcement in shaping employer leverage, and the broader economic reliance on migrant workers. Finally, Part IV concludes by arguing that this structural tension—economic dependence paired with legal vulnerability—requires reforms that align labor protections with the essential role migrant workers play in sustaining the nation’s food system.

II. Background

A. Historical Development of Agricultural Labor

The current structure of agricultural labor in the United States did not emerge by accident but instead is the product of a long history of reliance on legally vulnerable non-citizen workers. In Colonial America, the vast majority of the population—approximately 90 percent—was employed in agriculture.⁸ Farming was largely subsistence-based, with households producing much of what they needed to survive, including food, clothing, household furnishings, and basic farm implements.⁹ Agricultural production was thus deeply embedded in local economies and organized primarily around family labor rather than a specialized workforce.¹⁰

This labor system began to change dramatically with industrialization in the nineteenth century.¹¹ From the development of steamboats and railroads, which increased mobility between markets, to farming technologies that boosted productivity and expanded production, the agriculture sector was fundamentally transformed from a localized subsistence system into a commercially oriented, market-driven industry.¹² At the same time, the growth of the United States as a destination for immigration reshaped the available labor supply.¹³

B. Racialized Immigrant Labor in Western Agriculture

One of the earliest major sources of immigrant agricultural labor in industrializing America was Chinese workers.¹⁴ Beginning in the mid-to-late nineteenth century, Chinese workers became central to the development of the West’s agricultural economy, first arriving in large numbers during the Gold Rush era and later transitioning into wage labor in the railroad, mining, and agricultural sectors.¹⁵ By the 1880s and 1890s, Chinese laborers made up 75 percent of California’s agricultural workers and were deeply integrated into the state’s expanding produce economy.¹⁶ Most Chinese laborers who came to the United States were largely motivated by the need to earn income to support families back in China.¹⁷ In addition, many were required to repay loans to Chinese merchants who had covered the cost of their journey.¹⁸ Together, these financial responsibilities compelled them to take whatever jobs were available, regardless of pay.¹⁹

Although their labor was essential to the growth of the West’s farming industry and broader economy, Chinese immigrant workers were rarely valued or protected, instead facing widespread discrimination, violence, and legal exclusion.²⁰ Rising anti-Chinese sentiment in California led the state government to pass a series of restrictive measures targeting Chinese residents, including special licensing requirements for workers and business owners and barriers to naturalization.

The Federal Government also enacted its own restrictions on Chinese immigration. In 1879, Congress limited Chinese arrivals to fifteen passengers per ship, and in 1882, efforts to constrain Chinese immigration culminated in the Chinese Exclusion Act, which suspended the immigration of Chinese laborers and required all Chinese travelers to carry certificates verifying their status.²¹ As the first major federal law restricting immigration, it marked a turning point in U.S. policy toward Chinese agricultural and industrial laborers.²² The exclusion of Chinese laborers illustrates an early pattern in U.S. agricultural development: economic reliance on immigrant labor paired with legal structures designed to regulate, exclude, or control that same workforce.

After the exclusion of Chinese laborers, agricultural employers in the western United States turned to new sources of immigrant labor to meet continued demand for a low-cost workforce. Japanese immigrants, along with workers from Korea, Punjab, and the Philippines, were recruited to fill this gap and quickly became central to agricultural production in California and Hawaii.²³ By the early twentieth century, Japanese American farmers produced more than 40 percent of California’s commercial vegetables and constituted a major share of the West Coast agricultural labor force.²⁴

This substitution did not disrupt the underlying structure of racialized agricultural labor; rather, it reinforced a recurring pattern in which one excluded immigrant group was replaced by another while remaining subject to legal and political exclusion.²⁵ As Japanese American success in agriculture increased, discriminatory measures such as California’s Alien Land Law of 1913 and exclusionary advocacy groups like the Asiatic Exclusion League sought to limit their economic stability and long-term land ownership, ensuring continued precarity despite their central role in food production.²⁶ Constraints culminated during World War II, when Japanese Americans were forcibly incarcerated, their farms and property seized, and their agricultural production exploited without compensation.²⁷ Even after the war, many returned to find their land lost, destroyed, or sold off, while others faced continued hostility, including boycotts and violence directed at “Japanese” produce.²⁸ This pattern of labor substitution and the trajectory of Japanese farmers reflects a consistent pattern in U.S. agricultural labor: reliance on immigrant workers for economic productivity paired with recurring legal and extralegal mechanisms that prevent long-term security and their replacement.

C. The Bracero Program

Following the late nineteenth century exclusion of Chinese workers, and the subsequent rise and displacement of Japanese agricultural labor, Mexican migrants increasingly filled the labor demands of U.S. agriculture. Although Mexican workers had long been present in U.S. agriculture, their role expanded dramatically during World War II and the creation of the Bracero Program.²⁹

The Bracero Program was a bilateral agreement between the United States and Mexico that authorized Mexican men to enter the country on short-term agricultural labor contracts.³⁰ Created to address labor shortages during WWII, the Bracero Program became the largest contract labor program in U.S. history, issuing over 4.6 million contracts.³¹ The program included formal protections: guaranteed payment at prevailing area wage received by native workers; adequate, sanitary, free housing; meals at reasonable prices; and free transportation back to Mexico at the end of the contract.³² In addition, employers were required to only hire in areas of domestic labor shortages.³³

In practice, many if not most of these rules were ignored.³⁴ The Mexican workers (“Braceros”),³⁵ were overworked and underfed, sometimes leading to starvation and death.³⁶ Low wages, unpaid housing, and poor working conditions were extremely common, and the U.S. employers benefited from a stable, inexpensive labor force. Although the program ended in 1964, many view it as having institutionalized migration from the south to the north and normalized the poor treatment of migrant workers, with the placement of workers in toxic environments continuing to this day.³⁷ Of the four million braceros who entered the United States, most never returned to Mexico, creating a lasting presence of Mexican workers in U.S. agriculture.³⁸

While the termination of the Bracero Program marked the official end of formalized contract labor, it did not signal the end of Mexican labor migration to the United States. In fact, migration patterns established during the program have continued into the present, with Mexican workers still constituting the backbone of U.S. agricultural labor.³⁹ Over the decades, the demand for low-cost, flexible, and seasonal labor in agriculture has persisted, making Mexican migrant labor essential to U.S. food production.

D. The Continuing Role of Migrant Labor and Modern U.S. Agriculture

Today, an estimated 86 percent of agricultural workers in the U.S. are foreign-born, and 45 percent of all U.S. agricultural workers are undocumented.⁴⁰ Requests for the H-2A Temporary Agricultural Worker Program—which allows foreign workers to fill U.S. agricultural jobs for up to eight months—more than doubled between 2010 and 2019, rising from 79,000 workers in 2010 to 258,000 in 2019.⁴¹ According to estimates by the Center for Migration Studies, of the approximately 283,000 undocumented immigrants who work as agricultural workers, Mexicans comprise the majority at 88%, followed by Guatemala (7%), El Salvador (2%), Honduras (2%), and Nicaragua (1%).⁴² Of this population, 71% have been living in the United States for more than ten years.⁴³

Like the foreign-born laborers who preceded them, today’s migrant workers often confront extreme working conditions that tend to exploit their marginal status. Physical and mental health risks, insufficient healthcare access, and substandard housing underscore the ways in which structural dependence on migrant labor coincides with systematic neglect. The following Part explores how these conditions are not incidental but enabled, in part, by legal frameworks that exclude farmworkers from full labor protections and by immigration enforcement action.

III. Discussion

Although the United States continues to rely heavily on migrant labor in agriculture, the conditions surrounding this workforce have evolved, shaped by legal exclusions, enforcement practices, and ongoing structural vulnerabilities. This Part examines the factors that shape farmworkers’ rights and protections in the contemporary labor system. Section A analyzes statutory exclusions from key labor protections, including wage and collective bargaining laws. Section B explores how immigration enforcement and deportation threats enhance employer leverage and suppress worker bargaining power. Section C evaluates the economic contributions of migrant farmworkers and the broader structural reliance on their labor, highlighting the tension between their essential role and their limited legal protections.

A. Labor Statutes and Workers’ Rights

The legal landscape governing farm labor in the United States has long reflected a tension between economic reliance on migrant workers and the limitations placed on their enforceable rights. From the New Deal to contemporary labor protections, farmworkers have historically been excluded from many of the legal mechanisms available to other workers—a pattern that echoes earlier exclusionary laws targeting Chinese and Japanese laborers, which constrained economic and legal security for immigrant workers.

The Fair Labor Standards Act (“FLSA”) is a U.S. law that establishes minimum wage, recordkeeping, overtime pay, and child labor standards.⁴⁴ However, the Act includes significant exemptions for agricultural labor, particularly for small farms and seasonal work.⁴⁵ Under the FLSA, employees engaged in agricultural work are generally exempt from overtime pay, meaning they are not entitled to time-and-a-half for hours worked over forty in a week.⁴⁶ Additionally, employers who did not use more than 500 “man-days” of agricultural labor in any calendar quarter of the preceding year are not required to pay minimum wage or overtime to agricultural employees.⁴⁷ Undocumented farmworkers and H-2A workers are disproportionately employed in seasonal, small-scale, or piece-rate agricultural jobs—categories that fall into the Act’s exemptions.⁴⁸ As a result, many of these workers perform long hours under physically demanding conditions without the full economic safeguards that the Act provides to other employees.

Under the National Labor Relations Act (“NLRA”),⁴⁹ farmworkers do not have a federal right to collective bargaining, meaning they are excluded from protections against retaliation when attempting to organize or negotiate with their employer.⁵⁰ As a result, whether at the state or federal level, most farmworkers cannot use unions to collectively bargain over wages, hours, benefits, or working conditions, leaving them dependent on employers’ discretion.⁵¹

For undocumented farmworkers, this exclusion compounds their vulnerability. Although immigration status alone does not determine coverage under the NLRA, farmworkers as a class are excluded from its protections. In practice, the absence of enforceable collective bargaining rights limits their ability to challenge exploitative conditions, further entrenching the power imbalance between workers and employers. By examining these statutes, it becomes clear how legal frameworks recognize farmworkers’ essential role while simultaneously constraining their capacity to enforce labor protections.

B. Immigration Enforcement and Employer Leverage

The threat of deportation and strict immigration enforcement exerts a powerful influence over migrant farmworkers, shaping their willingness to accept hazardous working conditions and low wages.⁵² Many workers tolerate physically demanding labor, exposure to pesticides, and long hours because losing their job could mean deportation or the loss of a temporary visa.⁵³ Crackdowns on unauthorized workers, however, can create labor shortages with immediate economic consequences.⁵⁴ For example, strict immigration laws passed in several states have demonstrated these effects: a University of Georgia study found that House Bill 87, enacted in April 2011, reduced the state’s agricultural labor supply and cost Georgia over $181 million in less than a year due to labor shortages.⁵⁵

Federal immigration enforcement has intensified the precariousness of migrant farmworkers, with U.S. Immigration and Customs Enforcement (“ICE”) raids deterring foreign laborers from showing up to work and exacerbating existing agricultural labor shortages.⁵⁶ Reports indicate that workplace immigration enforcement actions have made some workers fearful of attending jobs in the fields, prompting farmers to seek policy changes that would make hiring easier amid ongoing labor constraints.⁵⁷ Moreover, immigration crackdowns have repeatedly forced undocumented and documented workers to stay home or hide, further straining an already tight workforce and weakening workers’ ability to push back against dangerous conditions or employer pressure.⁵⁸

Yet again, these dynamics reinforce the core tension in the modern farm labor system because, while U.S. agriculture relies heavily on immigrant labor to harvest and process food, enforcement policies deliberately keep that workforce in a fragile legal status, empowering employers to maintain leverage over wages and conditions. In this context, threats of deportation and immigration raids do not merely exist alongside exploitative labor practices—they actively shape the labor market, reducing workers’ bargaining power and deterring collective action, even as shortages reveal how indispensable these workers are to the nation’s food supply.

C. Structural Reliance and Economic Contribution

The exemptions and exclusions from labor law protections, alongside immigration enforcement, create a striking tension when considered alongside the essential role of migrant workers in the U.S. food system. Leaving these workers legally vulnerable—through risk of deportation, visa denial, exclusion from protections, limited remedies, and lack of overtime pay—can feel like a questionable choice given how critical they are to agricultural production and the broader economy.

One Federal Reserve Bank of Dallas study found that immigrant laborers helped the U.S. grow substantially after the COVID-19 pandemic spurring job growth and keeping down inflation.⁵⁹ Another study shared that the decrease of two million immigrants between 2019 and 2021 had a detrimental impact on several industries, including agriculture.⁶⁰ Undocumented immigrants also “paid $25.7 billion in Social Security taxes, $6.4 billion in Medicare taxes, and $1.8 billion in unemployment insurance in 2022, programs for which they are ineligible.”⁶¹

These economic contributions of migrant workers also underscore the tension in U.S. labor and immigration policy. Despite driving post-pandemic growth, sustaining agriculture, and funding federal programs they cannot access, these workers remain excluded from key protections and subject to deportation or visa risk. These contributions underscore that the marginalization of migrant farmworkers is not economically necessary but legally constructed.

Together, these factors illustrate the structural tension at the heart of U.S. agriculture. The combination of statutory gaps, enforcement pressures, and economic reliance creates a system in which exploitation is predictable, and worker remedies are constrained. Understanding this paradox is crucial for evaluating potential reforms that could protect these essential workers while maintaining the stability of the agricultural labor force.

IV. Conclusion

The United States’ reliance on migrant farmworkers exposes a fundamental tension: the economy depends on these laborers to sustain food production and broader economic growth, yet the legal and social systems keep them precariously vulnerable. Exclusions from labor protections, limited remedies, and the constant threat of deportation ensure that workers remain highly constrained, while employers retain leverage over wages and conditions. This structural paradox—essentiality paired with vulnerability—has persisted across history, from early immigrant labor to the present, and continues to shape the experiences of millions of migrant workers in agriculture today. U.S. law has not merely failed to protect agricultural workers; it actively structures dependence on legally vulnerable labor.

Addressing this tension requires legal and policy reforms that recognize both the economic and human stakes. Creating legal pathways for undocumented workers would not only provide stability and access to labor protections but also strengthen the agricultural economy: economists estimate legalization could contribute $1.2 trillion over ten years and $184 billion annually in taxes.⁶² Beyond the economic benefits, reforms would establish certainty in the labor market, allow employers to invest confidently, and reduce the incentives for undocumented migration.⁶³ By aligning legal protections with the essential role of migrant workers, such policies could resolve the contradiction at the heart of U.S. agriculture—ensuring that those who feed the nation are no longer left structurally vulnerable.

Cover Photo by Tim Mossholder on Unsplash.

Author

Maggie Traubert

References

1
The Essential Role of Immigrants in the U.S. Food Supply Chain, Migration Policy Institute (Mar. 2025), https://www.migrationpolicy.org/content/essential-role-immigrants-us-food-supply-chain [https://perma.cc/Q2HF-Z8DN].
2
Kathleen Kassel, Agriculture and Its Impact on the U.S. Food System, USDA Economic Research Service (Nov. 2023), https://www.ers.usda.gov/data-products/chart-gallery/chart-detail?chartId=58282 [https://perma.cc/6CV5-GW4X].
3
Id.
4
See The Essential Role of Immigrants, supra note 1.
5
Josselyn Andrea Garcia Quijano, Workplace Discrimination and Undocumented First‑Generation Latinx Immigrants, Advocates’ Forum, University of Chicago Crown Family School of Social Work, Policy, and Practice (last visited Apr. 2026), https://crownschool.uchicago.edu/student-life/advocates-forum/workplace-discrimination-and-undocumented-first-generation-latinx [https://perma.cc/4M6H-E5LW].
6
Marcelo Castillo, Legal Status of Hired Crop Farmworkers, Fiscal 1991–2022, U.S. Dep’t of Agric., Econ. Research Serv. (Sep. 2025), https://www.ers.usda.gov/data-products/chart-gallery/chart-detail?chartId=63466 [https://perma.cc/HZT7-NKFL].
7
See Andrew Moriarty, Immigrant Farmworkers and America’s Food Production: 5 Things to Know, FWD.US (Sep. 2022), https://www.fwd.us/news/immigrant-farmworkers-and-americas-food-production-5-things-to-know/ [https://perma.cc/G48L-HR99].
8
U.S. Nat’l Park Serv., The Dust of Many a Hard-Fought Field: Place Attachment and Agriculture at Minute Man, https://www.nps.gov/articles/000/-the-dust-of-many-a-hard-fought-field-place-attachment-and-agriculture-at-minute-man.htm [https://perma.cc/4SD4-VAKS] (last visited Apr. 2026).
9
Id.
10
Id.
11
Matthew A. McIntosh, The American Market Revolution, 1815–1840, Brewminate (Mar. 2018), https://brewminate.com/the-american-market-revolution-1815-1840/ [https://perma.cc/JG4E-JAHC].
12
Id.
13
Charles Hirschman & Elizabeth Mogford, Immigration and the American Industrial Revolution from 1880 to 1920, 38 Soc. Sci. Res. 897, (2009), https://doi.org/10.1016/j.ssresearch.2009.04.001 [https://perma.cc/53WF-BH3J].
14
U.S. Dep’t of State, Office of the Historian, Chinese Immigration and the Chinese Exclusion Acts, Milestones in the History of U.S. Foreign Relations, https://history.state.gov/milestones/1866-1898/chinese-immigration [https://perma.cc/DT5S-M2K9] (last visited Apr. 2026).
15
Id.
16
Tam Le, Deeply Rooted: How Asian Americans Shaped U.S. Agriculture, THE SPRUCE EATS (Apr. 2021) https://www.thespruceeats.com/history-of-asian-americans-in-us-agriculture-5120814#:~:text=Asian%20immigrants%20made%20up%2075%20plus%20percent,just%200.7%20percent%20of%20the%20farming%20population [https://perma.cc/4KY9-WQWR].
17
U.S. Dep’t of State, supra note 14.
18
Id.
19
Id.
20
Id.
21
Id.
22
Id.
23
Local First Arizona, How Asian American Farmers Helped Shape U.S. Agriculture, (May 2022), https://localfirstaz.com/news-blog/2022/5/23/how-asian-americans-farmers-helped-shape-us-agriculture#:~:text=One%20of%20the%20first%20groups,well%20as%20organized%20farm%20unions [https://perma.cc/L43S-UYCS].
24
Kaila Yu, The Rise of Asian Farmers in America, Offrange (May 2025), https://ambrook.com/offrange/culture/Asian-farmers-in-America [https://perma.cc/H67W-WB46].
25
See Jesse La Tour, Chinese Farm Labor and Exclusion in 19th Century California, Fullerton History (Dec. 2022) https://fullertonhistory.com/2022/12/14/chinese-farm-labor-and-exclusion-in-19th-century-california/ [https://perma.cc/DLC4-VH5J].
26
Yu, supra note 24.
27
Id.
28
Id.
29
See Mary E. Mendoza, Mexican Farm Labor and Agricultural Economy of the United States, Gilder Lehrman Inst. Am. Hist., 53 Hist. Now (Winter 2019), https://www.gilderlehrman.org/history-resources/essays/mexican-farm-labor-and-agricultural-economy-united-states [https://perma.cc/6VU4-39H8].
30
About the Bracero Program, Bracero Hist. Archive, https://braceroarchive.org/about [https://perma.cc/BSJ9-VBAZ] (last visited Apr. 2026).
31
Id.
32
Id.
33
Id.
34
Id.
35
Workers were called “braceros,” from the Spanish word bracero, meaning “laborer,” “arm-man,” or “one who works with their arms.” See Fred L. Koestler, The History of the Bracero Program: Mexican Farm Labor in the U.S., Tex. State Historical Ass’n (Aug. 1995) https://www.tshaonline.org/handbook/entries/bracero-program [https://perma.cc/4N5A-MXCK].
36
Mendoza, supra note 29.
37
Id.
38
Koestler, supra note 35. (“The Immigration Reform Control Act of 1986 gave legal status, or amnesty, to those who resided and worked in this U.S. by January 1, 1982,” however, undocumented workers are still hired and exploited.)
39
Mendoza, supra note 29.
40
Raquel Rosenbloom, A Profile of Undocumented Agricultural Workers in the United States, Center for Migration Studies (Aug. 2022) https://cmsny.org/agricultural-workers-rosenbloom-083022/ [https://perma.cc/DEF5-ZG3D].
41
Id.
42
Id.
43
Id.
44
Fair Labor Standards Act of 1938, 29 U.S.C. §§ 201–219.
45
U.S. Dep’t of Labor, Wage & Hour Div., Fact Sheet #12: Agricultural Employment Under the FLSA, U.S. Dep’t of Labor https://www.dol.gov/agencies/whd/fact-sheets/12-agricultural-employment-flsa [https://perma.cc/U95L-RQWC] (last visited Apr. 2026).
46
Id.
47
Id.
48
See Alexandra Hill & Francisco Scott, Some Segments of the Agricultural Economy Are Particularly Sensitive to Changes in the Foreign-Born Farm Labor Supply, Fed. Res. Bank of Kansas City (June 2025) https://www.kansascityfed.org/research/economic-bulletin/some-segments-of-the-agricultural-economy-are-particularly-sensitive-to-changes-in-the-foreign-born-farm-labor-supply/#:~:text=Historically%2C%20the%20industry%20has%20depended,their%20reliance%20on%20undocumented%20workers. [https://perma.cc/V9S4-Q57R].
49
29 U.S.C. §§ 151–169.
50
Samantha Mikolajczyk, Collective Bargaining Rights for Farmworkers, Nat’l Agric. L. Ctr (Jul. 2025) https://nationalaglawcenter.org/collective-bargaining-rights-for-farmworkers/ [https://perma.cc/2UZ6-32KS].
51
Id.
52
See Matthew Hall & Emily Greenman, The Occupational Cost of Being Illegal in the United States: Legal Status, Job Hazards, and Compensating Differentials, 49 Indus. Relations 275 (2010), https://journals.sagepub.com/doi/10.1111/imre.12090 [https://perma.cc/NKF4-BMN8].
53
Id.
54
John C. McKissick & Sharon P. Kane, Evaluation of Direct and Indirect Economic Losses by Georgia Fruit and Vegetable Producers, 29 J. Agribusiness 267 (Fall 2011).
55
Id.
56
See Frank Morris, ICE Raids Have Deterred Foreign Farm Workers, But Farmers Hope to Make Hiring Easier, NPR (Dec. 2025) https://www.npr.org/2025/12/02/nx-s1-5604903/ice-raids-have-deterred-foreign-farm-workers-but-farmers-hope-to-make-hiring-easier [https://perma.cc/CS3Z-YSPZ].
57
Id.
58
Ryan Nebeker, How the Current Immigration Crackdown is Impacting Food and Farmworkers, FoodPrint (Aug. 2025) https://foodprint.org/blog/how-the-current-immigration-crackdown-is-impacting-food-and-farmworkers/ [https://perma.cc/M3PT-T5RA].
59
Pia Orrenius, Ana Pranger, Madeline Zavodny & Isabel Dhillon, Unprecedented U.S. Immigration Surge Boosts Job Growth, Output, Fed. Res. Bank Dallas (July 2024) https://www.dallasfed.org/research/economics/2024/0702 [https://perma.cc/63SA-HEVT].
60
Kevin Appleby, The Importance of Immigrant Labor to the US Economy, Center for Migration Studies (Sept. 2024) https://cmsny.org/importance-of-immigrant-labor-to-us-economy/ [https://perma.cc/ZJ66-E5DS].
61
Id.
62
Id.
63
Id.