Immigration law finds its roots early in the creation of the United\u00a0States. The Constitution gives Congress the power to enact laws\u00a0governing the naturalization of non-citizens, underscoring the\u00a0importance of both immigration and citizenship to this country. The\u00a0subsequent Naturalization Act of 1790 laid down the first requirements\u00a0for obtaining citizenship and helped set the precedent that immigration\u00a0status, particularly citizenship, was a benefit to be given at the discretion\u00a0of the government. Throughout the history of the United States,\u00a0immigration law has developed into a complex area of civil law,\u00a0reflecting the view that immigration law is a type of public benefit law.\u00a0Immigrants who come to the United States are allowed to do so out of\u00a0the good will of our lawmakers and our citizens. Thus, the taking away\u00a0of immigration status should not be looked at as a punishment, but rather\u00a0as a remedy for violating the laws of American society. This notion has\u00a0been well established in immigration law since the Supreme Court\u2019s\u00a0decision in Fong Yue Ting v. United States, in which the Court held that,\u00a0because deportation was not a punishment for a crime, constitutional due\u00a0process protections were not implicated in removal proceedings.<\/p>\n