More than a decade ago, three states banned undocumented students from public colleges. For the post-DACA generation, the toll has been steeper.
Correction, March 24, 2023, 6:48pm: This article incorrectly identified which Columbia College Diana Pliego attended. It is in South Carolina, not Missouri. The article has been changed to reflect that, and to more precisely describe how Pliego paid for college.
During his junior year in high school, Steven was asked by a guidance counselor to list his top three colleges. Like many ambitious high-schoolers in South Carolina, his first choice was a no-brainer: Clemson University. He grew up watching football games with his family and had envisioned himself going there since he was a little kid. “Clemson has always been a huge part of my life,” he says.
As a freshman in high school, Steven visited the campus, about 45 minutes away from home, for the Men of Color National Summit, a two-day event designed for young African American and Hispanic men. It encouraged him to dream big and further solidified his conviction that he would apply to Clemson.
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So Steven was surprised when his guidance counselor, whispering to ensure privacy in a shared high-school office, broke the news to him: By law, he couldn’t attend Clemson because undocumented students are banned from enrolling in any public college in the state. (Steven is being identified by first name only because of his immigration status.)
Born in Mexico, Steven moved to the United States before his first birthday. South Carolina is the only home he’s known. “My parents have told me stories about crossing the border,” he says. “I was in a little baby carriage, but I don’t remember anything at all.”
If things had worked out a little differently, he’d have been referred to as a “Dreamer.” When Steven turned 16, he applied to the Deferred Action for Childhood Arrivals program, or DACA, but his application was never completed because, after President Donald J. Trump sought to end the program in 2017, the government stopped processing new applications.
As a high-school senior this year, Steven is in one of the first classes to navigate the college-application process without the protections afforded by DACA. His experience is likely to be an increasingly common one for undocumented students who apply to colleges that have for the past decade shaped their policies to accommodate recipients of the DACA program.
Learning about the state’s ban left him feeling worried and scared. “Going to Clemson was something that motivated me,” he says. “I thought it ended my opportunity to go to college.”
South Carolina enacted the enrollment ban in 2008, and it is still supported by the state’s Republican-led legislature. The goal was to prevent undocumented immigrants from realizing any kind of public benefit, which included access to state-funded institutions. Alabama passed a similar law in 2011, and in 2010 the Georgia Board of Regents created a policy to ban undocumented students from the top public colleges in the state. As State Rep. Micky Hammon, a co-author of the Alabama legislation, put it: “This bill is designed to make it difficult for them to live here so they will deport themselves.”
One in five Hispanic South Carolinians are like Steven: undocumented and banned from attending public colleges in the state, an analysis by The Chronicle found. And every year since the enrollment bans passed, it is estimated that at least 500,000 undocumented people have lived in the three states, all of whom are subject to the bans. The policies have had deeply personal impacts on countless students and their families, and a less obvious but still significant effect on the states’ economic vitality.
Many undocumented students either leave these states to attend college and don’t return, enroll in a private institution, or end up letting go of their college dreams altogether, according to interviews with dozens of students, high-school teachers, counselors, scholars, and immigration advocates. The bans, they say, are part of a larger message being conveyed by state officials to undocumented students: The doors of opportunity are frozen shut.
After the initial sadness that came with the news about Clemson, Steven quickly changed course. His high-school counselor didn’t mention he could still apply to private colleges in South Carolina. But after his mother sought information through friends whose undocumented children had gone to college, Steven’s new first choice became Furman University, a private college in the state that accepts undocumented students. But getting accepted is only his first challenge. Furman’s sticker price is $73,920 a year.
The price tag made Steven nervous, unsure that college is a realistic option for him. “Having the disadvantage of not having papers,” he says, “I wonder, is this possible?”
An estimated 11 million people living in the United States are undocumented, approximately 2.1 million of them 24 or younger. The nation’s education laws regarding them have long been inconsistent. Plyler v. Doe, a 1982 decision by the U.S. Supreme Court, affirmed the right of undocumented children to attend K-12 public schools nationwide on the grounds that they’re entitled to 14th Amendment protections, and that preventing children from education violates the equal-protection clause.
The Supreme Court’s decision, however, did not mention higher education. Federal law is silent on whether undocumented students should or should not be permitted to attend college, so each state has created its own rules.
Twenty-three states and the District of Columbia have deemed undocumented students eligible for in-state tuition.
South Carolina, Georgia, and Alabama have been outliers, but they may be harbingers of a future of diminished access. Florida’s governor and Texas legislators have signaled a desire to repeal existing state laws that have allowed undocumented students to, respectively, pay in-state tuition or simply attend the state’s public institutions.
South Carolina, Georgia, and Alabama’s bans were enacted amid a rise of anti-immigrant rhetoric approaching the 2008 presidential election. In a debate during the Republican primary, Mitt Romney weighed in on whether undocumented students should be allowed to pay in-state tuition. “Illegals are not going to get taxpayer-funded breaks that are better than our own citizens,” Romney said.
The total undocumented population nearly quadrupled from 1990 to 2007, peaking at 12.2 million, according to the Pew Research Center. By 2008, efforts to update federal immigration policy had failed (the last time sweeping immigration reform passed on the federal level was 1996). States decided to take it upon themselves to address immigration, which meant that policies were shaped by the politics of each state.
While Democratic-led states like California eased the struggles undocumented immigrants face, many Republican-led state legislatures enacted bills to deny public benefits to undocumented people, making their lives significantly harder.
In 2008, South Carolina became the first state to pass legislation explicitly barring undocumented immigrants from gaining access to public higher education. It was part of a larger bill, known as the South Carolina Illegal Immigration Reform Act, that chiefly took aim at employers; it discouraged them from hiring undocumented immigrants by levying fines and penalties, and it required them to verify the work status of employees. While some parts of the legislation were challenged in court, the higher-education ban was not, which means this aspect of the law largely flew under the radar.
The bill had 48 sponsors, all Republicans. The law’s supporters said that taxpayers shouldn’t subsidize the college education of undocumented students and that they take spots away from academically qualified American citizens.
After the South Carolina House of Representatives passed the bill 80 to 13, the lead sponsor, Robert W. Harrell Jr., a Republican from Charleston who was also the House speaker, told The Post and Courier, “We’re just responding to what our constituents have said they want to see done.”
He also wrote an opinion piece around that time stating that, “our national borders are wide open,” and asserting that immigrants cost South Carolina taxpayers $186 million a year, a figure for which he provided no source. Harrell, who is no longer in office (in 2014 he resigned after pleading guilty to six counts of misusing campaign funds), did not respond to several requests for comment. In June 2008, then-Gov. Mark Sanford, a Republican, signed the immigration bill.
South Carolina’s ban relied on assumptions that underpinned much of the legislation during that period, says Sophia Rodriguez, an assistant professor in the College of Education at the University of Maryland at College Park. According to an analysis she conducted of more than 100 proposed and enacted pieces of legislation in South Carolina from 2005 to 2011, immigrants were consistently described as an economic and security threat to the state.
“The word ‘immigrant’ really doesn’t appear in the state policies. It’s always referring to the ‘outsider,’ or the ‘other,’ or the ‘alien,’ or the ‘illegal,’ or the ‘unlawful,’” says Rodriguez, who also noted the state’s long history of educational inequity, including its 20-year delay in desegregating schools following Brown v. Board of Education. “South Carolina also recruits migrant labor to different industries. They want their exploited labor,” Rodriguez says, “but they don’t actually want to provide access to social and public resources.”
In 2010, Georgia followed suit in the form of a directive from the state’s Board of Regents. A committee of five regents and four university presidents convened in response to pressure from 15 state senators who had written a letter calling for the university system to deny admission to undocumented immigrants.
An incident from the news also motivated them to act. A Kennesaw State University student was found to be getting in-state tuition after a traffic arrest showed she was undocumented. “In the atmosphere we’re in today, with people as irate as they are about nonresidents getting benefits, that’s an added possibility for us to consider to firm our application forms up and to do what we’ve got to do,” said Larry Walker, at the time a regent and former majority leader of the Georgia House of Representatives, in remarks at the committee’s first meeting, according to The Florida Times-Union. The Chronicle couldn’t reach Walker for comment.
In its report to the regents, the committee tried to put the issue in perspective: Just 501 undocumented students, or a fraction of 1 percent of the student body, were enrolled in Georgia public colleges, and by this time, all of them were paying out-of-state tuition. Only 27 undocumented students attended the system’s top five universities, which was significant because, on the committee’s recommendation, the regents adopted a policy that forbade such students from attending public colleges that in the past two academic years had not admitted all academically qualified U.S. citizens who applied. That meant the state’s top five public universities: the University of Georgia, Georgia Tech, Georgia State University, Augusta University, and Georgia College and State University. In 2016, Augusta University and Georgia State were dropped from the list because of declining enrollment.
In 2011, Alabama’s House of Representatives passed House Bill 56, or the Beason-Hammon Alabama Taxpayer and Citizen Protection Act, which later became known as one of the strictest immigration bills ever to become law. It imposed restrictions on immigrants’ access to housing, employment, and public benefits, and it raised concerns that it would subject Alabamians, both U.S citizens and immigrants, to racial profiling, unlawful interrogations, searches, seizures, and arrests. Dozens of civil-rights groups filed a federal lawsuit against the measure, which eventually led to concessions. But its higher-education provisions weren’t challenged and remain in effect.
One of the bill’s Republican sponsors, State Representative Hammon, summed up the purpose of the bill by telling legislators that it “attacks every aspect of an illegal alien’s life.” In 2018, Hammon had to resign and serve three months in prison for misusing campaign funds. The Chronicle couldn’t reach him for comment.
At the federal level, President Barack Obama announced the DACA program in 2012. The program allowed undocumented students who arrived in the United States before age 16 to get Social Security numbers, work authorization, and driver’s licenses, all of which made it more possible for them to attend and afford college.
Alabama and South Carolina started to accept some DACA students, who pay out-of-state tuition. The reason they could enroll despite the bans came down to a technical distinction: While the students don’t have the “legal status” they would otherwise need, their classification under DACA meant they had a “lawful presence,” which allowed them to enroll.
A Trump-administration memorandum sought to terminate DACA, which led to lawsuits and a hearing before the U.S. Supreme Court, which ruled that the administration had acted in an “arbitrary and capricious manner,” and blocked the memorandum. But the court did not rule on DACA’s future.
Other litigation hobbled DACA. In 2022, the U.S. Court of Appeals for the Fifth Circuit agreed with a Texas district court, and DACA was ruled unlawful. A final decision on the constitutionality of the DACA program is expected by April.
Despite the continung litigation, current DACA recipients are able to maintain their work authorization and other benefits. But new applicants, those who turned 16 recently, are not.
The existence of DACA lulled many colleges into complacency, and undocumented students today have fewer protections than they once did. “Most campuses have stopped saying ‘undocumented students.’ They say ‘DACA students’,” says Roberto G. Gonzales, a professor of sociology and education at the University of Pennsylvania. “Student-services professionals, who have been trained during the time of DACA, now are left kind of flat-footed responding to growing numbers of undocumented students who are not covered by DACA.”
“If you are a teenager today without access to DACA and you live in an exclusionary state,” says Gonzales, referring to the three states with enrollment bans, “there are very steep barriers now to navigate in order to attend higher education.”
TJ Rumler, a school social worker in Greenville County, S.C., who has worked with many undocumented high-school students, recalls a young woman he worked with, a senior who had a 4.3 weighted grade-point average, and was in the running for class valedictorian. “Just a star student,” Rumler says. Around graduation, he asked about her plans. “I don’t know,” he remembers her telling him, “because I want to either be a teacher or a nurse. But even if I went to school, I can’t get licensed to do that in South Carolina.”
Rumler’s student was referring to another ban: Undocumented people in South Carolina are not allowed to earn professional licenses. Even those who attend private or out-of-state colleges aren’t able to pursue certain professions in the state.
“I saw almost a complete lack of hope,” Rumler says. “This girl had done everything right. Everything we tell a high-school kid to do. But she didn’t have the choices afforded to her that a lot of other kids did.”
What did she end up doing after high school? “She’s still in town,” Rumler says, “waiting tables at restaurants.”
Rumler later worked with the student’s younger sister. She had seen how her sister excelled but was still unable to go to college. “So,” she said, “‘why should I try?’” Rumler remembers her telling him. “And while I’m not saying that’s a healthy attitude to have,” he says, “there’s a level of me that gets it.”
For many undocumented students, educational success hinges on the adults with whom they happen to come into contact, says Benjamin J. Roth, an associate professor in the University of South Carolina’s College of Social Work. His research on how undocumented students get support for educational attainment found that teachers and other school personnel profoundly shaped how well they made the transition to college.
“Many of the youth that we talked to who grew up undocumented in South Carolina found their way because a coach took them under their wing, or because one teacher was someone that they trusted,” Roth says. But he also found that many undocumented students with enormous talent struggle to seek support because they are often unsure whether they can trust those in positions of authority with their immigration status.
And when undocumented students seek support, school personnel are often unaware of the particular nature of the challenges they face. “For the most part, this is not something that teachers get trained on,” Roth says. “The ban continues to catch people by surprise.”
For Diana Pliego, who grew up undocumented in South Carolina, a guidance counselor made a big difference.
As a student, Pliego hid her immigration status from classmates. When the conversation turned to college planning, Pliego made excuses about why she wasn’t applying to college despite taking honors and AP classes. “People knew that I was smart. It was very much expected that I would go to college,” she says. “So, it was really hard to keep making excuses, but I always just fell back on, like, ‘I just can’t afford it.’”
Her guidance counselor pressured her not to give up on college, telling Pliego that she’d automatically qualify for scholarships based on her grades alone. When Pliego broke down and told her counselor about her immigration status, “she was actually really wonderful,” Pliego says. “She picked up the phone and called local schools and tried to figure out how to best help me.”
Pliego applied to many private institutions in South Carolina and in neighboring states, but she was still afraid of not receiving enough scholarship money. “My family at the time was so low-income. I mean, we were on free lunch my whole childhood,” Pliego says. “We were barely making ends meet as it was, with both my parents working. I just didn’t see how I was gonna go to college.”
Taking the SAT and the ACT added another layer of stress, as she tried repeatedly to get the score she thought was necessary to get scholarships. When she practiced at home, all went well. But when test time came, so did the nerves. “I had so much anxiety, feeling like my entire future was riding on this one test,” she says. “Then I would get just below what I needed.”
“It was a very hard thing to carry, emotionally and mentally,” she says. “At one point I wanted to just drop out.” Pliego started considering alternatives to college. She looked up how to get a cosmetology license, but realized that wouldn’t be much easier. “I found out that to be able to get your license, you would need to put your Social Security number in the application,” she says. “I didn’t have one.”
The only reason Pliego kept going was her father, who pushed her to persist. “He was like, ‘If immigration reform passes tomorrow, are you going to be ready? Are you going to be ready to take the opportunity?’ And so that’s what kept me going, and thankfully, he was right.”
Immigration reform didn’t pass, but DACA was announced by Obama in 2012. Pliego became a DACA recipient, which allowed her to work legally and financially support her education.
She was accepted at Columbia College, in South Carolina, where she received a full-tuition scholarship. To afford room and board her first semester, Pliego relied nonadditional scholarships and, in her second semester, asked the church's pastor to co-sign for a small loan.
At Columbia, she found a home and a purpose. Pliego became an activist in student organizations and wanted to work toward changing public policy. She designed her own major, in community and policy advocacy. “I was able to focus on something that was meaningful to me,” she says, “It opened so many doors.”
Pliego interned for a South Carolina immigration law office and a South Carolina nonprofit focused on supporting immigrant youth. After graduation, she moved to Washington, D.C., where she started her professional career in the nonprofit sector. Today, she works as a policy associate at the National Immigration Law Center, where she researches, analyzes, and tracks public policy.
She has no plans to return to her home state.
Politicians who supported the bans said the goal of such legislation was to prevent undocumented students from taking opportunities from American citizens. That doesn’t appear to be what’s happened. Most of the existing research on the subject has focused on the effects of offering in-state tuition to undocumented students. Findings suggest that doing so doesn’t adversely affect the educational outcomes of U.S. citizens. When in-state tuition is made available to undocumented students, their enrollment increases, which generates net tuition revenue. And, as the authors of a 2012 paper observe, “We find no evidence that policy reduces enrollment rates of other groups.”
Conversely, in states where undocumented students are prohibited from paying in-state tuition, research suggests that their enrollment decreased by 8.4 percentage points the year the policy became law, and by 12.6 percentage points the following year.
No similar studies have examined the impact of outright bans. A 2015 policy report by the Georgia Budget & Policy Institute argues that creating barriers to higher education for undocumented students undermines the state’s goals for educational attainment and work-force development, and fails to capitalize on Georgia’s investments in its public-school system because it prevents graduates who are undocumented from continuing their education in the state.
When enrollment bans reject undocumented students, states like South Carolina, Alabama, and Georgia miss out on expanding their college-educated work force, and therefore, their tax revenue.
College graduates have higher earning power and pay more in federal and state taxes. The Center for American Progress analyzed the earning power of Dreamers, whom they defined as those who came to the U.S. as young children and hold DACA or Temporary Protected Status, or TPS. Their analysis found that dreamers in South Carolina hold over $367 million in spending power, while those in Alabama have over $285 million, and those in Georgia over $1.8 billion. Nationally, the numbers are even greater.
And yet, the diminishment of undocumented students’ economic power and earning prospects is small relative to the big picture. Undocumented students make up a tiny share of the nation’s college-going population — 2 percent of all students in higher education in the United States, the majority of whom don’t come from states with enrollment bans. So, while all three states with enrollment bans have faced decreases in higher-education enrollment rates in the past decade, changing these laws will most likely do very little to help stem the downward trend.
The future may look different, though. Historically, most undocumented immigrants have been older than traditional-age college students. But in recent years the number of minors crossing the border has been growing significantly, which could mean that the undocumented college-going population will soon be increasing.
Nonprofit organizations have stepped in to fill the gaps in policy and support undocumented students from the three states with bans.
One of them is the Alabama Coalition for Immigrant Justice, which advocates for immigration reform and encourages civic participation in the state. Celsa Allende Stallworth, an organizer there, holds “college-access nights” three or four times every year, during which she provides resources for those interested in attending college. A big part of the process, she says, is to make sure the students don’t lose hope before finishing high school.
“Some of them, unfortunately, quit because they feel hopeless. Some are undocumented minors who don’t have their parents here. And then we get into underage working. Why? Because these kids don’t see any other option,” Allende Stallworth says. “All we can do is try to inspire them. We’re looking for resources and trying to help as much as we can, but we’re basically putting bandages on a wound that’s much bigger.”
Steven, the student who once hoped to go to Clemson, is part of the Student DREAMers Alliance, a program that offers leadership seminars to Hispanic youth. Created by the Hispanic Alliance, a South Carolina nonprofit group, the program has helped dozens of undocumented students who are still in high school figure out their next steps.
Some students have been able to attend private and out-of-state colleges through a scholarship program called TheDream.US. It offers funding for undocumented students, and it has a program for those coming from states like South Carolina, Alabama, and Georgia, which the organization calls “locked out” states because they either have enrollment bans or, in places like Arkansas and Ohio, strictly prevent undocumented students from pursuing any kind of financial aid.
Meanwhile, in Georgia, a different kind of nonprofit was founded in response to the enrollment ban. In addition to providing college-preparation classes and college-application assistance to undocumented students, Freedom University was created to be a “modern-day freedom school.” Students take human-rights courses with volunteer college professors and are encouraged to participate in direct action to push for policy change.
Despite the challenges and no clear path for policy change, advocates in all three states say they will continue supporting undocumented students in any way that they can as long as undocumented students continue to attend and graduate from high school in the three states.
There will be more students like Steven. Recently, he was accepted into Spartanburg Methodist College, a small liberal-arts institution in his home state. The private college offered him a partial scholarship, and he’s trying to figure out whether he’ll be able to afford the remaining amount.
Learning about his acceptance, he says, was “something like never before. I was just shocked because it’s really something big.” The oldest of four children, Steven dreams of playing soccer in college while studying business. If he decides to enroll, he’ll be the first in his family to attend and, potentially, graduate from college.
When Steven didn’t hear back from Furman, he decided to check older emails to see if he’d missed anything. He had. Furman wanted an additional form required of those who are not U.S. citizens — an international-student form. “I emailed my counselor asking her about it because I didn’t know I was one,” Steven says.
He isn’t an international student, but his counselor said he is in the eyes of colleges, and she added that she didn’t think Furman would be an option for him because of the cost anyway. “I thought I wouldn’t have been classified as an international student since I live here in Greenville,” Steven says, “It’s just a surprise to me.”
Among many hoops he had to jump over, that technicality — whether he’s classified as an international or domestic student — is not one he expected. He’s not the first high-schooler to miss an important admissions email. But as an undocumented teenager, any misstep makes his options even more limited.
With his Furman application deemed incomplete, Steven is figuring out whether he can afford Spartanburg. Despite the law, bureaucracy, and all the other forces beyond his control, he’s not ready to let go of his college dream.
Brian O’Leary and Audrey Williams June contributed data analysis.