what are footnotes to the below literature reviews?

The lack of resources for immigrant youth in education systems in America is a problem of increasing significance. While there are many resources available to help immigrants adjust to the United States, the majority is not suited for immigrant students who often face language barriers and cultural differences that make it difficult for them to understand the information they need.

With millions of immigrants coming into this country every year, schools are quickly struggling with how to meet their educational needs. While many immigrants have high school education and can speak English, they also often lack the means to handle the high-level education that is now required of students in American schools.

The influx of students often requires that schools hire more teachers or provide translators for other languages. Many districts are already exceeding their budgets and are now looking to tax payers to help support their unique needs. Also, many of the students are not fluent in English and are forced to take English as a Second Language (ESL), which slows down their learning in other subjects.

There is also a general lack of an immigrant-friendly curriculum. Schools have created programs, such as Project ACHIEVE and CATCH, that are meant to help immigrants adjust to their new school. However, there are few programs for immigrants in high school because many districts feel that it is the parents' responsibility to teach their children about their new surroundings. In addition, there is no standard curriculum or program used in all schools to help students adjust and prepare for the demands of high school.

Schools also lack funding to hire ESL teachers and translators to help immigrant students understand what they need to know. This lack of funding will only be exacerbated by the influx of immigrant students that are expected within the next ten years. In many districts, the only source of funding for ESL and other language-related services is the state, which has little to spare.

Immigrants are also expected to adapt to American education within the next ten years. In 2006, President Bush announced plans to implement a three-tiered educational system based on income. Under this system, immigrants would be put in an independent school that would separate them from other students and run an entirely different curriculum for them. Similar to the rest of the country's public schools, students would be expected to master specific subjects that they are incapable of learning at an earlier age.

Although these plans were ultimately defeated, the fact that they were proposed shows the demand for specialized education in America. Currently, there is no standardized way of identifying immigrant issues or creating programs to help them meet their needs.

For decades, immigrants have been used as a political scapegoat for problems that exist in America's educational system. Immigrants are often blamed for the lack of funding in schools and the lack of a meaningful education for students. However, it is not clear that immigrants are any more or less capable of learning than their American counterparts.

As long as immigrant children face language barriers and cultural differences that make it difficult for them to develop a true understanding of what they are being taught in school, it is unlikely that they will be able to perform at the same level as their American counterparts.

However, it is important to note that after studying the effects of large-scale immigration, many researchers have found that immigrants actually do perform better than their counterparts. In fact, many people believe that a large influx of immigrants will boost the economy and increase the productivity of Americans by providing a large labor force.

In addition, it is important to note that immigrants generally do not cause educational problems at schools, but rather will ultimately level the learning curve for all students.

For immigrant youth in the education system, there are gaps in resources. For example, there are a lack of resources for immigrant students to understand their rights, no guarantee that schools will provide these services, and not enough culture tailored programs for immigrant families. These three legal analysis sections will discuss how legal doctrines relevant to school districts play a role in warding off these issues and what can be done about it. The first set of case law discusses the Brown v Board case which has implications for whether discrimination is allowed or not based on citizenship status. The second set of case law is related to the Fairfax County case which asks the question of what will be considered as discriminatory. The final section investigates social justice and examines how schools can work harder and improve their treatment of these students.

The first set of case law has been selected because it discusses the Brown v Board and Board of Ed cases. The cases give insight into schools' rights as they relate to immigration and citizenship status, as well as discrimination against immigrants. In the Brown case, Abigail Fisher appealed to a school board in Texas that decided not to allow her daughter with an F grade in ninth grade even though she was proficient in every subject except math. The Supreme Court ruled 9-0 that the school board was wrong in its decision not to accept her daughter into the high school. Fisher filed a complaint because she believed Brown's rights were violated of being denied access to a public education because she was a citizen of another country, Mexico, when she moved to Texas. The case came down to whether or not it violated her equal protection rights because they were denied access to a public education simply based on their citizenship status and nationality. The justices stated that "Racial classification, however, is subject to scrutiny under the Equal Protection Clause."(Brown v Board) This statement may have implications for immigrant students and their treatment in schools by reserving their rights and protection from discrimination.

The second set of case law is about Fairfax County. In the Fairfax case, Spaht v Fairfax school board, the plaintiff and her daughter were asked to sign a statement promising to behave in order to attend an English class. The plaintiff had submitted homework that stated that her daughter would not make progress if she did not promise to comply with the school rules of remaining quiet in class. In their arguments, the plaintiffs stated that it was discriminatory because non-native English speakers are punished for their language skills and should be held accountable for their actions and behavior. The court ruled 9-0 in favor of the school board stating that it protected the children in the school from discrimination based on nationality and cultural background fears. The decision stated that the school board was correct in its actions because it was attempting to ensure that the students were getting the most out of their education and fully understood the rules of behavior. The Supreme Court stated that "The requirement to sign a statement promising to comply with school rules was not a racially discriminatory requirement..."(Spaht v Fairfax)

The final set of case law investigates social justice and questions what schools can do to work harder at improving immigrant students' treatment in schools. A recent article by Reis and Chang investigated immigrant youth's testing issues in Detroit. In their study, they found that immigrants have a higher rate of English language learners than native born Americans. Due to this, Reis and Chang found that immigrant students were going through the same testing struggles as their native-born counterparts. They even found that immigrant students' scores on standardized tests were generally lower than their native-born counterparts. In response to these findings, Reis and Chang recommended several solutions for improving the quality of education for immigrant youth like changing cultural resources focused on foreign language acquisition and providing both individualized learning plans and culturally based instructional techniques.

Using the Brown v Board case and federal case law with its discussion of equal protection, international relations and immigration, along with examining social justice issues in schools, this analysis will conclude by examining possible solutions towards immigrants being able to fully succeed in school while ensuring they are protected from discrimination.

In terms of the Brown v Board case, it is important to note that there is a disagreement between foreign born and native-born students. While this may seem at first as a problem, it actually shows progress in equal protection laws. In the past, discrimination has been directed towards immigrants while they are here. This time, immigrants are still being discriminated against, but because of how they were born and not on the basis of their immigrant status. As Justice O'Connor puts it "Laws...such as these (that discriminate based on citizenship status) challenge the principle that all persons similarly situated should be treated alike."(Brown v Board) This quote also applies to discrimination based on language and other characteristics rather than citizenship status as well. Moreover, the case is focused on education rather than employment discrimination, yet it is still a step forward in protecting other people's rights.

The second set of case law is about Fairfax County. The evidence shows that as schools work harder to make sure immigrant students are succeeding, they are also making progress in their treatment of these students and not discriminating against them based on their immigration status. In addition, schools cannot discriminate based on their nationality or culture when it comes to serving the needs of the community and providing quality education to all students.

The final set of case law examines social justice issues that play a role in immigrant students' acceptance in school. Reis and Chang analyzed immigrant youth's testing issues in Detroit. The authors found that immigrants have a higher rate of English language learners than native born Americans. This means that immigrant students are at a disadvantage when it comes to understanding English and becoming successful in school, as they will generally perform lower than native speakers. However, this is not the case when it comes to their learning outcomes or how much they understand versus their native-born peers. In fact, Reis and Chang found that immigrant students' scores on standardized tests were generally lower than their native-born counterparts. They wanted to explain exactly why this was the case and found that there was a large difference between the amount of attention that schools were paying to immigrant youth versus their native-born counterparts. This can be seen by looking at the programs that are offered within their schools and how many resources are provided for immigrant students in comparison to their native-born peers. However, when it comes to individualized learning plans, schools do a good job providing these plans for all students, but they also tend to make them more accessible for native speaker students. This is understandable because parents want the same treatment for their children whether they are immigrants or born here.