Controlling Immigration
A Comparative Perspective, Fourth Edition
Edited by James F. Hollifield, Philip L. Martin, Pia M. Orrenius and François Héran


Controlling Immigration: A Comparative Perspective


This book was launched in 1990 at the Center for US-Mexican Studies at the University of California at San Diego (UCSD) as part of a National Science Foundation research project, under the direction of Wayne A. Cornelius, Philip L. Martin, and James F. Hollifield, comparing national efforts to manage migration. National studies of migration data and control systems that grew out of the NSF project were first published in 1994 by Stanford University Press; a second edition of the book appeared in 2004, and a third in 2014. This fourth edition continues the effort to use systematic, cross-national research to examine the gap between the goals and outcomes of immigration policies in major immigrant-receiving countries. A generation of scholars and students has wrestled with this question, which continues to drive research agendas in the multidisciplinary field of migration studies. We hope that the fourth edition will shed new light on the dilemmas of immigration control and help to advance the comparative study of immigration policy.

The fourth edition is divided into five parts, including (1) an introduction that gives an overview of the dilemmas of immigration control, followed by studies of (2) nations of immigrants in which immigration is part of the founding national ideal, (3) countries of immigration where immigration plays an important role in social and economic development but was not part of the process of nation-building, (4) latecomers to immigration—countries that once sent migrants abroad but in the past few decades made the transition from sending to receiving societies—including a new chapter on Greece and Turkey, and (5) the European Union and regional migration governance. Each country study is followed by one or more commentaries by scholars and policymakers who offer a critique and, in some cases, an alternative interpretation of policy developments.

Our work has benefited from the input of migration scholars and students from around the globe. The workshop for the second edition was hosted by the Center for Comparative Immigration Studies at UCSD. The third conference was organized by the John Goodwin Tower Center for Political Studies at Southern Methodist University (SMU) in conjunction with the Federal Reserve Bank of Dallas. The fourth conference, the basis for this edition, was again organized by the Tower Center at SMU, co-sponsored by the Institut Convergences Migrations, and hosted by the Collège de France. We are grateful to all who participated in this conference and to the staff of the Tower Center and the Collège de France for their invaluable administrative support. The project was underwritten by the Marian Tower International Conference Fund of the Tower Center at SMU, by grants from the Institut Convergences Migrations, and by the Collège de France. The editors and contributing authors are solely responsible for the information and views presented in this book, which do not necessarily represent those of the underwriters.

Special thanks go to Nicole Rafidi, assistant to the Director of the Tower Center, for her tireless work on the project, and to Alan Harvey, Director of Stanford University Press, and his colleagues. Without their extraordinary patience, skill, and support, the fourth edition might never have seen the light of day. To them we are deeply grateful.

James F. Hollifield, Philip L. Martin,

Pia M. Orrenius, and François Héran,

January 2022

Chapter 1

The Dilemmas of Immigration Control in Liberal Democracies

James F. Hollifield, Philip L. Martin, Pia M. Orrenius, and François Héran

All countries face the challenge of controlling migration. The dilemmas of control are especially acute in liberal democracies. Economic pressures encourage governments to be open to migration, while political, legal, and security concerns argue for closure and control—a liberal paradox (Hollifield 1992). How can countries be simultaneously open to immigration for economic and demographic reasons and closed to immigration to protect sovereignty, ensure security, and enhance the social contract?

This book explores the liberal paradox by comparing immigration trends and policies of major OECD countries. Two leitmotifs are convergence and gaps. The convergence hypothesis argues that governments that face similar problems adopt similar solutions, including (1) the policy instruments they choose to control immigration and (2) integration and naturalization policies that generate similar public reactions. The gap hypothesis argues that the gap between the goals or outputs of immigration policy (laws, regulations, executive actions, and court rulings) and the results or outcomes of those policies in terms of unauthorized and unwanted migration is growing wider, contributing to public hostility toward immigrants (regardless of their legal status) and putting pressure on political leaders and governments to adopt more restrictive policies (Hollifield 1986; cf. Czaika and De Haas 2013 and Ellermann 2021).

Beyond testing these two hypotheses against the evidence gathered in the countries and regions represented in the book, we seek to explain the efficacy of immigration control measures in an era of globalization that rivals that of the eighteenth and nineteenth centuries. In each of the country and regional profiles, the authors explain the evolution of immigration and immigrant policy and why some policies succeeded in achieving their objectives while others failed. Each country chapter is followed by commentaries that critique the author’s principal findings, supplementing them and, in some cases, offering an alternative interpretation.

International migration and mobility have been steadily increasing in the post–World War II era. According to UN data, in 2020 approximately 281 million people—3.6 percent of the world’s 7.8 billion people—resided outside of their country of birth for one year or more.1 Until the global pandemic of 2020, tens of millions of people crossed borders on a daily basis, which added up to roughly 3 billion border crossings per year. Human mobility was part of a broader trend of globalization, which includes more trade in goods and services, increased capital flows, greater ease of travel, and a veritable explosion of readily accessible information.

Migration is a defining feature of the contemporary world (De Haas, Miller, and Castles 2020). It is connected to trade and investment (Peters 2017), but it is also profoundly different. People are not shirts, which is another way of saying that labor is not a pure commodity. Unlike goods and capital, individuals can become actors on the international stage (they have agency), whether through peaceful transnational communities or through violent terrorist/criminal networks. In the rare instances when migrants commit terrorist acts, migration and mobility can be a threat to the security of states.

Many studies highlight the economic benefits of immigration (for example, Orrenius and Zavodny 2010; Martin 2022), such as new sources of human capital and workers, more entrepreneurial activity, more innovation, fewer labor market bottlenecks, and lower levels of inflation in periods of high growth. However, these benefits of migration come with some costs, including the short-term fiscal burdens of concentrated low-wage immigrant populations in certain regions and localities, the longterm challenges of social and economic integration, and, in an age of drug cartels and domestic and international terrorism, security costs—not to mention concerns for public health in times of pandemic. Liberal states also must contend with the issue of the rights (legal status) of migrants, including legalization, naturalization, and citizenship, or risk undermining the social contract. Hence economic needs for openness are pitted against political and legal pressures for closure—the liberal paradox. In liberal democracies, immigrants are typically granted a basic package of (human and civil) rights that enables them to remain, settle, become productive members of society, and (depending on the country) become naturalized citizens. Conversely, they may return to their countries of origin and affect economic and political development there. Migration has important costs (brain drain) and benefits (remittances and brain gain) for less-developed countries in the Southern Hemisphere (Hollifield, Orrenius, and Osang 2006; Hollifield and Foley 2021; Martin 2022).

Of course, not all migration is voluntary—in any given year, tens of millions of people move to escape wars, political violence, hunger, deprivation, and the vagaries of climate change, becoming refugees, asylum seekers, or internally displaced persons. At the end of 2020, the United Nations High Commissioner for Refugees (UNHCR) estimated the number of “persons of concern” at 82.4 million (1 percent of the world’s population), including 26.4 million refugees, 4.1 million asylum seekers, 48 million internally displaced people, and a relatively new category, 5.4 million Venezuelans forced to flee their country, a number that continues to rise (Hollifield 2021b; Hazán 2021). Wars in the Middle East (especially Syria and Iraq), East Africa, and West Africa and instability in South Asia (Afghanistan and Pakistan), Central America (the Northern Triangle), South America (Venezuela), and Europe (Ukraine) continue to feed a growing population of forced migrants. Two weeks after the Russian invasion of Ukraine, which occurred on February 23, 2022, more than two million people fled to escape the bombing. At the onset of the war, Ukraine had 44 million inhabitants, twice as many as Syria. If a quarter of the population were to leave Ukraine—a plausible estimate—this would be more than ten million exiles. According to UNHCR, 80 percent of the world’s exiles come from just nine countries, each responsible for the flight of at least half a million people. These are, in order of importance, Syria, Venezuela, Ukraine, Afghanistan, South Sudan, Myanmar, Somalia, the Democratic Republic of Congo, and Eritrea. The countries of the European Union, Germany in particular, struggle to cope with waves of forced migration—almost 1 million asylum seekers arrived in Germany in 2015 alone. In 2018–2019 and again in 2021, tens of thousands of Central Americans fled the Northern Triangle countries (El Salvador, Guatemala, and Honduras), most heading north through Mexico to seek asylum in the United States.

Because it is so complex and multifaceted, migration of all types poses a challenge for individual states, for regions such as the European Union (EU) and North America, and for the international community. Eighty-six percent of forced migrants, almost 70 million people, are hosted in countries in the Southern Hemisphere, where the ability of many states to host asylum seekers and refugees is limited. Forced displacement feeds the narrative of a global migration crisis that is destabilizing countries and entire regions (Weiner 1995; cf. Hollifield and Foley 2021). Certainly, understanding the dynamics of forced migration, displacement, and development in the global South is essential for explaining the dilemmas of immigration control in the global North.

Until the election of Donald Trump in the United States in 2016 and the global pandemic of 2020, international migration was generally on the rise. Despite the 9/11 terrorist attack on the United States and the great recession of 2007–2009, followed by the sovereign debt crisis in Europe, liberal democracies remained relatively open to immigration—the United States was admitting over 1 million immigrants annually until 2019, and in 2015 roughly 2.4 million people arrived in the EU from non-EU countries. The pandemic of 2020 led to new restrictions on human mobility, a sharp drop in border crossings, and a general decline in immigration. Legal permanent US immigration dropped by 30 percent between FY 2019 and FY 2020, from 1,031,765 to 707,362. Other forms of immigration to the United States had started falling several years prior due to Trump administration policies regarding Muslim immigrants, foreign students, and asylum seekers (Martin and Orrenius in this volume).

Global economic inequality and demographic differences mean that supply/push forces remain strong while demand/pull forces persist (Martin 2022). During the pandemic, exceptions were made for “essential workers” to continue to enter and work in many OECD countries. Growing demand for low-skilled workers and competition for the highly skilled, coupled with stable or shrinking workforces, have created more economic opportunities for migrant workers. Transnational networks (family and kinship ties) are as dense and efficient as ever, linking sending and receiving societies. Networks help to reduce risk and lower the transaction costs of migration, making it easier for people to cross borders and stay abroad. Moreover, when legal migration is not an option, migrants (especially asylum seekers) have turned to professional smugglers, and a global industry of smuggling has flourished, at times with dire consequences for migrants. In 2016, more than 5,000 migrants perished at sea while trying to enter the EU to seek asylum.

The Unwieldy Politics of Immigration Control

Migration, like any type of transnational activity, does not take place in a legal or institutional void. Governments are deeply involved in organizing and regulating migration (Waldinger and Fitzgerald 2004). The accrual of rights for non-nationals has been an extremely important part of the story of immigration control. For the most part, rights that accrue to migrants come from the legal and constitutional protections guaranteed to all members of a society (Joppke 2001). Thus, if an individual migrant is able to establish some claim to residence on the territory of a liberal state, his or her chances of being able to remain and settle will increase. Deportation or repatriation typically is difficult (Ellermann 2009; Wong 2015). At the same time, developments in international human rights law have helped to solidify the position of the individual vis-à-vis the nation-state, to the point that individuals (and certain groups) have acquired a type of international legal personality (Soysal 1994; Jacobson 1996). Once extended, rights have a very long half-life, and it is hard to roll them back. Regulating international migration requires liberal states to be attentive to the (human or civil) rights of the individual—if rights are ignored, the liberal state risks undermining its own legitimacy and raison d’être.

Four factors undergird immigration policymaking: security, cultural and ideational concerns, economic interests, and rights. National security (the institutions of sovereignty and border control), economics (markets), and rights are all part of a multidimensional game in migration policymaking. In normal times, the debate about immigration revolves around two poles: markets (numbers) and rights (status), or how many immigrants to admit, with what skills, and with what status. Should migrants be temporary (guest) workers or allowed to settle, bring their families, and get on a path to citizenship? Is there a trade-off between rights and numbers, as Martin Ruhs and others (Ruhs 2013; Ruhs and Martin 2008) suggest? These are all good questions. But cultural concerns—which regions of the globe immigrants should come from, which ethnic characteristics they should have, and issues of integration—are often politically more salient than markets and rights, and the trade-offs are more intense in some periods and in some countries than in others.

With the September 11, 2001, terrorist attacks in the United States followed by a series of bloody attacks in Europe in the 2000s and 2010s, policymaking regarding immigration and refugees shifted to a national security dynamic (with fear of Islam a deep cultural subtext) and the concern that liberal migration policies pose a threat to the nation and to civil society (Adamson 2006; Lucassen 2005). In times of war and pandemics, the dynamic of markets and rights gives way to a dynamic of culture, security, and public health, and finding equilibrium (compromise) in the policy game is even more complicated and the liberal paradox more acute. Yet as we can see with the conflict in Ukraine, the national security imperative cuts both ways when states suddenly are confronted with a humanitarian emergency and compelled to open their borders for geopolitical reasons. Making these trade-offs in times of great uncertainty is the policy dilemma facing governments in every immigration country.

The four-sided game (see Figure 1.1) is difficult at the national, state, and local levels, and it is made more complex because migration control has important foreign policy implications. The movement of people affects international relations and security in myriad ways (Adamson 2006; Hollifield 2012; Adamson and Tsourapas 2018). Hence, political leaders are always engaged in a two- or even three-level game (Putnam 1988), seeking to build local and domestic coalitions to maximize support for immigration policy but with an eye on the foreign policy consequences. It is virtually impossible for a state to manage international migration unilaterally, simply by sealing or closing its border—North Korea and other totalitarian states in autarky are a partial exception.

The country studies in this book highlight the administrative, political, legal, and economic difficulties of immigration enforcement in relatively open, liberal, and pluralistic societies. Executive and bureaucratic power in these countries is open to contestation by a variety of social and economic groups, and reducing the demand/pull factors that attract migrants is extremely difficult. Competing interests in liberal societies often lead to policymaking gridlock that, in the face of strong economic incentives, permits immigration to continue in one form or another (Freeman 1995; Martin 2022). Such policy paralysis sends mixed signals to prospective emigrants, incentivizing them to overcome obstacles placed in their path at borders (walls, fences, and other external controls) or in the workplace (internal controls). Amnesties for unauthorized migrants create a potential moral hazard, encouraging more irregular migration while fueling the smuggling trade and enlarging illicit economies and black markets. As levels of irregular migration increase along with asylum seeking, public opinion may shift in a xenophobic and nativist direction, spurred on by radical right-wing politicians, and immigration and refugee policies become more populist and symbolic, detached from the reality of migrant flows and stocks (Norris and Inglehart 2019; Joppke 2021; see also various chapters in this volume).

FIGURE 1.1. The Dilemmas of Migration Governance

Immigration countries cannot in the short term hope to reduce supply/push pressures in the sending societies—rapid population growth combines with low rates of economic growth to contribute to depressed wages and underemployment in those countries, especially among the young. Past migration, often driven by colonial ties, has created links between sending and receiving areas that are hard to break for cultural, legal, and humanitarian reasons. This is especially true in Europe, where many countries have deep historical ties with sending countries that were former colonies (Kastoryano 1997; Bosma, Lucassen, and Oostendie 2012; Lucassen 2021). Demand/pull and supply/push forces and networks that link sending and receiving societies are the necessary conditions for emigration to occur, but granting legal status (rights) to foreigners is the sufficient condition for immigration. Migrant rights most often derive from domestic sources of law, especially constitutions, but increasingly they are protected by international law and human rights conventions, particularly in Europe (Joppke 2001; Geddes and Hadj-Abdou in this volume). Despite the rise of rights-based politics (Hollifield 1992; Hollifield and Wilson 2012; also discussed later in this introduction) and regimes, which inhibit the action of states trying to control migration, policies increasingly seek to control immigration by targeting migrants’ civil, social, and political rights (Hollifield 2021a).

Legal and constitutional constraints notwithstanding, fixing immigration control systems that are buckling under the pressure of new waves of asylum seekers and economic migrants has become a political imperative in most of the countries included in this volume. The principal exceptions are Japan and South Korea, where the numbers of immigrants are growing but remain relatively small, and Canada, Australia, and New Zealand, where public hostility to immigration remains relatively low. The Great Recession of 2007–2009 led to a decline of flows, especially to the United States, where despite the moderation in the pace of immigration, the politics of immigration shifted more toward control (enforcement) and away from concerns about the integration of a large immigrant population, many of whom are undocumented (Hollifield 2010; Passel, Cohn, and Gonzalez-Barrera 2012). Meanwhile, integration dilemmas are acute in Canada, Australia, and New Zealand—nations of immigrants—where sources of immigration have become much more diverse (Favell 1998; Bloemraad 2006; Schain 2012; Reitz in this volume; Gamlen and Sherrell in this volume). The global pandemic of 2020 has further complicated immigration control policies, adding a security and public health dimension to the politics of migration and mobility.

As a result, immigration is highly contested in the de facto countries of immigration—such as France, Germany, the Netherlands, Switzerland, Britain, and the Scandinavian countries—where immigration is not part of the founding ideal, as in the nations of immigrants. Publics in numerous countries are uneasy about the long-term implications of immigration for the maintenance of national cultures, languages, and identities (see Figure 1.1), and public opinion often is hostile to immigration and asylum seeking (cf. Geddes 2021; Geddes and Hadj-Abdou in this volume). Debates over Muslim immigration in largely Christian societies have been especially vociferous and divisive in Europe (Kastoryano 1997; Kepel 2012; Norris and Inglehart 2019; various chapters in this volume). Even when foreign workers and their dependents are legal residents—there are millions of settled, legally admitted foreign workers, family members, and free movers in European countries (nationals of most EU member states have the right to move within the EU to search for employment, although free movement for some of the newer member states required a waiting period after accession)—they are often unwanted as a permanent component of the population for non-economic reasons, including low tolerance for cultural, racial, and ethnic diversity; fear of crime and terrorism; and overcrowding in major urban areas (Money 1999; Fetzer 2000; Sides and Citrin 2007; Brader, Valentino, and Suhay 2008; Hopkins 2010).

Public hostility generates strong incentives for officials in liberal democracies to redouble their efforts at immigration control by fine-tuning existing control measures such as employer sanctions (internal control), investing more heavily in border enforcement (external control), and pursuing new experiments to restore at least the appearance of control (such as so-called immigrant trainee programs in Japan and South Korea; see Chung in this volume). For this reason, the politics of immigration in many receiving countries has a strong symbolic dimension (Rudolph 2006; Hollifield 2021a), and wide gaps exist between policy outputs and outcomes and between public opinion—which in most countries wants immigration reduced—and liberal admissions policies (Hollifield 1986; Freeman 1995; Sides and Citrin 2007; cf. Czaika and De Haas 2013; Lutz 2019). Nativist and xenophobic reactions against immigration reached a fever pitch in the United Kingdom in 2016, when Britain voted to leave the European Union (Brexit), and in the United States in the same year with the election of Donald Trump to the presidency.

Immigration is a central issue of politics and public policy in the liberal democracies (Messina 2007; Schain 2012; Norris and Inglehart 2019). Especially in Europe, immigration is a driving factor in electoral politics (Givens 2005; Eatwell and Goodwin 2018; Joppke 2021), and it is a potent electoral issue in the United States (see Wong 2016; Tichenor 2021; Martin and Orrenius in this volume). In the early decades of the postwar era many countries had guest worker policies that sought to rotate foreigners into and out of the labor force (for example, the braceros in the United States during the 1940s and 1950s and Gastarbeiter in Germany in the 1960s and 1970s), but many of the “guests” stayed—some, in the United States in particular, without authorization. These nations were confronted with the challenge of assimilating large numbers of culturally different migrants and their descendants, many in the second and third generations. In Japan and South Korea, the influx of foreign workers eagerly sought by labor-hungry, small and medium-sized employers into racially and culturally homogeneous societies with a large and growing demographic deficit is a contentious issue of national policy (see Chung 2010, 2020, and her chapter in this volume; cf. Hollifield and Sharpe 2017). In the United States, the fourth wave of largely Hispanic and Asian immigrants provoked a nativist backlash with the election of Donald Trump (Ramakrishnan 2005; Hollifield 2010 2021; McCann and Jones-Correa 2020; Joppke 2021).


1. The average number of international migrants is low in part because of seven “demographic giants” (China, India, Pakistan, Indonesia, Brazil, Nigeria, and the United States), which together have 52 percent of the world population but account for very few emigrants, since in many of them internal migration replaces emigration. The rest of the planet has 223 million emigrants out of 3.7 billion inhabitants, a rate of 6.1 percent. Moreover, these emigrants tend to concentrate in rich countries: the migrant stock makes up 12.8 percent of the total population in high-income countries (11.9 percent in the euro zone, 14.9 percent in North America [the United States and Canada]).