U.S. Civil Rights Commissioner Peter Kirsanow urged President Barack Obama not to grant temporary amnesty and work permits to millions more illegal immigrants via executive action, asserting Obama’s timing could not be any worse for American workers, especially black Americans.

In a Tuesday letter to Obama, Kirsanow emphasized “the disastrous effect of illegal immigration on the employment of all Americans, but particularly black Americans.” He also said that the “proposed executive order is unfair to people who are attempting to immigrate legally.”

“Any grant of legal status will serve as a magnet to prospective illegal immigrants and further depress employment opportunities and wages for African-Americans,” he wrote. “Given that the labor force participation rate is at an historic low, the unemployment rate is 6.2 percent, and there has been a precipitous decline in household wealth, the timing for such a grant of legal status could not be worse.”

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He noted that nearly half of Black and three-fourths of illegal immigrant Hispanic males do not have an education beyond high school and, as a result, “illegal immigration has a disparate impact on African-American men” who would directly compete with illegal immigrant Hispanic males for scarce jobs.

“Granting legal status to millions of people who are in the United States illegally will continue to depress the wages and employment opportunities of African-American men and teenagers,” he wrote. “It also will depress the wages and employment opportunities of African-Americas [sic] going forward.”

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Since “disparate impact theory holds that a facially neutral policy can nonetheless constitute unlawful discrimination if it disproportionately affects a particular group,” Kirsanow wrote that Obama’s “proposed executive order will do just that.”

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