Minnesota Asylum Attorney

Minnesota, a state known for its commitment to diversity and inclusivity, plays a pivotal role in the nation’s immigration landscape, especially concerning asylum seekers. Asylum law in the United States provides critical protection for individuals who have fled their home countries due to persecution or the well-founded fear of persecution based on specific protected grounds. This guide offers an in-depth exploration of asylum law as it pertains to Minnesota, designed to aid business owners and attorneys, especially those new to this area of law, in understanding the complexities of asylum applications, the legal processes involved, and the implications of asylum in a business setting.

Minnesota’s business community, especially in urban centers like Minneapolis and Saint Paul, is increasingly engaged with immigrants, many of whom are seeking asylum or already have asylum status. For business owners, understanding asylum law is not only a social responsibility but can also enhance the workplace by creating an inclusive environment that respects the diverse experiences and backgrounds of their employees. This guide aims to provide a comprehensive roadmap for navigating the intricacies of asylum law in Minnesota, from initial application processes to post-asylum considerations for both employers and legal professionals.

This resource is structured to guide the reader through key aspects of asylum law, from foundational definitions and legal requirements to practical considerations for businesses employing asylees. It covers the legal definitions, processes, and challenges within the U.S. asylum system, specific considerations in Minnesota, common misconceptions, and the strategic elements crucial for successful asylum applications. With a detailed examination of each topic, this guide serves as a foundational resource for understanding and supporting asylees within Minnesota’s legal and business communities.

Understanding Asylum

Legal Definition of Asylum

Asylum is a form of international protection granted to individuals who cannot return to their home countries due to a well-founded fear of persecution. The United States has enshrined asylum as a legal right for individuals already within its borders or at one of its ports of entry. This protection is based on specific, protected grounds: race, religion, nationality, political opinion, or membership in a particular social group. An individual who successfully obtains asylum becomes known as an “asylee” and is legally permitted to remain in the U.S. under this protected status.

The principle of asylum is grounded in both U.S. and international law, with the U.S. drawing on the Refugee Act of 1980, which aligns with the 1951 United Nations Convention Relating to the Status of Refugees. By definition, asylum is distinct from refugee status, which is granted to individuals who are outside their country and have already been recognized by an international body or another country as a refugee before entering the U.S. In contrast, asylum seekers come directly to the U.S. and apply for protection here, often at substantial personal risk. The legal framework and procedural requirements for asylum are rigorous and complex, aimed at ensuring that only individuals who genuinely fear persecution receive protection.

Refugee vs. Asylee

The terms “refugee” and “asylee” are often used interchangeably but have distinct legal definitions under U.S. immigration law. A refugee is someone who has been granted protection while still outside the U.S., typically through a formal referral by the United Nations High Commissioner for Refugees (UNHCR) or a similar organization, and has been vetted abroad before their entry. Refugee status allows individuals to enter the U.S. legally under the protection of refugee programs, with support and resettlement assistance managed by non-profit organizations.

An asylee, on the other hand, is an individual who is either already in the U.S. or at a U.S. port of entry and seeks protection from persecution upon arrival. Asylees apply for protection through either an affirmative process (when they apply directly to the U.S. Citizenship and Immigration Services) or a defensive process (when they are in removal proceedings and claim asylum as a defense). Both refugees and asylees are eligible to apply for a Green Card (permanent residency) one year after obtaining their respective statuses, but the application paths and requirements differ significantly due to the nature of their entry and protection requests.

Protected Grounds for Asylum

To qualify for asylum, an applicant must demonstrate that they have been or fear future persecution based on one of five legally recognized grounds: race, religion, nationality, political opinion, or membership in a particular social group (PSG). These protected grounds are critical to asylum eligibility and are interpreted strictly within the context of U.S. immigration law.

Persecution based on race encompasses discrimination or harm inflicted due to the individual’s ethnic background, cultural identity, or physical characteristics. Religion-based persecution includes any form of discrimination or harm for one’s religious beliefs or practices. Nationality-related persecution often involves discrimination or mistreatment due to the individual’s citizenship or ethnic origins associated with a particular nation or region. Political opinion covers harm due to the individual’s expressed or perceived political beliefs, whether vocal or implied.

“Membership in a particular social group” (PSG) is arguably the most complex and contentious ground. It requires the applicant to demonstrate they belong to a group that shares common, immutable characteristics that cannot be changed or that the individual should not be required to change, such as gender, sexual orientation, or family ties. Each protected ground carries specific evidentiary and legal requirements, making asylum a challenging and highly individualized process. Legal practitioners must carefully assess which grounds apply to a client’s situation and develop a well-supported argument for each case.

The Asylum Application Process

Affirmative Asylum Process

The affirmative asylum process is for individuals who are not in removal proceedings. Applicants file for asylum by submitting Form I-589, Application for Asylum and for Withholding of Removal, to the U.S. Citizenship and Immigration Services (USCIS) within one year of their most recent arrival in the U.S. Filing within this one-year deadline is critical, as failing to do so can jeopardize eligibility unless specific exceptions apply. Applicants who file affirmatively are typically not in custody and have come forward to USCIS voluntarily to request protection.

Once the application is filed, the applicant will undergo a biometric screening, and an asylum officer will review the case during a non-adversarial interview. The asylum officer will evaluate the applicant’s fear of persecution and determine if it meets the legal criteria. If the officer finds the case compelling, asylum will be granted. If the application is denied, however, and the applicant does not have lawful immigration status, their case is referred to immigration court, where they may pursue a defensive asylum claim.

The affirmative process emphasizes thorough documentation and preparation, as the interview with the asylum officer is the applicant’s primary opportunity to present their story. Unlike immigration court proceedings, this interview is relatively informal but still requires detailed evidence and a well-prepared narrative. It is essential that the applicant’s story be consistent, supported by corroborating evidence whenever possible, and clearly tied to one of the protected grounds of persecution.

Defensive Asylum Process

The defensive asylum process comes into play when an individual is in removal proceedings, typically after being apprehended by immigration authorities. In this scenario, asylum serves as a defense against deportation. Applicants in removal proceedings will present their case in front of an immigration judge, where they must demonstrate that they meet the criteria for asylum. The defensive asylum process is generally more adversarial than the affirmative process, as government attorneys will argue against granting asylum, and the judge will determine the outcome.

During the court hearing, the applicant has the opportunity to present their case, including evidence, witnesses, and any other corroborating documents. The judge will assess the credibility of the applicant’s testimony, the likelihood of persecution, and whether the fear of returning to their home country is well-founded. If the judge grants asylum, the applicant may remain in the U.S. with asylee status. If denied, the applicant has the right to appeal the decision or seek other forms of relief.

The defensive process can be particularly challenging as it involves a court setting with strict procedural rules, making the role of legal counsel essential. Given the high stakes and the adversarial nature of this process, individuals in defensive asylum proceedings often face significant stress and require thorough preparation to present a compelling case.

One-Year Filing Deadline

Asylum applicants are generally required to file their application within one year of their last arrival in the United States. This one-year deadline is strictly enforced, but exceptions can be made for “changed circumstances” and “extraordinary circumstances.” Changed circumstances might include significant events in the applicant’s home country that have altered their risk of persecution, such as new political instability or heightened government crackdowns on certain groups.

Extraordinary circumstances refer to events or situations that might have prevented the applicant from filing on time, such as severe illness, mental health conditions, or legal barriers. Demonstrating an exception to the one-year rule can be challenging, as it requires substantial evidence to prove the circumstances directly impacted the ability to file within the deadline. Applicants and attorneys must carefully document and present any valid exceptions, as failure to meet the one-year filing requirement without a qualifying exception can lead to case dismissal or removal.

Key Elements of a Successful Asylum Claim

Well-Founded Fear of Persecution

To establish eligibility for asylum, the applicant must demonstrate a well-founded fear of persecution, a two-fold standard that includes both subjective and objective components. The subjective component involves the applicant’s genuine fear of persecution upon returning to their home country. This means the applicant must personally believe that returning poses a serious threat to their life or freedom due to one of the protected grounds.

The objective component requires that this fear be reasonable, meaning that an impartial observer would conclude there is a significant possibility of persecution if the applicant were to return. This requirement often involves presenting country conditions reports, expert testimonies, and credible third-party evidence that supports the applicant’s claims. Together, these components form the basis of the “well-founded fear” standard, making it essential for applicants to substantiate both their personal fear and its basis in objective reality.

Nexus to a Protected Ground

A key aspect of asylum eligibility is demonstrating a nexus, or connection, between the applicant’s fear of persecution and one of the protected grounds under U.S. law. This means that the persecution must be “on account of” race, religion, nationality, political opinion, or membership in a particular social group. The applicant must show that the persecutor was motivated by, or believed they were motivated by, one of these protected grounds.

Establishing this connection requires detailed testimony and often complex legal arguments, particularly when dealing with claims of persecution based on political opinion or membership in a particular social group. For instance, an applicant might need to prove that the persecutor targeted them because of their perceived political views, even if they were not overtly political themselves. Without a clear nexus, even genuine fears of harm may not qualify under asylum law, underscoring the need for a carefully crafted legal strategy to establish this crucial element.

Government Involvement or Inability to Control Persecutors

To succeed in an asylum claim, an applicant must show that the persecution they experienced or fear is linked to government action or a situation where the government is unwilling or unable to control non-governmental persecutors. This requirement stems from the fact that asylum is meant to protect individuals from serious abuses that their own governments are either complicit in or powerless to prevent.

Persecution directly carried out by government officials, such as police or military forces, meets this requirement. However, if the persecution is at the hands of non-state actors (such as gangs, militias, or extremist groups), the applicant must prove that the government is incapable of offering protection or is unwilling to intervene. Demonstrating government inaction often requires comprehensive evidence, including country reports, news articles, and expert testimonies. This element of the claim is critical in demonstrating that the applicant cannot seek refuge within their home country and has no other recourse but to seek asylum abroad.

Common Challenges in Asylum Cases

Credibility Issues

Credibility is a central factor in asylum cases, as applicants often rely heavily on their own testimony to support their claim. Any inconsistencies, contradictions, or inaccuracies in their story can undermine their credibility and jeopardize their chances of being granted asylum. Credibility issues can arise from simple misunderstandings, translation errors, or gaps in memory, but they may be perceived as indicators of dishonesty or exaggeration by immigration authorities.

To avoid credibility issues, applicants should ensure that their testimony is clear, consistent, and corroborated by any available documentation or witness statements. Attorneys play a critical role in preparing clients to recount their experiences in detail and to anticipate challenging questions. Presenting credible and consistent testimony, supported by evidence, can significantly strengthen an asylum claim and mitigate the risk of adverse findings based on credibility.

Particular Social Group (PSG) Claims

Claims based on membership in a particular social group (PSG) are among the most complex and debated in asylum law. Unlike the other protected grounds, PSG is not defined by a specific characteristic but rather by the group’s shared, immutable characteristics that the members cannot or should not be required to change. Common PSG claims include gender, family membership, and sexual orientation, but each claim must meet specific criteria to qualify.

To establish PSG membership, applicants must prove that their group is “socially distinct” within their home society and that it shares characteristics that are “particular” or well-defined. This often requires an in-depth analysis of cultural norms, legal standards, and social perceptions in the applicant’s home country. Due to the complexity and evolving nature of PSG claims, establishing PSG-based eligibility demands meticulous preparation, strong legal arguments, and a well-supported understanding of social dynamics within the applicant’s society.

Changed Country Conditions

Changed country conditions can have a significant impact on asylum eligibility, particularly if the situation in the applicant’s home country improves to the point where persecution is no longer a threat. The U.S. government closely monitors country conditions and uses these reports to evaluate whether applicants still face a risk if returned. If an applicant’s fear of persecution is based on past events and the conditions in their home country have substantially improved, their asylum claim may be weakened.

To counter this, applicants should present up-to-date reports, expert analyses, and other evidence showing that despite any surface-level changes, the risks they face remain genuine. Legal practitioners must remain vigilant about current country reports and expert testimonies to substantiate that persecution risks continue despite any improvements in general conditions. Changed country conditions present a unique challenge, especially in cases where political situations are fluid or human rights abuses fluctuate based on regime changes or policy shifts.

Misconceptions About Asylum

Economic Hardship Is a Basis for Asylum

A common misconception about asylum is that economic hardship qualifies as a basis for protection. In reality, asylum law does not provide protection for individuals fleeing poverty, lack of employment, or economic instability. U.S. asylum law requires that applicants demonstrate a well-founded fear of persecution based on one of the five protected grounds. While economic factors often drive migration, they alone are insufficient for asylum eligibility.

Individuals facing severe poverty or economic instability in their home countries may qualify for other types of immigration relief or temporary protections, but they do not meet the legal criteria for asylum. This distinction is crucial for applicants and advocates to understand, as focusing on economic conditions instead of protected grounds can undermine an asylum claim. Attorneys must guide clients in identifying and articulating the specific threats they face due to their identity or beliefs, separate from economic challenges.

Immediate Family Members Are Automatically Included

Another misconception is that family members are automatically included in an asylum application. While an asylum applicant can include immediate family members, such as a spouse and unmarried children under 21, these family members must be listed on the application and meet certain criteria. The relationship must be clearly documented, and the family members must be in the U.S. or eligible to enter if the primary applicant’s claim is approved.

Family members living abroad cannot automatically join the asylee in the U.S. unless they go through a separate process, such as applying for derivative asylum or family reunification after the primary applicant is granted asylum. It is essential for applicants to understand that failing to include family members in the initial application can lead to complex and lengthy processes later on, potentially delaying family reunification. This misconception highlights the importance of thorough and accurate filing, especially for applicants with dependents.

Asylum Grants Permanent Residency

Many applicants believe that being granted asylum automatically leads to permanent residency. However, asylum grants only temporary protection, allowing the asylee to remain in the U.S. and work legally. After one year of continuous presence as an asylee, individuals may apply for lawful permanent residency (a Green Card), but this is a separate application process with its own requirements.

Obtaining a Green Card is a critical step for asylees seeking long-term stability in the U.S., as it allows for a path to U.S. citizenship. However, it is not guaranteed, and asylees must comply with all necessary steps and requirements to adjust their status. This distinction is significant for applicants and employers alike, as understanding the legal limitations of asylum status can help in planning long-term integration and support strategies.

Legal Defenses and Strategic Considerations

Withholding of Removal

Withholding of Removal is an alternative form of relief for individuals who do not qualify for asylum but can demonstrate a risk of persecution if returned to their home country. While withholding of removal has a higher burden of proof than asylum, requiring a clear probability of persecution, it does not grant a pathway to permanent residency or citizenship. Individuals granted withholding of removal can remain in the U.S. and receive work authorization, but their protection is temporary and can be revoked if conditions change.

This form of relief is significant for applicants who may not meet the one-year filing deadline or have criminal records that disqualify them from asylum. Withholding of removal can be a viable option for those who face certain threats but do not meet all asylum eligibility criteria. Attorneys must carefully assess each client’s situation to determine whether withholding of removal is a viable and strategic option.

Protection Under the Convention Against Torture (CAT)

The Convention Against Torture (CAT) provides another layer of protection for individuals facing the likelihood of torture if returned to their home countries. Applicants who cannot meet asylum requirements may still qualify for CAT protection if they can prove it is “more likely than not” they would be tortured upon return. This form of relief does not require a nexus to a protected ground, making it an option for individuals who do not fall under the traditional asylum categories but still face extreme risk.

CAT protection does not provide a pathway to permanent residency or citizenship, and it carries specific legal limitations, but it allows applicants to remain in the U.S. and avoid deportation. For cases involving severe human rights abuses, CAT can be a critical option, especially when the legal standards for asylum are difficult to meet. Understanding the requirements and limitations of CAT is essential for practitioners handling complex asylum cases.

Safe Third Country Agreements

The U.S. has agreements with certain countries that designate them as “safe third countries,” meaning that individuals who pass through these nations before reaching the U.S. are generally required to seek asylum there instead. Canada, for instance, has such an agreement with the U.S., and asylum seekers arriving in the U.S. through Canada may be deemed ineligible unless they meet specific exemptions.

Safe third country agreements impact asylum eligibility and strategy, especially for applicants who traveled through multiple countries before arriving in the U.S. Attorneys must consider whether an applicant may be subject to these agreements and advise clients accordingly. Although these agreements aim to manage asylum claims across borders, they introduce additional legal challenges and may necessitate alternate forms of relief.

The Role of Business Owners

Employment of Asylees

Employers play an important role in supporting asylees by providing stable employment and integrating them into the workforce. Asylees are authorized to work in the U.S. upon being granted asylum and do not require sponsorship for employment. They may use an Employment Authorization Document (EAD) as proof of work eligibility, providing employers with an opportunity to support an asylee’s transition to life in the U.S.

For business owners, employing asylees aligns with inclusive hiring practices and helps address labor shortages. It is crucial for employers to recognize that asylees have the legal right to work without restrictions, and this authorization is generally renewable. Employers should ensure they are familiar with EAD requirements and other work authorization documents to prevent discriminatory practices and misunderstandings during hiring.

Supporting Employees in Asylum Process

Employers can provide invaluable support to employees undergoing the asylum process by offering flexibility with scheduling, especially for court dates and legal appointments. Asylum cases can take years to resolve, and employees may require time off for hearings, interviews, and other obligations. Business owners should create a supportive environment that acknowledges these unique challenges, promoting loyalty and trust.

Additionally, businesses can support asylees by providing documentation of employment, such as job letters or affidavits, which may be required as evidence in legal proceedings. Showing support for asylee employees not only strengthens their asylum claim but also reflects a company’s commitment to diversity and social responsibility.

Minnesota-Specific Considerations

Local Immigration Courts

Minnesota has immigration courts that handle asylum cases, with Minneapolis being the primary location for hearings. The state’s immigration court system is often impacted by substantial caseloads and backlogs, which can lead to delays in processing times. These delays can affect both applicants and employers, as extended waiting periods can impact an asylee’s ability to fully integrate into society and the workforce.

Understanding the local immigration court structure, including wait times and common procedural requirements, is crucial for attorneys and applicants. Practitioners should prepare clients for the realities of lengthy proceedings and the potential need for patience. Knowing how local courts operate also enables legal professionals to provide accurate guidance and manage client expectations regarding the timeline for asylum cases in Minnesota.

Community Resources

Minnesota is home to numerous community organizations and non-profits that support asylum seekers. These include the Advocates for Human Rights, the Immigration Law Center of Minnesota (ILCM), and other local groups that provide legal representation, language support, mental health services, and advocacy for immigrants. Many of these organizations work closely with attorneys and provide invaluable resources for applicants who cannot afford private legal representation.

For attorneys and business owners, connecting clients and employees to these organizations can provide necessary support and information. In addition to legal services, community organizations often offer workshops, employment resources, and other assistance that aids asylees in adapting to life in Minnesota. Leveraging these resources can ease the integration process and help asylees build a stable foundation.

State Legislation Impacting Asylum Seekers

Minnesota has enacted various state laws and policies that impact asylum seekers, especially regarding access to state benefits, healthcare, and identification. While federal law governs asylum eligibility, Minnesota offers specific protections and services that can improve the quality of life for asylum seekers residing in the state. For example, state laws may allow asylees to access specific health programs, educational opportunities, and temporary driver’s licenses.

Understanding Minnesota’s state-level protections can help asylum seekers and their legal representatives maximize available support. Business owners should be aware of these benefits to provide accurate information to asylee employees, helping them navigate available resources. This knowledge fosters a supportive workplace and empowers asylum seekers to access the services they are entitled to receive.

Potential Consequences of Asylum Denial

If an asylum application is denied, the applicant may face serious consequences, including the possibility of removal (deportation) from the United States. Denial can lead to immediate removal orders, barring applicants from re-entering the U.S. for a specified period. For individuals with family or work connections in the U.S., removal can be especially devastating, separating them from their loved ones and livelihoods.

In addition to removal, denied applicants may face further immigration restrictions or difficulty obtaining other visas in the future. Denial may also affect the family members who depend on the applicant’s asylum case for legal status, potentially leaving dependents in legal limbo. Understanding these consequences highlights the importance of thoroughly preparing asylum cases and exploring alternative forms of relief when necessary.

Appeals and Further Actions

Board of Immigration Appeals (BIA)

For individuals whose asylum applications are denied, the Board of Immigration Appeals (BIA) offers a path for appeal. The BIA is the highest administrative body for interpreting immigration law, and it allows asylum seekers to challenge immigration court decisions within a 30-day period. Filing an appeal requires clear evidence and legal arguments that demonstrate errors in the initial decision or procedural mishandling.

The BIA process is complex and often requires strong legal representation to navigate. Applicants may submit briefs, legal arguments, and supporting documentation, and in some cases, the BIA may remand the case back to the immigration judge for reconsideration. Attorneys specializing in immigration appeals play a crucial role in identifying grounds for appeal and presenting a compelling case to the BIA.

Federal Court Review

Beyond the BIA, individuals denied asylum may pursue further appeals in federal court, specifically by filing a petition for review with the U.S. Court of Appeals. This step is generally reserved for cases with substantial legal or procedural errors that cannot be resolved through the BIA. Federal court review is complex, as it involves presenting legal arguments in a more formal setting with stringent requirements.

Federal appeals require highly skilled representation, as these cases involve interpreting federal statutes, legal precedent, and administrative procedures. Attorneys representing clients in federal court must be prepared to address complex legal theories and procedural nuances, making it essential for asylum seekers to understand the limitations and requirements of this level of review.

Practical Tips for Applicants and Attorneys

Documentation

Comprehensive documentation is essential to a successful asylum case. Applicants should gather all relevant evidence early, including personal identification, travel records, medical records, news articles, and affidavits from family members or witnesses who can verify their claims. Attorneys should work closely with clients to obtain official country reports and expert testimonies to bolster the claim’s credibility.

Corroborating evidence supports the applicant’s narrative and helps address credibility concerns, particularly in cases where testimony alone may not suffice. Organizing this documentation efficiently and presenting it in a clear and logical manner can strengthen the case and provide asylum officers and judges with a compelling account of the applicant’s situation.

Legal Representation

The importance of experienced legal representation in asylum cases cannot be overstated. Navigating the complexities of asylum law, preparing for interviews and hearings, and gathering the necessary evidence are all tasks that benefit from skilled guidance. Asylum seekers who lack resources for legal representation can seek assistance from pro bono attorneys, non-profit organizations, or law school clinics.

Legal representation increases the likelihood of a favorable outcome, as experienced attorneys can help prepare applicants, anticipate potential issues, and address procedural requirements. Attorneys also ensure that clients understand their rights, options, and responsibilities throughout the asylum process, offering both strategic and emotional support during a challenging journey.

Staying Informed

The landscape of asylum law is constantly evolving, with new court decisions, policies, and legislative changes affecting eligibility and procedural requirements. Staying informed about these developments is essential for attorneys, applicants, and employers alike. Understanding recent case law, shifts in policy, and emerging trends can help attorneys provide accurate advice and anticipate challenges.

Attorneys should regularly review updates from the Department of Justice, the Department of Homeland Security, and leading legal organizations specializing in immigration. Likewise, business owners should be aware of relevant changes that may impact their asylee employees. A proactive approach to staying informed promotes better advocacy and enhances support for those seeking asylum in Minnesota.

Related Issues

Temporary Protected Status (TPS)

Temporary Protected Status (TPS) is a temporary immigration status granted to nationals of certain countries experiencing conditions that make return unsafe, such as armed conflict, natural disaster, or other extraordinary situations. TPS does not grant asylum or a pathway to permanent residency but allows individuals to remain in the U.S. and obtain work authorization.

For asylum seekers whose countries are designated for TPS, this status may offer temporary relief while they await the outcome of their asylum case. It is important to understand the distinctions between TPS and asylum, as TPS does not provide the same long-term protections. Attorneys should consider TPS as a temporary measure when applicable but continue pursuing asylum for clients seeking more permanent solutions.

Deferred Action for Childhood Arrivals (DACA)

Deferred Action for Childhood Arrivals (DACA) is a program providing temporary relief from deportation and work authorization for certain individuals who arrived in the U.S. as children. While DACA does not grant asylum or a pathway to residency, it may provide temporary security for young applicants with ongoing asylum cases.

Asylum seekers who meet DACA requirements may be eligible for protection under both programs, although each has distinct eligibility criteria. Understanding DACA’s benefits and limitations is crucial, particularly for younger applicants who may have family ties or other connections to the U.S. that strengthen their asylum claims.

Conclusion

Navigating the complexities of asylum law requires a deep understanding of both legal principles and practical considerations. Business owners play a vital role in supporting asylee employees by fostering inclusive work environments and providing necessary support. For attorneys, continual learning, empathy, and meticulous preparation are key to advocating effectively for asylum seekers.

Minnesota’s commitment to diversity and community support is evident in the resources available to asylum seekers, from legal services to community organizations. By understanding and applying the principles of asylum law, Minnesota’s business and legal communities can contribute to a more just, compassionate, and inclusive society.

Additional Resources