American Bar Ass’n, The History of Juvenile Justice 5, available at https://www.americanbar.org/content/dam/aba/migrated/publiced/features/DYJpart1.authcheckdam.pdf.
 Brian Evans, Campaign for Youth Justice, Adolescent Brain Development (Dec. 10, 2018), available at http://www.campaignforyouthjustice.org/images/factsheets/Adolescent_Brain_Development_FINAL.pdf.
 Terrie E. Moffitt, Adolescent-Limited and Life-Course-Persistent Antisocial Behavior: A Developmental Taxonomy, 100 Psychol. Rev. 674-75, 685-686 (1993); Terrie E. Moffitt, Natural Histories of Delinquency, in Cross-National Longitudinal Research on Human Development and Criminal Behavior 3-4,7, 29 (Elmar G.M. Weitekamp & Hans-Jürgen Kerner eds., 1994); Jeffrey Arnett, Reckless Behavior in Adolescence: A Developmental Perspective, 12 Developmental Rev. 339, 343 (1992); U.S. Dept. of Justice, Statistical Briefing Book, https://www.ojjdp.gov/ojstatbb/crime/index.html (last visited Apr. 29, 2019) (statistics showing that arrests for both serious violent crimes and property crimes peak in late adolescence).
 Joshua Rovner, Youth Commitments and Arrests, The Sentencing Project (Apr. 1, 2016), https://www.sentencingproject.org/publications/racial-disparities-in-youth-commitments-and-arrests/.
 Latino Disparities in Youth Incarceration, The Sentencing Project (Oct. 12, 2017), https://www.sentencingproject.org/publications/latino-disparities-youth-incarceration/.
 Black Disparities in Youth Incarceration, The Sentencing Project (Sept. 12, 2017), https://www.sentencingproject.org/publications/black-disparities-youth-incarceration/.
 Katrina Dizon Mariategue, Southeast Asian Americans and the School-to-Prison-to-Deportation Pipeline, Southeast Asia Resource Action Center (Apr. 15, 2018), https://www.searac.org/resource-hub/immigration/resources-toolkits-immigration/southeast-asian-americans-and-the-school-to-prison-to-deportation-pipeline/.
 What You Need to Know About the Violent Animals of MS-13, The White House, May 21, 2018), https://www.whitehouse.gov/articles/need-know-violent-animals-ms-13/.
 Alex S. Vitale, The New ‘Superpredator’ Myth, NY Times (Mar. 23, 2018), https://www.nytimes.com/2018/03/23/opinion/superpredator-myth.html.
John DiIulio, The Coming of the Superpredators, Weekly Standard (Nov. 27, 1995, 12:00 AM), https://www.weeklystandard.com/the-coming-of-the-super-predators/article/8160.
 Krista Larson & Hernan Carvente, Juvenile Justice Systems Still Grappling with Legacy of the “Superpredator” Myth, Vera Inst. (Jan. 24, 2017), https://www.vera.org/blog/juvenile-justice-systems-still-grappling-with-legacy-of-the-superpredator-myth.
 Office of Juvenile Justice and Delinquency Prevention, Juvenile Arrest Rate Trends, OJJDP Statistical Briefing Book (Dec. 6, 2017), https://www.ojjdp.gov/ojstatbb/crime/JAR_Display.asp?ID=qa05201.
 Jill Tucker and Joaquin Palomino, Vanishing Violence, NY Times (Mar. 21, 2019), https://projects.sfchronicle.com/2019/vanishing-violence/.
 Press Release, Wendy Sawyer, Prison Policy Initiative, Youth Confinement: The Whole Pie (Feb. 27, 2018), available at https://www.prisonpolicy.org/reports/youth2018.html.
 A noncitizen is inadmissible if he or she makes a formal, knowing admission of a drug offense to a Department of State or a Department of Homeland Security official. 8 U.S.C. § 11182(a)(2)(A)(i)(II), INA § 212(a)(2)(A)(i)(II). No conviction is necessary to trigger inadmissibility under this section.
 Laila L. Hlass and Rachel Prandini, Deportation By Any Means Necessary: How Immigration Officials are Labeling Youth as Gang Members (2018), available at https://www.ilrc.org/sites/default/files/resources/deport_by_any_means_nec-20180521.pdf (finding that immigration officials across the Department of Homeland Security are falsely accusing immigrant youth of gang involvement; that immigrant youth with prior gang involvement are being denied immigration benefits, even when there is evidence of rehabilitation and community involvement; and that immigration law provides no clear definition on what constitutes gang involvement); Marie Holper and Claire Valentin, Boston Has a Secret Point System That Turns Normal Teenage Behavior Into Gang Membership, ACLU (Nov. 21, 2018), https://www.aclu.org/blog/immigrants-rights/boston-police-has-secret-point-system-turns-normal-teenage-behavior-gang (“In Massachusetts, law enforcement officials labeled him a gang member not because he was arrested for gang violence or suspected of engaging in it. Rather they labeled him that way because he was the victim of an assault at school. The crime committed against him cost him eight points. He was “verified” when he was seen leaving school with other supposedly "verified" gang members.”); F.E., There’s No Evidence I’m in a Gang — Because I’m Not. But I’ve Been Locked Up for Two Months for Gang Membership., ACLU (Aug. 15, 2017), https://www.aclu.org/blog/immigrants-rights/immigrants-rights-and-detention/theres-no-evidence-im-gang-because-im-not-ive (explaining that the author was accused of belonging to a gang based on a doodle found in his notebook and people he said hi to school).
 First Amended Petition for Writ of Habeas Corpus and Class Action Complaint for Injunctive and Declaratory Relief at 10, Saravia v. Sessions, Case No. 17-cv-03615-VC. (N.D. Cal. 2017), available at https://www.aclunc.org/docs/20170811-first_amended_petition.pdf [hereinafter First Amended Petition].
 Stephen Kang, The Trump Administration Is Detaining Immigrant Kids for Gang Membership Without Evidence. So We Sued., ACLU (Aug. 14, 2017, 2:00 PM), https://www.aclu.org/blog/immigrants-rights/immigrants-rights-and-detention/trump-administration-detaining-immigrant-kids.
 Hlass and Prandini, supra note 15 at 10.
 Joel Rubin, ICE Arrests Hundreds of Immigrants in ‘Sanctuary Cities’ Around the Nation, California, LA Times (Sep. 28, 2017), https://www.latimes.com/local/lanow/la-me-ice-raids-sanctuary-20170928-story.html.
 Lily Moore-Eissenberg and Hailey Fuchs, Activists Rush to Provide Aid for Those Detained in ICE Raid, Toledo Blade (June 8, 2018), https://www.toledoblade.com/local/2018/06/07/Activists-rush-to-provide-aid-for-those-detained-in-ICE-raid.html.
 Alice Speri, The Largest Gang Raid in NYC History Swept Up Dozens of Young People Who Weren’t in Gangs, The Intercept (Apr. 25, 2019), https://theintercept.com/2019/04/25/bronx-120-report-mass-gang-prosecution-rico/.
 Julianne Hing, ICE Admits Gang Operations Are Designed to Lock Up Immigrants, The Nation (Nov. 20, 2017), https://www.thenation.com/article/ice-admits-gang-operations-are-designed-to-lock-up-immigrants/.
 K. Babe Howell, Gang Policing: The Post Stop-and-Frisk Justification for Profile-Based Policing, 5 Univ. Denver Crim. Law Rev. 1 (2015).
 Hlass and Prandini, supra note 15 at 5.
 See James B. Jacobs, Gang Databases: Context and Questions, 8 Criminology & Public Policy 4, 705 (2009), available at https://crimejustice.law.nyu.edu/wp-content/uploads/9-Jacobs-Gang-Databases.pdf (explaining an individual can be added to a gang database without having ever been charged or convicted of a crime); Rebecca Bader Brown, The Gang’s All Here: Evaluation the Need for a National Gang Database, 49 Colum. J.L. & Soc. Probs. 293, 299 (2009), available at http://jlsp.law.columbia.edu/wp-content/uploads/sites/8/2017/03/42-Brown.pdf.
 Nat’l Juvenile Justice Network, Safeguarding the Confidentiality of Youth in the Justice System 8 n. 39 (2016), available at http://www.njjn.org/uploads/policy-platforms/Juv-confidentiality_safeguards-recommendations_8.1.16_FINAL.pdf.
 See Hlass and Prandini, supra note 15 at 5 n. 9 (The California State Auditor found so many inaccuracies with California’s gang database (“CalGang”), that the California legislature passed a law in 2017 placing a moratorium on the use of shared gang databases until issues exposed by a state audit are addressed and blocking federal law enforcement access to shared gang databases for immigration enforcement); Nat’l Juvenile Justice Network, 2017 NJJN Member Youth Justice Advances 5 (2018), available at http://www.njjn.org/uploads/digital-library/2017%20Leg%20Advances%20Snapshot%20(updated)%20.pdf.
 Rebeccca A. Hufstader, Immigration Reliance on Gang Databases: Unchecked Discretion and Undesirable Consequences, 90 N.Y.L. Sch. L. Rev. 671, 683 (2015) (finding that California, Georgia, South Carolina, Virginia, and Washington all made their databases available to federal law enforcement); Chicagoans for An End to the Gang Database, et. al., v. City of Chicago, et.al., No. 1:18-cv-04242 (N.D. Ill. 2018).
 Julie Mao and Paromita Shah, Frequently Asked Questions on “Gang-Related” Immigration Enforcement (2017), available at https://www.nipnlg.org/PDFs/community/2017_Oct_FAQ-ICE-gang-enforcement.pdf.