Carl is a Partner in Fragomen’s Washington, DC office, where he focuses on immigration compliance counseling and enforcement defense (both civil and criminal), federal court litigation of civil immigration disputes, legislative and regulatory representation on key immigration policy issues, and management of complex immigration cases—including alien investor visa programs, agency allegations of petitioner fraud and serious allegations of inadmissibility. A veteran of major law firms, Carl regularly teams with lawyers specializing in white-collar investigations, civil litigation, corporate transactions and global tax minimization to achieve client goals.
Carl has been at the forefront of immigration reform and agency policy since 1983. He began his career as counsel to the Senate Subcommittee on Immigration and Refugee Affairs, and helped draft and negotiate both the Immigration Reform and Control Act of 1986 and the Immigration Act of 1990. In private practice, Carl worked to amend the 1996 Illegal Immigration Reform and Immigrant Responsibility Act to narrow the strict liability elements of the Special Counsel’s statute and to create electronic employment verification options for industries targeted for immigration enforcement. Carl has remained active in advocating for immigrant and employer rights as legislation and enforcement schemes have changed over the years. He also has extensive knowledge and experience related to preventing and responding to ICE enforcement actions.
Carl has represented parents and families pro bono in litigation under the Individuals with Disabilities Education Act (IDEA), as well as numerous organizations and individuals seeking to protect the rights of foreign nationals in U.S. immigration proceedings.
Education
Georgetown University | J.D., 1991, magna cum laude
Stanford University | B.A., 1982, with honors and distinction
Awards
Named to Best Lawyers in America, 2006 to 2019
Best Lawyers in Washington, Washingtonian Magazine
Recognized in Chambers Global and Chambers USA publications
Professional Accomplishments / Memberships
Bar Admissions: California, District of Columbia
Court Admissions: U.S. District Court, District of Columbia, U.S. Court of Appeals, DC Circuit
Member, American Bar Association, White Collar Section
Represented major corporate and industry interests in the U.S. immigration reform legislative debate
Drafted and worked to amend major immigration legislation to support employers and individuals, including amendment of the Immigration and Nationality Act for numerous legislative clients in the 1996 Illegal Immigration Reform and Immigrant Responsibility Act as well as smaller bills enacted since 2000
Since 2006 to the present, represented many of the major companies investigated by U.S. Immigration and Customs Enforcement and U.S. Attorney’s Offices for potential criminal violations of employment eligibility and related rules
Represented potential defendants in criminal visa fraud investigations and litigated civil forfeiture actions based on alleged immigration violations
Represented numerous companies as compliance counsel to avoid potential criminal or civil immigration liability to U.S. Immigration and Customs Enforcement
Acted as counsel of record in numerous federal court challenges to federal immigration programs, including the L-1B visa category, the H-2A visa category, the H-1B program, the EB-5 program and the program requiring certificates for foreign-educated health care workers
Brought mandamus and similar litigation to compel agency action on unreasonably delayed applications for immigration benefits, and prevailed in cases where the government challenged federal court jurisdiction for such litigation
Appeared in corporate transactions to identify and mitigate immigration-related risks
Represented the Commonwealth of the Marshall Islands in its successful renegotiation of its Immigration Compact with the United States
Represented many companies and industries before the Office of Management and Budget in attempts to change agency rules that were contrary to law or policy
Since 1998, represented numerous companies in the meat, chicken and protein industries in their immigration-related legislative, regulatory and compliance matters