Immigrants' limited political power in the United States makes it inherently difficult to curb misconduct by federal immigration officials, says Kevin R. Johnson, UC Davis law professor. Even when the U.S. Supreme Court hears an immigration decision in a case concerning alleged abuse, it typically rules against the noncitizen, while Congress sits idly by, Johnson says. In a recent examination of 71 Supreme Court decisions from 1952 to 1993 involving the Immigration and Nationality Act, Johnson found that Congress overrode the court's decision in only four cases. In the alleged INA abuse cases brought by noncitizens, the government prevailed in 67.3 percent. In similar cases brought by U.S. citizens, the government prevailed in only 26.7 percent. Hence, Johnson says, "political action, not litigation, may be the only long-term solution for noncitizens." For this to happen, such images as the illegal Mexican alien or smuggled Chinese must yield to the more accurate picture of hardworking immigrants contributing to the U.S. economy. A drive for naturalization of immigrants, such as that recently proposed by the Clinton administration, is a move in the right direction, Johnson says.