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With the rising concern about the numbers and impacts of illegal aliens in the United States - as evidenced by the sweeping passage of Proposition 187 in California, the immigrant provisions in 1996 Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), and Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA) - criminal illegal aliens have become a subject of particular focus. These individuals have not only entered or resided in the United States without the knowledge or permission of the U.S. government, but, while here, they have also violated the laws of the nation, its states, or municipalities.