““Demonstrating the Obama administration’s awareness of both the lawlessness of its actions and the fact that they were certain to undermine legislative efforts to reform immigration law in a manner consistent with the Constitution, one DHS memorandum observed: Even many who have supported a legislated legalization program may question the legitimacy of trying to accomplish the same end via administrative action, particularly after five years where the two parties have treated this as a matter to be decided in Congress.3””