a comprehensive list of criminal actions committed by aliens and any jurisdiction that ignored or otherwise failed to honor any detainers with respect to such aliens. Criticism of Section 9(b) While there is evidence that immigrants commit fewer crimes and are incarcerated at a lower rate than native-born Americans, there are very few studies of crime specific to illegal immigrants who are the targets of the order. Critics say that the effort to publicize immigrant crime is an effort to skew public perceptions about crimes committed by undocumented migrants. Some historians have compared Trump's proposed list of crimes committed by immigrants to the Nazi Germany-era policy of publishing lists of crimes supposedly committed by Jews. Historian Claudia Koonz of Duke University, an expert on Nazi Germany, said that the proposal was deeply troubling and that: "It's tough to make parallels when the scapegoat is so different. But the process is the same. The process was to exaggerate every piece of evidence showing the criminality of the targeted group. So even though it was atypical and not representative, by the media blitz that accompanied it, people began to see it as normal." A number of commentators, including Amanda Erickson of The Washington Post, Christopher Hooton of The Independent, and Tessa Stuart of Rolling Stone also compared the policy of distributing list of criminal actions committed by undocumented immigrants to antisemitic Nazi propaganda that focused on crime in order to stir up anger and hatred toward Jews. Section 13 - VOICE office Section 13 creates the Office of Victims of Immigration Crime Engagement, which operates to assist victims of immigrant crime. The Biden administration dissolved the office on June 11, 2021. Legal challenges Legal basis for the challenges The challenges are based largely on the Tenth Amendment to the United States Constitution. This amendment was the basis for the U.S. Supreme Court's decision in Printz v. United States (1997), in which the Court, in an opinion by Justice Antonin Scalia, struck down a law, held that the U.S. government cannot engage in "federal commandeering of state governments." While an emphasis on the Tenth Amendment has historically been championed by conservative jurists, the states and local governments challenging the executive order in this case reflect the amendment's use by liberals. A federal statute involved in the cases is section 1373 of title 8 of the United States Code. That section provides that "a