systemic refusal to comply with the law and carry out his statutory duties. He has also breached the public trust by willfully refusing to carry out his statutory duty to control the border and guard against illegal entry, notwithstanding the calamitous consequences of his abdication of that duty. Wherefore Alejandro N. Mayorkas, by such conduct, has demonstrated that he will remain a threat to national and border security, the safety of the American people, and to the Constitution if allowed to remain in office, and has acted in a manner grossly incompatible with his duties and the rule of law. Alejandro N. Mayorkas thus warrants impeachment and trial, removal from office, and disqualification to hold and enjoy any office of honor, trust, or profit under the United States.