Charles Garcia argues that the phrase "illegal immigrant" should not be used to describe people who have entered the United States without documentation. One major piece of his argument is that such immigrants have not committed a crime by entering the United States in this way. People who are characterized as "illegal" cannot be punished as criminals, they can only be deported, and this, as Garcia observes, is a civil matter, one decided by a judge. Many people do not realize this, and a major reason why, Garcia suggests, is the fact that the news media, including most major outlets (in 2012), persisted in using the phrase "illegal immigrants." Not only is the phrase offensive and dehumanizing, as Garcia points out, it is actually wrong as a matter of fact. Thus, without any legal basis for characterizing undocumented immigrants, many of whom are long-time residents in the country, Garcia argues that the media and politicians are unjustly stigmatizing a vast swath of people. He cites multiple studies that chart the use of the phrase, and points to the fact that the Associated Press has decided that the phrase is "accurate" and "neutral," lacking the value judgment that Garcia ascribes to it. Thus the Supreme Court's decision to avoid using the term in Arizona v. United States was an important one.