Undocumented students graduate from high school at 98,000 per year nationally (27,000 annually in California). School counselors are certificated campus professionals tasked with social, emotional, college, and career interventions for all students and also provide advocacy between students and any barriers interfering with school safety, mental health, and school completion. Immigrant students face problems of access and inequity in education, in addition to being English learners and liminal-status students. Although "Plyer v. Doe's" (1982) landmark court decision allowed undocumented students to receive free public education, it did not provide guidelines for educators. Some school counselors gatekeep advanced opportunities and "track" immigrant students into lower achieving classes, while others serve as social justice champions. Yet limited literature exists on how they currently serve undocumented students. Also missing are undocumented students' perspectives and how to develop and support them while acknowledging the unique needs brought on by their unauthorized status. The study aimed to understand how counselors characterized their roles in recognizing undocumented students' needs and the contextual hindrances that may limit their efficacy. It sought to illuminate student voices concerning the counselor-undocumented student relationship and influential actions that occur on their behalf. Using a Critical Race Theory-based framework--empowerment theory--it highlighted perspectives of actions and hindrances in meeting identified needs of four counselors and eight undocumented students. It concluded with implications for counselors and their supervisors and recommendations for further research. [The dissertation citations contained here are published with the permission of ProQuest LLC. Further reproduction is prohibited without permission. Copies of dissertations may be obtained by Telephone (800) 1-800-521-0600. Web page: http://bibliotheek.ehb.be:2222/en-US/products/dissertations/individuals.shtml.]