This article provides a brief history of undocumented students and higher education, from the landmark case of "Plyler v. Doe" to the examination of Deferred Action for Childhood Arrivals. As lawmakers engage in debate regarding undocumented immigrants, states have attempted to provide educational clarity. In addition, academic institutions such as The University of California, Berkeley through their Undocumented Student Program (USP) have taken measures to address the needs of undocumented students in higher education.