Flattening the Curve, Constitutional Crisis and Immigrants' Rights Protections: The Case of Israel

Despite being a small and relatively secluded country, managing the COVID-19 pandemic has so far been quite a challenge for Israel. This contribution seeks to explain how Israel had managed migration and the pandemic amidst a constitutional crisis between February and July 2020.


CLOSING BORDERS
The first Coronavirus patient was diagnosed in Israel in late February 2020, after having arrived from Italy 1 . This happened days after Israel started prohibiting entry of tourists from countries with high infection rates 2 and imposed quarantine requirements on Israeli nationals arriving from those countries. Yet despite this measure, in our globalized world, the pandemic penetrated Israel, proving the no matter how self-contained and closed-off states attempt to be, they inevitably maintain a significant degree of interdependence and interconnectedness, and are not able to avoid significant outside influences.
By March 2020, entry restrictions became broader, allowing only entry of nationals and residents 3 This impacted, for example, the ability to bring in new migrant workers, despite the fact that the Israeli economy is very much dependent on the availability of migrant workers in construction, agriculture, and the care sectors 4 . This also restricted the ability of spouses and children of Israeli citizens who are not nationals themselves to come to Israel in order to be with their family members 5 , and impacting their ability to meaningfully enjoy their right to family life 6 .
Procedures allowing a limited possibility for non-nationals who are family members of Israeli citizens to enter the country for only published in late July, following massive pressure from the Israeli civil society and press 7 .

CONSTITUTIONAL CRISIS, LEADERSHIP CRISIS
The pandemic outbreak occurred when Israel was also dealing with an unprecedented constitutional crisis 8 . Over the course of 1 year, Israel went through three cycles of elections due to the inability to form a majority government after the two first cycles. The third elections were held after the first Coronavirus patients were diagnosed in Israel, and just a few days before the economy shut down. The crisis of the pandemic deemed so severe to some of the elected officials as to justify breaking multiple election promises and forming a unity government 9 . In the process of shutting down the economy, different parties were holding discussions on possibilities of forming a government, a process that has proven to be challenging in the last few decades in Israel's parliamentary democracy system 10 .
Initially, much of the COVID-19 emergency was thus handled by an interim government, the moral authority of which was met with massive public resistance 11 . The interim government was viewed with suspicion due to both the lack of ability to form a stable new government and the fact that even after the new unity government was formed, several of its ministers were 7 The Population and Immigration Authority, Entry to Israel Policy in the Coronavirus Period (March 19, 2020, update from July 28, 2020) https://www. gov.il/he/departments/news/border_closing_coronavirus_14062020. The policy allowed for some married couples and their children to re-enter Israel "after examination and in exceptional circumstances". However, it seems that the policy was not implemented immediately. Gur David, U. The Skies are Closed and That's It, The State Continues to Deny Thousands of Israelis the Possibility of Reunification with Their Partners and Children, HAMAKOM (July 23, 2020) https://www.hamakom.co.il/post-uriel-no-flights/. 8 Bar Siman Tov, I. Covid-19 Meets Politics: the Novel Coronavirus as a Novel Challenge for Legislatures, 8 THE THEORY AND PRACTICE OF LEGISLATION 11-48 (2020); Ben Sales, Israel Is Going Through a Constitutional Crisis, JEWISH TELEGRAPHIC AGENCY (Mar. 24, 2020), https://www.jta.org/2020/03/24/israel/ israel-is-going-through-a-constitutional-crisis. 9 See, e.g., Hostovsky Brandeis, T. Israel's Perfect Storm: Fighting Coronavirus in the Midst of a Constitutional Crisis, VERFASSUNGBLOG (April 7, 2020) https:// verfassungsblog.de/israels-perfect-storm-fighting-coronavirus-in-the-midstof-a-constitutional-crisis/; Mordechay, N., and Roznai, Y. Constitutional Crisis in Israel: Coronavirus, Interbranch Conflict, and Dynamic Judicial Review, VERFASSUNGBLOG (April 8, 2020) https://verfassungsblog.de/constitutionalcrisis-in-israel-coronavirus-interbranch-conflict-and-dynamic-judicial-review/; Sales, B. Israel is Going Through a Constitutional Crisis, FORWARD.COM (March 25, 2020), https://forward.com/fast-forward/442315/israel-is-going-through-aconstitutional-crisis/. 10  facing criminal charges or undergoing criminal investigations, including the Prime Minister Benjamin Netanyahu himself. In addition, the interim government had a somewhat compromised authority to take some of the steps deemed necessary to manage the pandemic 12 .
The constitutional crisis in Israel though was not limited to the executive and legislative branches. This process also occurred as the pressure was mounting on the Israeli judicial system. The right-wing political leadership in Israel delegitimized the Israeli courts on an ongoing basis, looking to pass an override clause to restrict its ability to conduct judicial review of primary legislation. This issue of judicial autonomy and the override clause was one of the issues in the negotiations between the parties which eventually formed the government 13 . It is worth mentioning that much of the legitimacy crisis of the Israeli court system had to do with its display of judicial activism in decisions on asylum policy, namely a series of decisions strike down legislation on immigration detention 14 .
The exposed nerves of the relationships between the different branches of government were once again hit, leading to the eventual intervention of the Israeli High Court of Justice in various issues relating to the relationship between the legislature and the government having to do with the coalition formation process 15 .
Finally, in the midst of this conundrum, Israel announced intentions to annex parts of the West Bank 16 , an act that attracted significant international criticism 17 . While this intention has yet to materialize when this paper was written, this act, which would be a violation of international law, would, in all likelihood, impose another set of constitutional crises in Israel, as well as security issues and international pressures.

EMERGENCY LEGAL FRAMEWORK
It was in this constitutional atmosphere, Israel was forced to cope with the emerging Coronavirus crisis. The above-mentioned entry and immigration restrictions were, a small part of the picture: Between mid-March and early July Israel applied a mixed 12  com/high-court-orders-vote-for-new-knesset-speaker-to-go-ahead-thursday/. 16 Al Jazeera and News Agencies. Netanyahu Discusses Annexation Plan with Gantz: Report, AL JAZEERA (June 18, 2020), https://www.aljazeera.com/news/2020/06/ netanyahu-discusses-annexation-plan-gantz-report-200618083806812.html. 17 Tidey, A. More Than 1,000 European MPs Call for Israel Annexation to Be Halted and Warn of 'Consequences', EURONEWS (June 24, 2020), https://www.euronews. com/2020/06/24/more-than-1-000-european-mps-call-for-israel-annexationto-be-halted-and-warn-of-consequen. approach of acute emergency measures enforcing closures 18 , restricting economic activity 19 , an extremely strict approach to physical distancing 20 , alongside with minimal economic assistance to persons whose financial stability was compromised due to the resulting changes in the labor market 21 .
Nevertheless, this massive use of emergency regulations did not go unnoticed. The Attorney General of the State of Israel criticized the massive use of the emergency regulations, calling to rely on primary legislation to the extent possible 26 . Some members of the Israeli public demonstrated against the use of the regulations 27 . Finally, several Israeli human rights organizations petitioned against some of those regulations, and some of those petitions were successful in the Israeli High Court of Justice 28 .

NEVERTHELESS, IMMIGRATION
Inevitably, despite the pandemic, the vast emergency measures and the above-mentioned constitutional crisis, the issue of immigration could not be sidelined in Israel, even in a time like this.
Just like in non-pandemic days, the characteristics of Israel's immigration policy are a big part of the character of the state. It is easy to understand the Israeli immigration and asylum regime if we imagine a spectrum. On one end of the spectrum there are immigrants who are included in the Israeli society and the welfare state and receive access to status. On the other end are those migrants who are excluded from Israel, and thus are not able to acquire status or access to the Israeli welfare state. I will provide a short overview of the meaningful categories of migrants in the Israeli immigration regime and explain how the challenges of the pandemic have met each of the particular categories.

Jewish Migrants or Olim and Family Members of Israeli Citizens
On the inclusive end of the spectrum are Jewish migrants and their relatives who migrate under the Law of Return 29 . The most fundamental component of Israel's immigration laws, the general premise of which is that "Every Jew has the right to come to this country as an oleh [an ascender, Jewish new comer-t.k.a]" 30 . This notion corresponds to the nature of Israel as a Jewish and democratic state, as proclaimed in its 25 PM Netanyahu's Statement to the Media, ISRAEL MINISTRY OF FOREIGN AFFAIRS (July 2, 2020), https://mfa.gov.il/MFA/PressRoom/2020/Pages/PM-Netanyahu-s-statement-to-the-media-2-July-2020.aspx. 26 Gorali, M. Mandelblit to Netanyahu: Promote Legislation to Coping with Coronavirus Instead of Emergency Regulations, CALCALIST (Apr. 6, 2020), https:// www.calcalist.co.il/local/articles/0,7340,L-3806478,00.html. 27 Toi Staff. Hundreds protest against Netanyahu, contentious emergency virus bill in Tel Aviv, THE TIMES OF ISRAEL (June 5, 2020), https://www.timesofisrael.com/ hundreds-protest-against-netanyahu-contentious-emergency-virus-bill-in-telaviv/. 28  declaration of independence 31 and in Israel's basic laws 32 , which translates into an effort to maintain a Jewish majority 33 . Under the corresponding naturalization norms, the Nationality Law, citizenship is granted automatically to those who immigrate to Israel under the Law of Return. Non-returnees have a limited ability to acquire citizenship 34 .
After the pandemic outbreak, Israeli authorities announced an increase in the applications for oleh status, though it is unclear how significant this increase is. Numbers ranged from a two percent increase in Aliya to up to a fifty percent increase 35 . Some have argued that the Coronavirus outbreak is an opportunity to induce aliya -Jewish migration or return -to Israel, given the economic crisis in many countries, which also hit some of the Jewish communities 36 . At the same time, others provided data supporting the conclusion that aliya to Israel will actually decrease 37 . This hope of potential aliya was celebrated by many in Israel. Israel, in fact, encouraged the arrival of some Jewish non-citizens, with the hope of serving them as the Jewish home. In July, the Israeli government approved the massive arrival of thousands of Ultraorthodox students under relaxed quarantine rules 38 . This created a situation which some might perceive as an anomaly, in which persons who are outsiders to the national community (but insiders to the ethnic-religious community) are allowed to enter the country even at a high cost for public health, while the entry of insiders to the national community (such as non-citizen nuclear family members of nationals, who are ethnicreligious outsiders by virtue of being non-Jewish) is restricted 39 . Attempts to challenge this inconsistent and discriminatory policy in Court failed, as the Court deferred to the government on this matter, finding that individuals may petition regarding their individual cases rather than challenge the policy in its entirety 40 .

Migrant Workers
Under the Israeli immigration regime, non-Jews do not hold a right to immigrate to Israel, and their entry to the state is restricted through the Entry to Israel Law 41 . Non-Jewish persons would typically not be able to naturalize in Israel.
Further down from the inclusive end of the spectrum we would find the category of non-Jewish migrant workers. Since the early 1990s Israel has invited migrant workers to enter its territories for employment in agriculture, construction, industry and care sectors for a limited period of time 42 . The migrant workers comprise a significant part of the Israeli labor market and employers became dependent on their available labor 43 . Nevertheless, they are not fully included in the Israeli society and welfare state, are largely isolated and are eligible for only a few of the socio-economic rights and benefits that Israeli nationals enjoy access to 44 . Generally speaking, migrant workers are only rarely perceived in the fully capacity of their humanity, but rather are perceived in terms of their labor force and their utility to their employers.
An overtly simplified perception of the best interest of the employer was the underlying logic of all the policy measures that addressed the rights of migrant workers. Most measures addressed the concerns of the employers in the care sector, where the intimate connection and the pre-existing health conditions of the employers are cause for concern. Despite the mostlyclosed border policy, attempts to freeze entry of labor migration were not completely successful, and eventually the Population and Immigration Authority allowed for migrant workers who left Israel for vacation to return to Israel, subject to quarantine requirements 45 . Later on, newly recruited migrant workers were also allowed to enter Israel to work in the care sector 46 , and (June 14, 2020), available at: https://www.gov.il/he/departments/news/ border_closing_coronavirus_14062020. This restriction was placed despite the fact that this impacts the right to family life of the Israeli citizens. 40  migrant workers in the agriculture sector were also allowed to return to Israel from their vacation 47 .
Various restrictions were temporarily imposed on the ability of migrant workers in the care sector who work in nursing homes 48 . One such restriction was a general prohibition on care workers to leave the nursing home premises, except in unusual circumstances 49 . Additionally, migrant workers were subjected to daily monitoring of their health situation, and required to wear PPA at all times 50 . All considerations of the workers' right to privacy, freedom of movement, and autonomy 51 were sidelined or utterly disregarded by both risk-averse employers and officials. As physical distancing requirements were eased, and due to intense pressures of migrants' rights NGOs, eventually migrant workers were allowed to leave their workplaces to enjoy some time off. However, they were still barred from staying in shared apartments, in which most of them had stayed in before the pandemic outbreak 52 . This restriction effectively meant that migrant workers were not able to stay outside of their employer's house for more than a few hours at a time, since most were not able to afford renting out their own place. In the tense and stressful situation of coping with a global crisis of massive scale and a demanding job, this restriction was another dimension of difficulty to an already physically and emotionally tasking situation.

Asylum Seekers
Further down the immigration policy spectrum are asylum seekers. Israel is currently hosting more than thirty thousand asylum seekers, mostly from Eritrea and Sudan 53 , referred to Care Sector (July 13, 2020) https://www.gov.il/he/departments/policies/ extending_plan_to_allow_entering_of_caregivers. 47  %202020.pdf. The state's authorities and the Court use the term 'infiltrators' to describe the asylum seeking population, but, in our view, a more accurate term would be "asylum seekers, " since the latter term focuses more on the purpose of these people's arrival in Israel rather than on the way they reached the country. by the government as "infiltrators." Despite being a party to the Convention and the Protocol since their entry into force, Israel has yet to incorporate its international law obligations to refugees into its domestic law, and has only started conducting Refugee Status Determination (RSD) on its own in 2009 54 . Most of the asylum seekers have arrived in Israel since the middle of the first decade of the twenty-first century through its southern, continental border with Egypt in an undocumented manner 55 . Since 2010, many of them were subjected to a difficult journey en route to Israel, which for many included a period of time during which they were held captive by their smugglers, tortured, raped, and enslaved to extort money from their families 56 . In 2013, this border became virtually impossible to cross with the erection of a border fence 57 .
Asylum seekers enjoy a fragile status in Israel, and most are protected from deportation under temporary collective arrangements 58 . Generally speaking, Israel has been applying various means of exclusion on the asylum seeking population, including strict border policies 59 ; extended periods of immigration detention for those who enter in an undocumented manner 60 ; denial of social and economic rights, as well as political participation 61 ; continuous attempts resettlement (voluntarily and forcibly) to third countries 62 ; geographical limitations, restricting their ability to work or reside in certain urban areas 63 ; heavy taxation 64 ; issuance of work permit which do not grant asylum seekers the right to vote, but include an implicit commitment to refrain from enforcing the prohibition to employ them on the employers 65 ; extremely low recognition rates (0.1%) 66 ; and imposition of bureaucratic hurdles and 54 Before that was only partially involved in a hybrid RSD process administered by the United Nations High Commissioner for Refugees (UNHCR). Harel, S.  61 Kritzman-Amir, supra note 53, at 23, 33. 62 https://reliefweb.int/report/israel/israel-forced-and-unlawful-israelsdeportation-eritrean-and-sudanese-asylum-seekers. 63 Kritzman-Amir, supra note 53, at 34. 64 Reuters, New Tax in Israel Leaves African Migrants Feeling Unwanted and Unwelcome, JERUSALEM POST (July 3, 2017), https://www.jpost.com/Israel-News/ New-tax-in-Israel-leaves-African-migrants-feeling-unwanted-and-unwelcome-498648. 65 Public Advocacy, Employment, ASSAF, http://assaf.org.il/en/node/139 (last visited July 21, 2020). 66 Kritzman-Amir, supra note 53, at 26. constantly changing policies 67 . These exclusion mechanisms are deliberate with the goal of deterring asylum seekers from reaching Israel in first place, and deterring those who do reach Israel from staying 68 . As a result, the majority of the asylum seekers are in a liminal situation in which they are physically present but legally absent and, in the foreseeable future, they have no chance of obtaining a stable civil status that will allow them to plan their future, build their lives, or settle down. The Israeli asylum regime has been the subject of critique by the UNHCR, Court, academia, and administrative bodies, among others 69 .
This liminal situation had direct economic implications on the asylum seeking communities even before the pandemic. Not only were asylum seekers struggling to find non-precarious employment due to their status, but they were also facing a financial struggle, mostly due to the so-called "deposit law" 70 . The law required asylum-seekers to "deposit" one-fifth of their salaries each month with the state and made these salaries available only upon their departure from the country. In addition, under the "deposit law" employers were required to transfer additional 16 percent of the salaries to the deposit -instead of paying an equivalent amount on the benefits they were eligible to receive from their employers according to Israeli employment laws. This imposition on the already-low salaries of asylum seekers has already jeopardized their stability 71 . The constitutionality of this law was challenged by a coalition of human rights organizations in a petition to the Israeli High Court of Justice shortly after the law entered into force in May 2018 72 .
But due to massive furloughs and business closures among asylum seekers, poverty approached a scope that could no longer be alleviated by community mutual aid mechanisms 73 . Many of them worked in the restaurant industry, which suffered a significant blow when physical distancing requirements were put in place 74 . They were not eligible to many of the welfare benefits which are extended to nationals. Their severance payments were not made available, since, as per the "deposit law, " employers transfer severance pay of asylum seekers into the "deposit, " even in this situation during which it was clear that leaving Israel is not a viable option in the foreseeable future 75 . Many asylum seekers were struggling to find adequate housing to quarantine in, as many of them lived in overcrowded, poorly ventilated shared spaces 76 . Having lost their employment, they have also lost their health insurance, and were not eligible for services of the national health care system, which, despite its claim to be universal, was limiting services only to citizens and residents 77 .
This crisis in the asylum seeking communities did not go unnoticed. The Israeli government considered in April 2020 relaxing measures of economic pressure to push asylum seekers out of Israel in order to address the emergency situation, but was hesitant to legislate the amended regulations necessary to relieve the pressure off the asylum seeking population, for fear of political dissatisfaction of its base 78 . The main concern was that this measure will be perceived as a normalization or acceptance of the presence of asylum seekers in Israel, in contrast to the wide and intensive efforts to exclude them 79 .
As in the past, the Israeli High Court of Justice, became once again an important institution in which migrants' rights NGOs challenge governmental policies. The Court, on the one hand, was well-experienced in judicial review in emergency situations, and, on the other hand, gained reputation (and suffered loss of legitimacy in the Israeli public) for repeatedly nullifying aspects of the immigration policies when those defied constitutional human rights obligations 80 . It is in this particular legal-political climate that the High Court of Justice issued its decision to strike down parts of the "deposit law" as unconstitutionally violating the right to property of asylum seekers in a disproportionate 73  manner 81 . In the closing paragraph of her opinion, Chief Justice Hayut, who wrote the majority opinion in this case, mentioned that the Court stands behind its holding as a general matter, but that the pandemic outburst and its economic implications on this disempowered population give additional force to the decision 82 .
This decision thus, stands against the common wisdom, which suggests that courts would be inclined to extend deference to the executive and legislative 83 , and thus would be ineffective guardians of human rights in situations of emergency, fearing loss of legitimacy should they intervene in the management of the crisis 84 . In fact, it seems that it is the emergency that allowed the Court to reach this decision, without fearing loos of legitimacy. Interestingly, the Court's decision received little news coverage and public attention 85 and thus infringed the Court's legitimacy to a minimal degree. In the last few years the Court has made continuous, seemingly conscious attempts to preserve its legitimacy and appear to be respectful of sovereign decisions in the realm of immigration. In this case, whether intentional or not, it was probably an institutionally solid strategic move on the Court's end to publish the decision in the height of the pandemic. This way, its decisions managed to fly under the radar of the majority of the population in Israel, and -to some extent -the Israeli government and parliament, which were too busy dealing with the pandemic and the constitutional crisis. Additionally, the decision received additional publically-needed justification, in light of the dire situation and the immediate need to alleviate the pressure off the asylum seeking communities. To some extent, the constitutional crisis in Israel and the emergency situation triggered by the pandemic have paradoxically made it possible to protect the rights asylum seekers in an otherwise challenging environment. The bigger questions of the lack of access of asylum seekers to the Israeli welfare state was not fully addressed yet 81  by either the government or the Court, and thus asylum seekers continue to struggle even after the decision of the Court.

Palestinians
On the far end of the spectrum is the most excluded population: Palestinian migrants. Shortly after the 1967 war, during which Israel occupied the West Bank and Gaza, Israel started allowing Palestinians from these occupied territories to come into Israel as frontier workers 86 . While their employment in Israel was often restricted for various political and security related reasons, the ability to employ Palestinians became an important feature of the Israeli economy 87 . Similarly, the income generated from employment in Israel constitutes an important contribution to the Palestinian economy 88 .
For many years, Palestinians who used to reside in what is now Israel prior to its independence and their descendants had a very limited ability to acquire citizenship 89 , since those who fled Israel before or during the 1948 war 90 were ineligible for citizenship. Perhaps most importantly, the possibility of naturalization for Palestinians and enemy nationals, even for the purpose of family reunification, has been almost completely blocked by temporary legislation, which has been renewed over the course of 18 years, but for rare and exceptional circumstances 91 . Despite judicial challenges to the legislation, it was upheld twice by a slim majority in the Supreme Court 92 .
Palestinians are also most likely to lose their citizenship status, since one of the grounds on which citizenship may be revoked is entering into enemy countries or acquiring citizenship in one of those countries, in which many of the Palestinian citizens of Israel have family ties or other affiliations 93 . Calls for broadening the authority to revoke the citizenship of Palestinians are often heard within the judicial process or the public debate 94 , and the few rare occasions on which citizenship has been revoked involved Palestinian citizens 95 . It should also be noted that a significant number of Palestinians do not have citizenship status, but rather hold an inferior residency status, which they can easily lose if they relocate, even temporarily, to another country 96 and which carries only limited rights and partial participation in the Israeli welfare state. To put it differently, Israel's immigration and citizenship regime are engaged in the exclusion and "othering" Palestinians 97 .
When it comes to migration for employment, Palestinians -as frontier workers -are even more excluded than the other migrant workers, as they are not eligible for some of the (few) rights protections that are afforded to migrant workers and expected to receive them at their homes. It is therefore interesting how Israel approached the issue of employment of Palestinians during the Coronavirus outbreak. At the peak of the pandemic outbreak, when Israelis were asked to shelter in place and borders were by and large closed, Israel imposed a closure on the West Bank and Gaza 98 . It also placed restrictions on Palestinian workers, allowing them to continue working in Israel but prohibiting their return to their homes for several weeks at a time 99 . To some extent, the prohibition to return home turned Palestinian frontier workers to migrant workers and was somewhat counterintuitive. It ran against the decades of efforts to exclude Palestinian workers and make them as temporary, as excluded and as disposable as possible. Yet this measure allowed for Palestinians to have a longer presence than usual in Israel. Aiming to protect the Israeli public, this step also protected the Palestinians, who reported that a significant number of those tested positive for COVID-19 contracted the virus during their employment in Israel 100 . At the same time, this forced people to make a tough choice between providing for their families or staying with them in a tense and challenging time. Additionally, the requirement from Palestinian workers to remain in Israel was not accompanied by any form of inclusion in the Israeli welfare state. Thus, amidst this global health crisis, Palestinians were not offered either access to the national healthcare system, nor were their employers required to provide health insurance for them 101 . The result was that Palestinians who were suspected to have contracted the virus had no recourse in Israel, and were dumped by their Israeli employers, in an act triggered by fear and disregard, next to checkpoints, at the hope that they would be picked up by Palestinian ambulances 102 . Additionally, employers were not held to any significant standard regarding the type of housing they need to provide, and the immediate result was that workers often resided in their work places 103 . Generally speaking, there was no authority overseeing the employment conditions and access to rights of Palestinians workers in this tense time 104 .
This practice was challenged in a petition to the Israeli High Court of Justice, requiring that Palestinian workers be provided adequate housing, health insurance 105 . Additionally, the petition required monitoring of the conditions of the Palestinian employees 106 . In response to the petition, the government issued emergency regulations, requiring provision of health insurance, setting clear guidelines for physical distancing and adequate housing standards 107 . In addition, employers were instructed to refrain from confiscating identity documents of their employees, which was previously required, allegedly by mistake, since it is illegal according to Israeli law 108 . Nevertheless, it seems that enforcement of these regulations is partial at best, and Palestinians continue to face difficult challenges during their employment in Israel 109 .

CONCLUSION
This paper is written as the number of persons tested positive for the Coronavirus is rapidly increasing in Israel. Though initially able to respond quickly and "flatten the curve" in the spring of 2020, Israel has become quite vulnerable to the pandemic come summer 2020 110 .
It is often true that through examination of immigration policy -a policy directed at vulnerable persons on the edge of society -we learn a lot about the society as a whole. It is also true