In Maria Marulanda's 2011 article in the Fordham Law Review titled "Preemption, Patchwork Immigration Laws, and the Potential for Brown Sundown Towns", Marulanda outlines the possibility for non-blacks to be excluded from towns in the United States. Marulanda argued that immigration laws and ordinances in certain municipalities could create similar situations to those experienced by African Americans in sundown towns. Hispanic Americans are likely to suffer, despite the purported target being illegal immigrants, in these cases of racial exclusion.[23]