Although the validity and attainability of the American Dream has been debated, the fact that the idea itself exists, that people believe it to be true, is undeniable. By the American Dream, I am referring to the understanding that in the United States, socio-economic mobility is not only an inherent right of American citizens, but it is also widely feasible. Further, the degree to which the American Dream can be achieved is based on a person's "discipline and drive" and "failure to move up reflects on one's character" (13). Michelle Alexander challenges this notion of the American Dream in the introduction of "The New Jim Crow: Mass Incarceration in the Age of Colorblindness" by citing the existence of a clear "underclass" in American society today (12). This "underclass" is "a group so estranged from mainstream society that it is no longer in reach of the mythical ladder of opportunity" (13). My first reaction was to question Alexander's qualifications for deeming this marginalized group unable to get to the alleged ladder. What makes someone entirely ineligible for the American Dream, as opposed to it just not being realistically feasible? For example, a common example regarding the ways in which poverty prohibits a person from obtaining certain rights as a citizen is the method for calling on potential jurors. The list of potential jurors is often taken directly from the Department of Motor Vehicles. Therefore, if a person does not have a license (presumably because he or she is too poor even for the potential of car ownership), he or she will not be chosen as a potential juror, which is the right of American citizens. In this case, a person's change to serve on a jury is not technically impossible, in the sense that they do have the ability to register at the DMV, it is just not realistic. However, Alexander clearly differentiates what she calls the "underclass" from all other members of society, including the lowest of the lower-class. The "underclass" or "undercaste" are "permanently barred by law or custom from mainstream society" (13). The important distinction here is that the "underclass" has been LEGALLY marginalized by the United States Government, prohibited from an array of social, economic and political rights. These rights include, but by no means are limited to, access to public housing, welfare, employment, right to vote, right to be a juror, etc. According to Alexander, the creation of a second class of citizens denied certain rights inherent to all Americans is implemented through the American criminal justice system. Contrary to many people's understanding of the American penal system, this marginalization is maintained well beyond a person's status as a prisoner: once a person is labeled a criminal, he or she has lost his or her rights even after release from prison. According to Alexander, "the system of mass incarceration is based on the prison label, not prison time" (14). The reason, though, that Alexander equates this issue of the ramifications of mass incarceration with the likes of Jim Crow is that the overwhelming majority of those who are made criminals in the United States are African American. According to Alexander, "Like Jim Crow (and slavery), mass incarceration operates as a tightly networked system of laws, policies, customs, and institutions that operate collectively to ensure the subordinate status of a group largely defined by race" (13). It is important to understand, however, the fact that this intention of the subordination of African Americans is no longer explicitly stated. Rather, this racism is masked by new "race neutral language" (40). This rhetoric uses the concept of the criminal to persecute African Americans, essentially creating "preservation through transformation," as articulated by Reva Siegel (21). According to Alexander, "proponents of racial hierarchy found they could install a new racial caste system without violating the law or the new limits of political discourse, by demanding 'law and order' rather than 'segregation forever'" (40).