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Immigrant students in U.S. public schools are present in social studies classrooms, and are exposed to citizenship education practices. Thus, exploring social studies teachers’ conceptions and practices of citizenship education for immigrant students becomes essential. This qualitative study examines how three secondary social studies teachers in two public schools talked about the tensions inhibiting the teaching of citizenship education in relation to immigrant students. Findings suggest that the teachers used a discourse of empathy to explain some of the academic tensions they and the students faced. Additionally, within this discourse of empathy, the teachers articulated cultural impediments as well as local and state regulations that hindered the teaching of citizenship education to those students.