Featured Issues

Featured Issue: Representing Clients Before ICE

2/3/25 AILA Doc. No. 25010904. Removal & Relief

This resource page combines resources for attorneys representing clients before ICE. For information about why AILA is calling for the reduction and phasing out of immigration detention, please see our Featured Issue Page: Immigration Detention and Alternatives to Detention.

Quick Links

Communicating with OPLA, ERO, and CROs

The Office of the Principal Legal Advisor (OPLA) includes 1300 attorneys who represent the Department of Homeland Security (DHS) in immigration removal proceedings before the Executive Office for Immigration Review (EOIR). OPLA litigates all removal cases as well as provides legal counsel to ICE personnel. At present, there are 25 field locations throughout the United States.

Enforcement and Removal Operations (ERO) manages all aspects of immigration enforcement from arrest, detention, and removal. ERO has 24 field office locations. ERO also manages an “alternative to detention” program that relies almost exclusively on the “Intensive Supervision Appearance Program (ISAP)” to monitor individuals in removal proceedings.

Since 2016, ICE has had an Office of Partnership and Engagement (formerly Office of Community Engagement) to be a link between the agency and stakeholders. As part of this office, Community Relations Officers (CROS) are assigned to every field office to work with local stakeholders such as attorneys and nonprofit organizations.

*Headquarters does not provide direct contact numbers or emails for individual employees.* (AILA Liaison Meeting with ICE on April 26, 2023)(AILA Doc. No. 23033004). However, attorneys can contact Chapter Local ICE Liaisons as they may have this information provided to them via local liaison engagement.

Latest on Enforcement Priorities & Prosecutorial Discretion

Executive Order 14159 (90 FR 8443, 1/29/25) directs DHS to set priorities that protect the public safety and national security interests of the American people, including by ensuring the successful enforcement of final orders of removal, enforcement of the INA and other Federal laws related to the illegal entry and unlawful presence of [noncitizens] in the United States and the enforcement of the purposes of this order. Given the January 25, 2025, confirmation of DHS Secretary Kristi Noem, a memorandum detailing enforcement priorities may be issued in the coming weeks.

An unpublished ICE memo from acting ICE Director Caleb Vitello entitled “Interim Guidance: Civil Immigration Enforcement Actions in or near Courthouses” makes reference to targeted noncitizens and includes:

  • National security or public safety threats;
  • Those with criminal convictions;
  • Gang members;
  • Those who have been ordered removed from the United States but have failed to depart; and/or
  • Those who have re-entered the country illegally after being removed.

Procedures and email inboxes created under the Biden Administration to request Prosecutorial Discretion no longer appear on the ICE website. AILA members are encouraged to review current DOJ regulations entitled “Efficient Case and Docket Management in Immigration Proceedings” for alternative basis for seeking termination or administrative closure.

Access to Counsel

Filing Administrative Complaints on Behalf of Detained and Formerly Detained Clients

Selected ICE Policies and Current Status

For comprehensive comparison of current and prior ICE policies, please review the “Immigration Policy Tracker (IPTP).” The IPTP is a project of Professor Lucas Guttentag working with teams of Stanford and Yale law students and leading national immigration experts.

Pre Jan 20, 2025 Status Current Status
  • Unclear but attorneys should proceed with extreme caution in pursuing any relief under this process.
  • No recission has been announced.
  • No recission has been announced.
  • The 2021 Victim Centered Approach Memo and the 2011 Prosecutorial Discretion for Victims and Witness have allegedly been rescinded though no public updated guidance available at the time of this updated. Media reports suggest that the requirements of 1367 protections should still be followed.
  • No recission has been announced.
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Federal Court Cases

DOJ Files Lawsuit to Stop New York’s Protect Our Courts Act

DOJ filed suit against the state of New York to stop the Protect Our Courts Act, a 2020 state law that prohibits federal officers from conducting civil arrests in or around courthouses without a warrant signed by a judge. (United States v. New York, 6/12/25)

6/12/25 AILA Doc. No. 25061706. Detention & Bond, Removal & Relief
Practice Resources

Practice Alert: EOIR Guidance to Immigration Judges on Dismissals and Other Adjudications

On May 30th, 2025, immigration judges nationwide received instructions on how to adjudicate the recent wave of dismissal requests from ICE OPLA. Read this practice alert for the text of the email and accompanying guidance.

6/12/25 AILA Doc. No. 25061204. Expedited Removal, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Vacates IJ’s Release on Bond Order After Finding Respondent Failed to Show She Was Not a Flight Risk

The BIA held that a grant of withholding of removal that is pending on appeal does not justify release on bond where the factors regarding flight risk weigh strongly against release on bond. Matter of E–Y–F–G–, 29 I&N Dec. 103 (BIA 2025)

6/11/25 AILA Doc. No. 25061202. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Remands Asylum Claim Where BIA Failed to Consider Impact of Petitioner’s Past Experiences on Her Religious Practice

The court concluded that, in determining whether the Brazilian petitioner experienced harm rising to the level of persecution, neither the BIA nor the IJ considered the impact of petitioner’s past experiences on her ability to freely practice her religion. (De Souza Silva v. Bondi, 6/11/25)

6/11/25 AILA Doc. No. 25061800. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Remands After BIA Failed to Explain Its Refusal to Consider Petitioner’s Ineffective Assistance Claim

Granting the petition for review, the court concluded that the BIA abused its discretion by failing to offer a reasoned explanation for its determination that it could not or should not review claims of ineffective assistance of counsel before a different tribunal. (Li v. Bondi, 6/10/25)

6/10/25 AILA Doc. No. 25061702. Removal & Relief
AILA Announcements

Take Action: Demand Congress to Protect Due Process and Stop the Administration from Undermining the Integrity of the Immigration Courts

The administration is targeting noncitizens at immigration courts and USCIS field offices through coordinated arrests that violate due process. Urge your Member of Congress to conduct oversight, investigate the interagency abuse, and protect the integrity of the immigration process.

6/10/25 AILA Doc. No. 25061003. Detention & Bond, Expedited Removal, Removal & Relief
Federal Agencies, Agency Memos & Announcements

DHS Announces Fine Forgiveness for Noncitizens Who “Self-Deport”

DHS announced that noncitizens who “self-deport” through the CBP Home App will receive forgiveness of any civil fines or penalties for failing to depart the U.S. Currently, individuals can be fined nearly $1,000 per day they do not depart after a final deportation order.

6/9/25 AILA Doc. No. 25061102. Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Finds No Nexus Between Gang Threats and Petitioner’s Membership in “Young Male Salvadorans” Social Group

The court upheld the denial of the petitioner’s asylum and withholding of removal claims, holding that substantial evidence supported the IJ’s conclusion that petitioner failed to establish a nexus between the harm he suffered and his proffered social group. (De Paz-Peraza v. Bondi, 6/9/25)

6/9/25 AILA Doc. No. 25061600. Asylum & Refugees, Removal & Relief
Agency Memos & Announcements

Presidential Memo on DOD Security for the Protection of DHS Functions

President Trump released a memo on 6/7/25 calling on the National Guard and other Federal service members to protect ICE personnel during immigration enforcement actions. The memo calls for at least 2,000 National Guard personnel to serve for 60 days or at the DOD Secretary’s discretion.

6/7/25 AILA Doc. No. 25060905. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That Pending Application for TPS Generally Will Not Warrant Administrative Closure

The BIA reaffirmed its holding in Matter of W–Y–U–, and concluded that a pending application for Temporary Protected Status (TPS) generally will not warrant a grant of administrative closure. Matter of B–N–K–, 29 I&N Dec. 96 (BIA 2025)

6/6/25 AILA Doc. No. 25061001. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Vacates CAT Grant After Finding No Individualized Risk of Torture for Bisexual Criminal Deportee with Gang Tattoos

The BIA held that the applicant, a bisexual criminal deportee with visible gang tattoos, had not established an individualized risk of torture in detention in El Salvador, and vacated the IJ’s grant of Convention Against Torture (CAT) protection. Matter of A–A–F–V–, 29 I&N Dec. 118 (BIA 2025)

6/6/25 AILA Doc. No. 25070300. Crimes, Removal & Relief
Congressional Updates

86 Representatives Urge DHS to End Arrests at Immigration Courts

Rep. Dan Goldman (D-NY) led 86 House members in a letter to DHS Secretary and ICE Acting Director expressing concern over ICE enforcement operations at immigration courts and noting that many of those arrested do not have a criminal record.

6/5/25 AILA Doc. No. 25060602. Detention & Bond, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That IJ’s Predictive Findings on Harm Respondent Would Suffer in Russia Were Speculative

The BIA held that the IJ’s predictive findings on the harm respondent would suffer in Russia based on his travel to the United States and his support for Ukraine were speculative, and vacated the grant of Convention Against Torture (CAT) protection. Matter of E–Z–, 29 I&N Dec. 123 (BIA 2025)

6/5/25 AILA Doc. No. 25070900. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Says Federal Conviction for Inducing Minor to Engage in Illegal Sexual Activity Was an Aggravated Felony and Crime of Child Abuse

The court concluded that the petitioner’s conviction for inducing a minor to engage in illegal sexual activity in violation of 18 USC §2422(b) was categorically an aggravated felony and a crime of child abuse under the INA. (Hsieh v. Bondi, 6/4/25)

6/4/25 AILA Doc. No. 25061362. Crimes, Removal & Relief
Practice Resources

Practice Alert: Members reporting increased ICE arrests for people on ATD monitoring

Reports show ICE is arresting ATD individuals at ISAP/ICE check-ins nationwide.

6/4/25 AILA Doc. No. 25060431. Detention & Bond, Expedited Removal, Removal & Relief
AILA Announcements

Call for Examples: ICE Arrests at Immigration Courts

AILA members recently reported widespread instances of ICE Enforcement and ERO agents appearing at immigration courts to detain individuals. AILA released a policy brief summarizing the reports. To better understand the details, please complete this survey if your client was arrested at EOIR.

6/3/25 AILA Doc. No. 25060305. Expedited Removal, Removal & Relief
Federal Agencies, FR Regulations & Notices

DOJ 60-Day Request for Comments on Revision of Forms EOIR-60 and EOIR-61

DOJ request for comments on revision of Form EOIR-60, Notice of Entry of Limited Appearance for Document Assistance Before the Board of Immigration Appeals, and Form EOIR-61, Notice of Entry of Limited Appearance for Document Assistance Before the Immigration Court.  (90 FR 23568, 6/3/25)

6/3/25 AILA Doc. No. 25060311. Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Dismisses Cancellation Challenge as Unreviewable and Denies Unexhausted Ineffective Assistance Claim

The court held that it lacked jurisdiction to review the agency’s discretionary denial of cancellation of removal where the petitioner’s arguments did not raise a colorable legal question, and rejected the petitioner’s ineffective assistance of counsel claim. (Linares-Rivas v. Bondi, 6/3/25)

6/3/25 AILA Doc. No. 25061363. Cancellation, Suspension & 212(c), Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Holds That Agency Properly Relied on Border Interview in Making Adverse Credibility Determination

The court held that because the agency considered petitioner’s argument about the reliability of his border interview, it properly relied on the interview in making an adverse credibility determination under the REAL ID Act’s totality-of-the-circumstances standard. (Singh v. Bondi, 6/3/25)

6/3/25 AILA Doc. No. 25061203. Asylum & Refugees, Removal & Relief
Client Flyers

Know Before You Go: Immigration Court Hearings and ICE Arrests

AILA provides a flyer to alert your clients of ICE arrests outside of immigration courthouses with information they should know before going to immigration court. The flyer is available as a generic PDF version as well as a Word version you can customize with your firm's information. Please share.

6/2/25 AILA Doc. No. 25060235. Detention & Bond, Expedited Removal, Removal & Relief

Know Before You Go: Immigration Court Hearings and ICE Arrests

AILA provides a flyer to alert your clients of ICE arrests outside of immigration courthouses with information they should know before going to immigration court. The flyer is available as a generic PDF version as well as a Word version you can customize with your firm's information. Please share.

Federal Agencies, FR Regulations & Notices

DOS Determination Pursuant to Section 2(b)(2) of the Migration and Refugee Assistance Act of 1962

DOS public notice determining that assistance to migrants without legal basis to remain in the United States to voluntarily return to their country of origin or country of legal status will contribute to the foreign policy interests of the United States. (90 FR 23096, 5/30/25)

5/30/25 AILA Doc. No. 25053011. Asylum & Refugees, Consular Processing, Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Denies Motion for Stay Where Petitioner Failed to Show Likelihood of Success and Irreparable Harm

The court denied the petitioner’s motion to stay the IJ’s removal order pending appeal, finding that he failed to show that he was likely to succeed on the merits of his underlying appeal and that he would be irreparably injured without a stay. (Sarkisov v. Bondi, 5/29/25)

5/29/25 AILA Doc. No. 25060302. Removal & Relief
Cases & Decisions, Federal Court Cases

CA11 Upholds BIA’s Finding That Petitioner’s Motion to Reopen Was Untimely and Procedurally Barred

Denying the petition for review, the court held that the BIA afforded the petitioner’s third motion to reopen reasoned consideration and that it properly exercised its discretion in finding that Niz-Chavez v. Garland did not justify equitable tolling. (Hamilton v. Att’y Gen., 5/29/25)

5/29/25 AILA Doc. No. 25060432. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Finds That IJ Erred in Allowing Respondent Whose NTA Lacked Time and Place Information to Withdraw Her Pleadings

The BIA held that lack of time and place information on the Notice to Appear (NTA) did not render untrue or incorrect the respondent’s admission to the factual allegations or invalidate the charges of removability in the NTA. Matter of Lopez-Ticas, 29 I&N Dec. 90 (BIA 2025)

5/29/25 AILA Doc. No. 25053002. Removal & Relief