Featured Issues

Featured Issue: U.S. Immigration Courts under Trump 2.0

The U.S. immigration court system plays a critical role in upholding due process and ensuring fair hearings for individuals facing deportation. However, since January 20, 2025, the Department of Justice (DOJ) has implemented significant changes that challenge the structural integrity of these courts. This page aims to provide up-to-date information on the policy and legal shifts affecting the U.S. immigration court system.

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Updates from EOIR

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FR Regulations & Notices

DHS 60-Day Notice and Request for Comments on Form 405

DHS 60-day notice and request for comments on Office of the Immigration Detention Ombudsman (OIDO) Intake Form, DHS Form 405. Revisions are based on usability testing recommendations. Comments are due by 12/16/24. (89 FR 83509, 10/16/24)

10/16/24 AILA Doc. No. 24101601. Detention & Bond, Removal & Relief
Practice Resources

Immigration-Related Agency Updates Related to Hurricane Milton

We know that Hurricane Milton is on many of your minds. Here is a round-up of current agency information related to how they might handle the aftermath.

Practice Resources

Practice Pointer: BIA Holds IJs Can Amend Noncompliant NTAs in Matter of R-T-P-

AILA provides a practice alert on the implications of Matter of R–T–P–, the latest decision dealing with the impacts of DHS’s issuance of Notices to Appear (NTAs) that do not contain statutorily required information.

AILA Doc. No. 24100936. Removal & Relief
Practice Resources

Brennan Center: The Alien Enemies Act, Explained

The Brennan Center for Justice provides an explainer on the Alien Enemies Act (AEA) of 1798, noting, "This detention and deportation power poses an alarming risk of abuse and rights violations in both wartime and peacetime."

10/9/24 AILA Doc. No. 25031804. Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Finds Mexican Government Was Unable or Unwilling to Control Petitioner’s Attackers in Home Invasion

The court held that the record evidence showed that petitioner experienced harm committed by forces that Mexican authorities were either unable or unwilling to control, and that BIA erred by failing to consider highly probative evidence of nexus. (Meza Diaz v. Bondi, 10/8/24, amended 2/25/25)

10/8/24 AILA Doc. No. 24101504. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Upholds Denial of Asylum as to Salvadoran Petitioner Threatened by MS-13 Gang

The court held that petitioner’s proposed particular social group (PSG) of “Salvadoran men who resist gang recruitment” was not valid, and found that the IJ did not err in concluding that he had not made a sufficient nexus showing as to his other two PSGs. (Alvarado-Reyes v. Garland, 10/7/24)

10/7/24 AILA Doc. No. 24101502. Asylum & Refugees, Removal & Relief
Policy Briefs

Policy Brief: Analysis of Proclamation and Interim Final Rule on “Securing the Border”

President Biden signed a proclamation, and the Administration issued an Interim Final Rule as well as a Final Rule, “Securing the Border,” relying in part on the authority in INA 212(f) that will effectively bar access to asylum for most people arriving between ports of entry when in effect.

10/7/24 AILA Doc. No. 24060510. Admissions & Border, Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Remands Asylum Claim Where BIA Misapplied Matter of R–K–K– and Erred in Internal Relocation Analysis

Granting the petition for review of the BIA’s affirmance of the IJ’s denial of asylum, the court held that the BIA erred by misapplying Matter of R–K–K– in making its adverse credibility determination, and also erred in its internal relocation analysis. (Singh v. Garland, 10/4/24)

10/4/24 AILA Doc. No. 24101503. Asylum & Refugees, Removal & Relief
Practice Resources

American Immigration Council Special Report: Mass Deportation

The American Immigration Council provides an estimate of the fiscal and economic cost should the government deport the roughly 11 million people who, as of 2022, lacked permanent legal status and faced the possibility of removal.

Practice Resources

Practice Alert: EOIR Issues Memo on NTAs Filed by DHS

AILA provided a practice alert after EOIR issued a memorandum with updated guidance on NTAs filed by DHS. This memo cancels a 2018 memo issued by former EOIR Director James R. McHenry, III. The 2024 memo is currently in effect.

9/30/24 AILA Doc. No. 24093000. Removal & Relief
AILA Public Statements, Press Releases

Biden Administration Cements Harmful Asylum Restrictions

AILA President Kelli Stump and Executive Director Ben Johnson respond to the Biden Administration’s codification of harmful policies that are already undermining U.S. asylum law and denying fair access to humanitarian protection for vulnerable individuals and families.

9/30/24 AILA Doc. No. 24093006. Admissions & Border, Asylum & Refugees, Removal & Relief
Agency Memos & Announcements

Points of Contact for Credible Fear Interviews in CBP Custody

DHS provided a “Points of Contact for Credible Fear Interviews in CBP Custody” spreadsheet. This includes contacts for Border Patrol, USCIS Asylum, and EOIR.

9/30/24 AILA Doc. No. 24090914. Admissions & Border, Asylum & Refugees, Removal & Relief
Practice Resources, Litigation Resources

Venue Challenges in APA Immigration Cases

NILA created a practice alert discussing the venue choices a plaintiff has under 28 U.S.C. § 1391(e) when challenging a decision or delay in decision-making by USCIS under the Administrative Procedure Act, as well as considerations that inform venue selections.

9/27/24 AILA Doc. No. 24092762. Removal & Relief
Agency Memos & Announcements

CRS Provides FAQs on Credible Fear and Defensive Asylum Processes

The CRS report addresses FAQs about credible fear and asylum, including those related to expedited and formal removal processes; credible fear screening processes, criteria, and legislative history; procedural protections; and data regarding credible fear and asylum outcomes.

9/26/24 AILA Doc. No. 24092601. Asylum & Refugees, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That Respondent’s Convictions for Retail Theft in Pennsylvania Were Not Categorically CIMTs

The BIA held that the respondent’s convictions for retail theft in Pennsylvania were categorically not for crimes involving moral turpitude (CIMTs) because the statute does not require an intent to permanently deprive the victim of property. Matter of Thakker, 28 I&N Dec. 843 (BIA 2024)

9/20/24 AILA Doc. No. 24092332. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Finds BIA Erred in Making No-Nexus Determination with Regard to Guatemalan Petitioners’ Family Membership PSG

The court held that the BIA erred in concluding that the petitioners had failed to establish a sufficient nexus between their persecution and their family membership, and thus vacated the denial of their asylum and withholding of removal claims. (Mazariegos-Rodas, et al. v. Garland, 9/20/24)

9/20/24 AILA Doc. No. 24100101. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Holds That Petitioner’s Louisiana Conviction for Accessory After the Fact to Armed Robbery with a Firearm Was Not an Aggravated Felony

The court held that Louisiana’s accessory-after-the-fact statute was not a categorical match for the generic federal offense of obstruction of justice, and was thus not an aggravated felony under INA §101(a)(43)(S) that would permit expedited removal. (Lopez Orellana v. Garland, 9/18/24)

9/18/24 AILA Doc. No. 24092063. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA8 Reverses Habeas Decision After Finding That Appellee’s Year-Long Detention Did Not Violate His Due Process Rights

The court reversed the judgment of the district court and remanded for the denial of the appellee’s habeas petition, concluding that, pursuant to U.S. Supreme Court precedent, due process imposes no time limit on detention pending removal. (Banyee v. Garland, et al., 9/17/24)

9/17/24 AILA Doc. No. 24092064. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Remands for BIA to Assess Whether Exceptional Circumstances Warranted Recission of Petitioner’s In Absentia Removal Order

The court held that the BIA did not consider the totality of the circumstances, and thus granted the petition for review and remanded for the BIA to more fully address whether exceptional circumstances warranted recission of petitioner’s in absentia removal order. (Singh v. Garland, 9/17/24

9/17/24 AILA Doc. No. 24092000. Removal & Relief
Agency Memos & Announcements

EOIR's Varick Immigration Court to Host Model Hearing Program Event

Join the EOIR's Model Hearing Program on 9/30/24, at New York – Varick Immigration Court and via Webex. This event offers crucial training on Asylum, Withholding of Removal, and related protections. Register by email for in-person attendance or via Webex. For details, contact PAO.EOIR@usdoj.gov.

9/16/24 AILA Doc. No. 24091632. Asylum & Refugees, Removal & Relief

Practice Management Resources

The practice of law is a profession, but your law practice is a business. Whether you seek assistance with managing your work flow, obtaining new clients, dealing with staff, enhancing finances, or incorporating technology, AILA resources can help you achieve even greater success.

Agency Memos & Announcements

EOIR Announces Language Access Plan

EOIR has unveiled its Language Access Plan, in accordance with Executive Order No. 13166, to enhance services for individuals with limited English proficiency. This plan reflects EOIR's commitment to ensuring equitable access while aligning with DOJ's broader efforts.

9/13/24 AILA Doc. No. 24091302. Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Finds BIA Incorrectly Applied “Unable or Unwilling to Control” Standard Where Honduran Petitioner Was Abused as a Child

The court found that, in deciding that petitioner failed to show that Honduran officials were unable or unwilling to protect her, the BIA failed to consider whether it would have been futile for an abused child to seek protection from the government. (Castellanos-Ventura v. Garland, 9/13/24)

9/13/24 AILA Doc. No. 24092061. Asylum & Refugees, Removal & Relief
AILA Blog

Think Immigration: BIA Hands Immigration Judges the Whiteout to “Fix” Defective NTAs

AILA Past President Jeremy McKinney writes about the BIA decision in Matter of R- T- P- allowing immigration judges to “cure” defective NTAs, making them an agent of the prosecutors. This is the latest sign that an independent immigration court is necessary to ensure justice and due process.

9/12/24 AILA Doc. No. 24091201. Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Holds That Petitioner’s Municipal Convictions for Petty Larceny Were CIMTs

Denying the petition for review, the court found that the BIA correctly concluded that petitioner’s petit larceny convictions under Reno Municipal Code §8.10.040 were crimes involving moral turpitude (CIMTs) that rendered him removable under INA §237(a)(2)(A)(ii). (Lopez v. Garland, 9/11/24)

9/11/24 AILA Doc. No. 24092001. Crimes, Removal & Relief