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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Liaison Minutes

AILA ICE Liaison Committee Meeting with ICE

AILA’s ICE Liaison Committee provides meeting minutes with ICE responses from the committee’s 4/26/23 liaison engagement with the agency. Topics include OPLA non-appearance, ERO check-in procedures, and related problems with Notices to Appear.

4/26/23 AILA Doc. No. 23033004. Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds Guatemalan Petitioner with SIJ Status Was Not Paroled for Purposes of Removal

The court found that the petitioner’s Special Immigrant Juvenile (SIJ) status did not exempt him from removal, reasoning that the plain language of INA §245(h)(2) shows that SIJ parole applies only for adjustment of status, not for purposes of removal. (Cortez-Amador v. Att’y Gen., 4/25/23)

4/25/23 AILA Doc. No. 23060104. Removal & Relief, Special Immigrant Juveniles
Cases & Decisions, Federal Court Cases

CA4 Upholds CAT Denial to Bisexual Man and Former Gang Member Petitioner from Jamaica

The court found that petitioner, a bisexual man and former gang member, had not shown the requisite likelihood that he would be tortured if returned to his home country of Jamaica, and thus upheld the agency’s denial of his Convention Against Torture (CAT) claim. (Kerr v. Garland, 4/24/23)

4/24/23 AILA Doc. No. 23060202. Asylum & Refugees, LGBTQ, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Upholds BIA’s Determination That Visa Fraud Waiver Could Not Overcome Grounds for Petitioners’ Removal

The court held that the visa fraud waiver did not reach the petitioners’ grounds for removal, that it lacked jurisdiction over the claims the BIA did not reach, and that the petitioners failed to show a violation of their due process rights. (Reese v. Garland, 4/24/23)

4/24/23 AILA Doc. No. 23060203. Admissions & Border, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Rejects Petitioner’s Argument That BIA Impermissibly Engaged in Factfinding in Characterizing His Criminal History

The court found that the BIA did not second-guess the IJ’s factual findings, but instead conducted a de novo reweighing of the equities based on the facts found by the IJ, and thus properly exercised its discretion to deny cancellation of removal. (Hernandez v. Garland, 4/21/23)

4/21/23 AILA Doc. No. 23042405. Cancellation, Suspension & 212(c), Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Finds That Habeas Corpus Petitions Are Hybrid Actions for Purposes of the EAJA

Denying the appellants’ motion for attorney’s fees, the court held that habeas corpus petitions are not purely civil in nature but rather are hybrid actions, and therefore do not unequivocally fall under the text of the Equal Access to Justice Act (EAJA). (Gomez Barco v. Garland, 4/20/23)

4/20/23 AILA Doc. No. 23042407. Removal & Relief
Practice Resources

Practice Alert: Key Takeaways on the Credible Fear Interviews in Customs and Border Protection Custody

AILA provides a practice alert regarding DHS changes to how and when credible fear interviews occur for individuals processed under Title 8 expedited removal.

Federal Agencies, Agency Memos & Announcements

ICE Launches Online CeBONDS Capability to Automate Bond Payments

ICE announced the implementation of Cash Electronic Bonds Online (CeBonds), a web-based system aimed to provide a fully automated online platform for requesting verification of bond eligibility, making cash immigration bond payments, and sending electronic notifications to cash bond obligors.

4/20/23 AILA Doc. No. 23042401. Detention & Bond, Removal & Relief
Federal Agencies, FR Regulations & Notices

USCIS 60-Day Notice and Request for Comment on Proposed Revisions to Form I-212

USCIS 60-day notice and request for comment on proposed revisions to Form I-212, Application for Permission to Reapply for Admission into the United States after Deportation or Removal. Comments are due 6/20/23. (88 FR 23682, 4/18/23)

4/18/23 AILA Doc. No. 23041802. Removal & Relief
Practice Resources

Practice Pointer: Motions to Withdraw and Substitute Counsel

The EOIR Liaison Committee provides a practice pointer for attorneys moving to withdraw as counsel of record for cases pending in the EOIR system and respondents who may decide to change counsel.

4/17/23 AILA Doc. No. 23041701. Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds That IJ’s Consideration of Evidence Underlying Petitioner’s Expunged Charges Fell Within IJ’s Broad Discretion

The court held that the IJ did not err in concluding that the facts and circumstances surrounding the petitioner’s arrest, which included expunged criminal charges, presented serious adverse factors that worked against a favorable exercise of discretion. (Doyduk v. Att’y Gen., 4/14/23)

4/14/23 AILA Doc. No. 23042406. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Upholds BIA’s Finding That Petitioner Had Not Entered into Marriage in Good Faith

The court held that substantial evidence supported the agency’s finding that petitioner had not entered into his marriage in good faith, where the evidence showed a severely limited commingling of assets and a dubious commitment to the marriage by both parties. (Alzaben v. Garland, 4/14/23)

4/14/23 AILA Doc. No. 23042402. Family Immigration, Family-Based Immigrants, Removal & Relief
Practice Resources

Practice Alert: During Webex Hearings, All Parties Should be Clearly Visible on Camera

The EOIR Liaison Committee provides a practice alert on member concerns regarding judges having their courtroom cameras positioned in such a way that the judge’s face is not clearly visible during Webex hearings.

4/14/23 AILA Doc. No. 23041401. Removal & Relief
Practice Resources

Practice Alert: EOIR Specialized Dockets

The EOIR Liaison Committee provides a practice alert on EOIR’s clarification that every immigration court has specialized dockets and that practitioners may seek engagement with local EOIR to determine when specialized dockets occur at particular immigration courts.

4/14/23 AILA Doc. No. 23041403. Removal & Relief
Practice Resources

Practice Alert: Following Date and Time on NTA vs. Relying on ACIS/800#

The EOIR Liaison Committee provides a practice alert on member concerns on the Notice to Appear (“NTA”) that lists a hearing date and time and the 1-800 number used to determine whether they have a court hearing.

4/14/23 AILA Doc. No. 23041499. Removal & Relief
Practice Resources

Practice Alert: EOIR’s “Off Calendar” Notices

The EOIR Liaison Committee provides a practice alert on its “Off Calendar” initiative to address immigration court backlogs.

4/14/23 AILA Doc. No. 23041407. Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR to Host Series of Stakeholder Meetings Regarding Pre-Hearing Conferences

EOIR invites stakeholders to meet with assistant chief immigration judges to discuss pre-hearing conferences for immigration court matters. Register for EOIR’s Stakeholder listserv for those details coming soon. EOIR plans to host 28 meetings on this topic between April 17 and May 25, 2023.

4/13/23 AILA Doc. No. 23042001. Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Remands Asylum Claim of Ukrainian Petitioner After Finding That Agency’s Adverse Credibility Determination Relied on Legal Error

The court held that the IJ’s adverse credibility finding was not supported by substantial evidence and that the IJ unjustifiably refused to allow the petitioner to present readily available witness testimony, thereby depriving him of a full and fair hearing. (Malets v. Garland, 4/14/23)

4/12/23 AILA Doc. No. 23042404. Asylum & Refugees, Removal & Relief
Cases & Decisions, Amicus Briefs/Alerts

AILA and Partners Submit Amicus Brief on Child Endangerment Statutes

AILA and partners submitted an amicus brief to the Supreme Court in Diaz-Rodriguez v, Garland on whether child endangerment statutes qualify as crimes of "child abuse, child neglect, or child abandonment" under INA 237(a)(2)(E)(i) and urge the Court to grant certiorari in this case.

4/10/23 AILA Doc. No. 23060704. Removal & Relief
Federal Agencies, FR Regulations & Notices

Department of the Treasury Notice on Interest Rate for Immigration Bonds

Department of the Treasury notice that for the period beginning 4/1/23 and ending 6/30/23, the U.S. Immigration and Customs Enforcement Immigration Bond interest rate is 3 per centum per annum. (88 FR 20945, 4/7/23)

4/7/23 AILA Doc. No. 23040701. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

ICE Announces Online Tool for Noncitizens to Provide Change of Address

ICE announced an online change-of-address form for noncitizens that will give individuals the option to update their information online in addition to the existing options of doing so by phone or in-person.

4/6/23 AILA Doc. No. 23041206. Removal & Relief
Cases & Decisions, Federal Court Cases

CA11 Holds That Petitioner Had No Protected Liberty Interest in Discretionary Cancellation of Removal

The court held that the petitioner did not have a constitutionally protected liberty interest in cancellation of removal, and found that it lacked jurisdiction under INA §242(a)(2)(B)(i) to review the petitioner’s ineffective assistance of counsel claim. (Ponce Flores v. Att’y Gen., 4/5/23)

4/5/23 AILA Doc. No. 23053114. Cancellation, Suspension & 212(c), Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Finds It Lacks Subject-Matter Jurisdiction to Review Status-Adjustment Decisions by USCIS

The court held that status-adjustment decisions made by USCIS outside the context of removal proceedings are not final agency actions reviewable under the Administrative Procedure Act, nor are they final removal actions reviewable per the INA. (Elldakli, et al. v. Garland, et al., 4/4/23)

4/4/23 AILA Doc. No. 23053104. Adjustment of Status, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Finds BIA Did Not Err in Determining That Petitioner’s Brazilian Conviction Rendered Him Ineligible for Asylum and Other Relief

The court held that substantial evidence supported the BIA’s determination that the petitioner’s Brazilian conviction, which carried a sentence of more than seven years, constituted both an aggravated felony and a particularly serious crime. (Andrade-Prado, Jr. v. Garland, 4/4/23)

4/4/23 AILA Doc. No. 23042601. Asylum & Refugees, Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Upholds BIA’s Denial of Petitioner’s Second Motion to Reopen and Denies Parties’ Joint Request to Refer Case to Mediation

The court upheld the BIA’s denial of petitioner’s untimely and numerically barred second motion to reopen, and denied the parties’ joint request to send the case to mediation in order to put the appeal into abeyance while petitioner pursued other forms of relief. (Ayanian v. Garland, 4/3/23)

4/3/23 AILA Doc. No. 23053113. Removal & Relief