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

Browse the Featured Issue: U.S. Immigration Courts under Trump 2.0 collection
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Cases & Decisions, Federal Court Cases

CA9 Finds Petitioner’s Conviction for Arson in California Was Not an Aggravated Felony

The court held that arson in violation of California Penal Code (CPC) §451 was not a categorical match to its federal counterpart, and thus that the petitioner’s conviction under CPC §451(b) was not an aggravated felony that rendered him removable. (Togonon v. Garland, 1/10/22)

1/10/22 AILA Doc. No. 22020331. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Finds BIA Abused Its Discretion in Denying Continuance to Petitioner with Pending U Visa Application

Where the petitioner had a pending U visa application, the court held that the BIA abused its discretion in denying his motion for a continuance, finding that the BIA had departed from precedential opinions in holding that he had failed to show good cause. (Garcia Cabrera v. Garland, 1/6/22)

1/6/22 AILA Doc. No. 22013111. Asylum & Refugees, 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 1/1/22, and ending 3/31/22, the U.S. Immigration and Customs Enforcement Immigration Bond interest rate is 0.06 per centum per annum. (87 FR 802, 1/6/22)

1/6/22 AILA Doc. No. 22010602. Detention & Bond, Removal & Relief
Professional Resources

Get Ready for Mandatory E-Filing with EOIR, Starting February 2022

EOIR has announced e-filing will become mandatory for all lawyers practicing before EOIR effective February 11, 2022. Mandatory e-filing comes with important changes that can help you get the work done, if you are ready for them. Get prepared with this tip from the Practice & Professionalism Center.

1/6/22 AILA Doc. No. 22010600. Practice Management, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Finds That “Prosecution Witnesses” Is Not a PSG

The court agreed with the BIA that the Honduran petitioner’s proposed particular social group (PSG) of “prosecution witnesses” lacked particularity, and found no error in the BIA’s decision upholding the IJ’s adverse credibility finding as to petitioner. (Herrera-Martinez v. Garland, 1/5/22)

1/5/22 AILA Doc. No. 22013105. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Upholds Withholding of Removal Denial to Petitioner with Felony Assault Conviction

The court affirmed the BIA’s determination that petitioner’s felony assault conviction was a particularly serious crime rendering him ineligible for withholding of removal, because he had failed to show how the alleged errors compelled reversal. (Aviles-Tavera v. Garland, 1/4/22)

1/4/22 AILA Doc. No. 22013113. Asylum & Refugees, Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Withdraws Prior Opinion and Issues Substitute Opinion in Parada-Orellana v. Garland

The court denied the petitioner’s petition for panel rehearing, withdrew its prior panel opinion of 8/6/21, and held that the BIA did not abuse its discretion by applying an incorrect legal standard when it denied petitioner's motion to reopen. (Parada-Orellana v. Garland, 1/3/22)

1/3/22 AILA Doc. No. 22013112. Removal & Relief

DHS OIG Report on ICE’s Medical Center at Irwin County Detention Center

DHS’s OIG reported that the medical processes and communication protocols at Irwin County Detention Center need improvement, as facility employees, ICE staff, and detainees were not kept consistently informed of COVID-19 protocols. DHS OIG made five recommendations; four are now closed.

1/3/22 AILA Doc. No. 22010604. Detention & Bond, Removal & Relief
AILA Blog

Custody Redetermination Hearings and Material Change in Circumstances

AILA Law Journal author Matthew Boles shares some insights about researching and writing about custody redetermination and why he hopes his AILA Law Journal article on the subject can help other practitioners across the country advocate in front of immigration judges.

12/30/21 Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Declines to Rehear Bogle v. Garland En Banc

The court issued an order denying the rehearing en banc of Bogle v. Garland, in which the court held that the circumstance-specific approach applies to the 30-gram limit of INA §237(a)(2)(B)(i)’s personal-use exception. (Bogle v. Garland, 12/29/21)

12/29/21 AILA Doc. No. 22012101. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Vacates District Court’s Class-Wide Injunction in Case Challenging Bond Procedures Under INA §236A

In a class action challenging bond procedures used to detain noncitizens during the pendency of removal proceedings under INA §236A, the court held that the district court lacked jurisdiction to issue an injunction in favor of the class. (Pereira Brito, et al. v. Garland, et al., 12/28/21)

12/28/21 AILA Doc. No. 22011207. Detention & Bond, Removal & Relief
Federal Agencies, FR Regulations & Notices

Third Delay of Effective Date of Final Rule on Pandemic-Related Security Bars to Asylum and Withholding of Removal

USCIS and EOIR interim final rule further delaying until 12/31/22 the effective date of the final rule “Security Bars and Processing” (85 FR 84160, 12/23/20). Comments on the extension of the effective date as well as the possibility of a further extension are due 2/28/22. (86 FR 73615, 12/28/21)

12/28/21 AILA Doc. No. 21122833. Asylum & Refugees, Expedited Removal, Removal & Relief
Cases & Decisions, Amicus Briefs/Alerts

AILA and Partners Submit Amicus Brief on the Interpretation of Child Endangerment

AILA and partners submitted a brief in Marquez v. Garland arguing that the Board’s interpretation reading of child abuse, child neglect, and child abandonment encompasses negligent child-endangerment and is overboard; thereby, the court should grant the petition for rehearing en banc.

12/27/21 AILA Doc. No. 22032432. Crimes, Removal & Relief
Federal Agencies, Practice Resources

CLINIC Provides Comparison Table of Prior and Current Versions of EOIR’s Immigration Court Practice Manual

CLINIC provides a comparison table that briefly summarizes some of the key changes between the prior version of the EOIR Immigration Court Practice Manual, published in February 2008, and the current version, released in December 2020.

12/23/21 AILA Doc. No. 22020101. Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Reinstates IJ’s Grant of CAT Relief to Guatemalan Petitioner Where BIA Exceeded Its Proper Scope of Review

Where the BIA had reversed the IJ’s decision granting the Guatemalan petitioner Convention Against Torture (CAT) relief, the court held that BIA erred by inserting itself into the factfinder role and disagreeing with the IJ’s weighing of the evidence. (Arreaga-Bravo v. Att’y Gen., 12/23/21)

12/23/21 AILA Doc. No. 21110304. Asylum & Refugees, Removal & Relief
Federal Agencies, Practice Resources

Practice Alert: EOIR Provides Rotating IJ Schedules Through Regional Public Information Officers

EOIR has resumed providing rotating schedules for immigration judges through its regional public information officers.

12/23/21 AILA Doc. No. 21020805. Removal & Relief

CRS Provides Year-End Report on Apprehensions and Expulsions at the Southwest Border

CRS provided the FY2021 report on apprehensions and expulsions at the southwest border. The report includes current border enforcement policies, encounters by demographic category, encounters by country of citizenship, and more.

12/22/21 AILA Doc. No. 21122838. Admissions & Border, Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds Congolese Asylum Seeker’s Fear of Returning to the DRC Was Objectively Reasonable

Granting the petition for review, the court held that the record compelled a finding that the risks petitioner faced upon return to the Democratic Republic of the Congo were sufficient to give rise to an objectively reasonable fear of future persecution. (Nsimba v. Att’y Gen., 12/22/21)

12/22/21 AILA Doc. No. 22011831. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Holds That “An Offense” in INA §240A(b)(1)(C) Includes “Multiple Criminal Convictions” Described in INA §212(a)(2)(B)

Denying the petition for review, the court held that the phrase “an offense” in the cancellation of removal statute at INA §240A(b)(1)(C) includes the “[m]ultiple criminal convictions” described in INA §212(a)(2)(B) that render a noncitizen inadmissible.(Ramirez-Medina v. Garland, 12/22/21)

12/22/21 AILA Doc. No. 22012133. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Concludes That Petitioner’s Two Arizona Convictions for Marijuana-Related Offenses Were Not CIMTs

The court held that Arizona Revised Statutes §13-3405(A)(4) was overbroad and divisible and that petitioner’s convictions, which concerned categories in the statute involving the smallest quantity of marijuana, were not crimes involving moral turpitude (CIMTs). (Walcott v. Garland, 12/22/21)

12/22/21 AILA Doc. No. 22012131. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Finds That BIA Sufficiently Considered Petitioner’s CAT Claim and Provided Adequate Rationale for Its Rejection

The court held that the BIA had sufficiently considered the relevant record evidence regarding the petitioner’s claim for deferral of removal under the Convention Against Torture (CAT) and had provided an adequate rationale for rejecting that claim. (Rodriguez-Jimenez v. Garland, 12/21/21)

12/21/21 AILA Doc. No. 22012132. Asylum & Refugees, Removal & Relief
Federal Agencies, Agency Memos & Announcements

DHS Releases Statement on Seeking Support Regardless of Immigration Status After Severe Weather in the South and Midwest

DHS announced it is monitoring areas affected by the severe weather and tornadoes in Kentucky and throughout the South and Midwest, stating that sites that provide emergency response and relief are considered protected areas for purposes of ICE and CBP enforcement actions.

12/21/21 AILA Doc. No. 21122137. Removal & Relief
Federal Agencies, Agency Memos & Announcements

DHS Announces Use of Body Worn Cameras in New ICE Pilot Program

DHS announced that ICE law enforcement officers in select cities will begin wearing body worn cameras for pre-planned operations. The body worn camera will be mounted on an officer’s or agent’s outerwear. Footage may be used to assess police conduct and for non-investigative purposes.

12/21/21 AILA Doc. No. 21122332. Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds It Lacks Jurisdiction to Review BIA’s Decision Not to Waive Limitations Period for VAWA-Based Motion to Reopen

The court concluded that it lacked jurisdiction to review the petitioner’s Violence Against Women Act (VAWA)-based motion to reopen, finding that the BIA’s decision not to waive the one-year limitations period for filing the motion was a discretionary one. (Yasin v. Att’y Gen., 12/20/21)

12/20/21 AILA Doc. No. 22011833. Humanitarian Parole, Removal & Relief, VAWA
Federal Agencies, Agency Memos & Announcements

EOIR Updates Number of Board Members in Part III of the Policy Manual

EOIR updated Part III, Chapter 1.3 of the EOIR Policy Manual to state that the board consists of 23 members, including a Chairman and up to two Vice Chairmen.

12/20/21 AILA Doc. No. 22010700. Removal & Relief