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.

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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An unpublished ICE memo from acting ICE Director Caleb Vitello entitled “Interim Guidance: Civil Immigration Enforcement Actions in or near Courthouses” makes reference to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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Cases & Decisions, Federal Court Cases

CA6 Holds That Cancellation Hardship Determinations Are to Be Reviewed under IIRAIRA Substantial Evidence Standard

The court held that cancellation-of-removal hardship determinations are to be reviewed under the IIRAIRA substantial evidence standard and that the Guatemalan petitioner did not establish exceptional and extremely unusual hardship. (Baltazar Us v. Blanche, 4/29/26)

AILA Doc. No. 26050865. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Practice Resources

Practice Alert: Circumvention of Lawful Pathways (CLP) Rule Vacated May 7, 2026

On May 7, 2026, the U.S. District Court for the Northern District of California in East Bay Sanctuary Covenant v. Trump vacated the Circumvention of Lawful Pathways (CLP) rule which was promulgated by the Department of Homeland Security in May 2023.

5/8/26 AILA Doc. No. 26050805. Admissions & Border, Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Paralegal.

Client Flyers

AILA offers concise educational flyers for members to share with their clients or prospective clients to inform them about a wide range of pertinent immigration law issues. Customizable versions are available.

Accessible to Public.
Federal Agencies, FR Regulations & Notices

ICE NPRM Increasing Fee for Form I-246, Application for a Stay of Deportation or Removal

ICE notice of proposed rulemaking that would increase the fee for adjudicating Form I-246, Application for a Stay of Deportation or Removal, from $155 to $755, representing a 387% increase. Comments are due 7/6/26. (91 FR 24739, 5/7/26)

5/7/26 AILA Doc. No. 26050701. Removal & Relief
Accessible to Public.
Cases & Decisions, DOJ/EOIR Cases

BIA Finds No Clear Probability of Torture or Government Acquiescence in Mexico Based on Speculative and Generalized Evidence

The BIA held that the respondent did not establish eligibility for CAT protection because he failed to show a clear probability of harm rising to the level of torture by gang or cartel members and did not show government acquiescence to torture. Matter of J–E–L–, 29 I&N Dec. 605 (BIA 2026)

5/4/26 AILA Doc. No. 26050534. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Agency Memos & Announcements, Federal Agencies

EOIR Announces Closure of San Francisco Immigration Court After 9/4/26

EOIR announced it will close the San Francisco Immigration Court at the close of business on 9/4/26 and make its Sansome Street location a hearing location under the Concord Immigration Court's adminstrative control. EOIR will issue new hearing notices for all cases reassigned to the Concord court.

5/1/26 AILA Doc. No. 26050400. Removal & Relief
Accessible to Public.
Cases & Decisions, Federal Court Cases

CA1 Upholds Petitioner’s Removability for Fraud and Denial of Relief Based on Serious Nonpolitical Crime Bar

The court held that the petitioner was removable for fraud and willful misrepresentation and failed to establish eligibility for asylum, withholding of removal, or Convention Against Torture (CAT) protection. (Usma Acosta v. Blanche, 5/1/26)

5/1/26 AILA Doc. No. 26050862. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Practice Resources

Practice Alert: New Immigration Fees Authorized by the Reconciliation Bill

USCIS has published an Interim Final Rule codifying the collection of fees and other provisions for asylum, Form I-94, temporary protected status, and employment authorization documents. This alert will continue to be updated with any new details provided.

Accessible to: Member, Student, Govt/Policy, Paralegal, International Associate.
Cases & Decisions, Federal Court Cases

CA7 Finds Niz-Chavez Does Not Warrant Equitable Tolling of Motion-to-Reopen Deadline

The court found petitioner was not entitled to equitable tolling based on Niz-Chavez v. Garland, where the asserted defect in the Notice to Appear (NTA) was apparent at the time of the original proceedings and petitioner failed to act diligently. (Coatl-Chiquito v. Blanche, 4/30/26)

4/30/26 AILA Doc. No. 26050802. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Holds IJ Must Enter In Absentia Order and Lacks Authority to Administratively Close Proceedings Where Respondent Fails to Appear

The BIA held that when respondents, including minors, fail to appear and DHS has established proper notice and removability, the IJ lacks authority to administratively close proceedings and must enter an in absentia removal order. Matter of Orozco Becerra, 29 I&N Dec. 600 (BIA 2026)

4/29/26 AILA Doc. No. 26050401. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA6 Upholds Denial of Motion to Reopen Where Petitioner Failed to Identify Specific Interpreter Errors

The court held that the petitioner did not establish grounds to reopen his removal proceedings based on alleged interpreter errors where he failed to identify specific mistranslations or show prejudice. (Deh v. Blanche, 4/29/26)

4/29/26 AILA Doc. No. 26050863. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA6 Holds That Petition-for-Review Deadline Is Subject to Equitable Tolling but Dismisses Petition as Untimely

The court held that the 30-day deadline to file a petition for review under INA §242(b)(1) is subject to equitable tolling, but found that the petitioner was not entitled to tolling on the record and thus dismissed the petition as untimely. (Oxlaj-Perez v. Blanche, 4/29/26)

4/29/26 AILA Doc. No. 26050800. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA7 Holds That Failure to Appear Was Not Due to Exceptional Circumstances Where Petitioner Failed to Notify the Court

The court held that the petitioner did not establish exceptional circumstances under INA §240(b)(5)(C), where his failure to appear resulted from financial hardship and transportation difficulties rather than exceptional circumstances beyond his control. (Nimaga v. Blanche, 4/29/26)

4/29/26 AILA Doc. No. 26050804. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Immigration News

AILA Law Journal, Vol. 8, Number 1, April 2026

The April 2026 edition of the AILA Law Journal is now available.

Accessible to: Member, Student, Paralegal.
Practice Resources

Practice Alert: AILA Tracking Detentions at USCIS Biometrics Appointments

AILA is tracking increased reports of detentions at USCIS biometrics appointments.

Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That FBI Memorandum Indicating Respondent Is National Security Risk Warrants Significant Weight in Bond Proceedings

The BIA held that an FBI Letterhead Memorandum indicating that the respondent is a potential national security risk warrants significant weight in bond proceedings, and ordered the respondent detained without bond. Matter of Shentu, 29 I&N Dec. 595 (BIA 2026)

4/27/26 AILA Doc. No. 26042804. Detention & Bond, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That IJ Erred in Terminating Proceedings Based Solely on DACA Receipt Without Considering Opposition to Termination

The BIA held that the IJ erred in terminating removal proceedings based solely on the fact that respondent had been accorded Deferred Action for Childhood Arrivals (DACA) and without considering reasons for any opposition to termination. Matter of Santiago-Santiago, 29 I&N Dec. 589 (BIA 2026)

4/24/26 AILA Doc. No. 26042703. DACA, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA1 Holds That There Is No Categorical Bar to Political Opinion Claims Based on Opposition to Gangs

Granting the petition for review and remanding, the court held that the BIA erred in applying a categorical rule that opposition to gangs cannot constitute a political opinion and failed to adequately address the petitioner’s religion-based asylum claim. (Lopez Martinez v. Blanche, 4/23/26)

4/23/26 AILA Doc. No. 26050404. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That Political Opinion Must Be Tied to Government and That Opposition to Gangs Is Insufficient

The BIA held that to establish a political opinion under the INA, a noncitizen must have an actual or imputed belief or conviction regarding a discrete cause tied to a government, and that opposition to criminal gangs is insufficient. Matter of D–G–E–A– & N–G–G–E–, 29 I&N Dec. 570 (BIA 2026)

4/21/26 AILA Doc. No. 26042262. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA4 Holds Matter of K– Does Not Apply Where Petitioner Admits Drug Offenses in Seeking Cancellation of Removal

The court held that Matter of K– does not apply where a petitioner, represented by counsel, admits to controlled substance offenses under oath in seeking cancellation of removal, and that such admissions preclude a finding of good moral character. (Sandoval Diaz v. Blanche, 4/20/26)

4/20/26 AILA Doc. No. 26042800. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Amicus Briefs/Alerts

AILA and NIJC Argue Immigration Judges Must Develop the Record

AILA and the National Immigrant Justice Center (NIJC) filed an amici brief outlining immigration judges’ affirmative duty to develop the record in removal proceedings and how this duty applies to pro se respondents and cases where counsel’s performance falls below minimum professional standards.

AILA Doc. No. 26041739. Removal & Relief
Accessible to: Member.
Cases & Decisions, Federal Court Cases

CA1 Reverses Denial of Adjustment to Venezuelan Petitioner Where BIA Engaged in Impermissible Factfinding

The court reversed and remanded, holding that the BIA engaged in impermissible factfinding by relying on a factual determination not supported by the record in reversing the IJ’s grant of adjustment of status to the Venezuelan petitioner. (Taveras Martínez v. Blanche, 4/17/26)

4/17/26 AILA Doc. No. 26042708. Adjustment of Status, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA4 Holds That North Carolina PJC with Community Service Constituted Conviction under INA §101(a)(48)(A)

The court held that the petitioner’s North Carolina Prayer for Judgment Continued (PJC) conditioned on community service constituted a conviction under INA §101(a)(48)(A) rendering him ineligible for cancellation of removal based on two CIMT convictions. (Gardner v. Blanche, 4/14/26)

4/14/26 AILA Doc. No. 26042301. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA7 Finds That Petitioner Failed to Show Exceptional and Extremely Unusual Hardship and That BIA Did Not Abuse Discretion in Denying Reopening

The court held that the petitioner failed to establish exceptional and extremely unusual hardship for cancellation of removal under INA §240A(b)(1) and found that the BIA did not abuse its discretion in denying his motion to reopen his removal proceedings. (Petrov v. Blanche, 4/14/26)

4/14/26 AILA Doc. No. 26042302. Cancellation, Suspension & 212(c), Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Holds IJs Must Conduct In Absentia Hearing Where Record Contains Evidence of Alienage Despite DHS Nonappearance

The BIA held that where respondent is charged as present without admission or parole, neither party appears, and the record contains evidence of alienage, the IJ errs in terminating proceedings instead of conducting an in absentia hearing. Matter of Bolivar-Bolivar, 29 I&N Dec. 548 (BIA 2026)

4/10/26 AILA Doc. No. 26041363. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Accessible to Public.