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An unpublished ICE memo from acting ICE Director Caleb Vitello entitled “Interim Guidance: Civil Immigration Enforcement Actions in or near Courthouses” makes reference to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

AILA's Enforcement Tracker

AILA’s Enforcement Tracker gathers reports of immigration enforcement actions across the United States in one location.

1/13/26 AILA Doc. No. 26011503. Employer Compliance, Removal & Relief
Accessible to: Member, Student, Paralegal.
Examples & Questions

Enforcement Tracker - Form

Use this form to report enforcement actions, including both arrests and worksite enforcement. Information will immediately be made available to AILA members on AILA’s Enforcement Tracker.

1/13/26 AILA Doc. No. 26011603. Employer Compliance, Removal & Relief
Accessible to: Member, Student, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That Death Threats Alone Rarely Constitute Persecution and Require Objective Credibility and Immediate Ability to Carry Out

The BIA held that death threats alone rarely rise to the level of persecution and only do so if they are objectively credible and issued by a person or persons with the immediate ability to carry them out. Matter of E–M–F–S–, et al., 29 I&N Dec. 379 (BIA 2026)

1/9/26 AILA Doc. No. 26011202. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA8 Upholds Asylum Denial as to Guatemalan Domestic Violence Survivor Based on Lack of Nexus

The court held that the Guatemalan petitioner, who alleged domestic abuse by her former partner, failed to establish a nexus between the abuse and a protected ground, and did not show a likelihood of torture with government acquiescence. (Aguilar-Hernandez, et al. v. Bondi, 1/6/26)

1/6/26 AILA Doc. No. 26011203. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA11 Upholds Denial of CAT Relief to Colombian Petitioner Alleging Harm by FARC

The court held that substantial evidence supported the denial of Convention Against Torture (CAT) relief and that the BIA did not err in rejecting the petitioner’s ineffective assistance of counsel claim pursuant to Matter of Lozada. (Gutierrez-Mikan, et al. v. Att’y Gen., 1/5/26)

1/5/26 AILA Doc. No. 26011204. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Federal Agencies, AILA Announcements

EOIR Policy Memorandum (PM 26-01) on the Annual Asylum Fee

EOIR Director issued Policy Memorandum 26-01 on the annual asylum fee. EOIR will waive the fee for asylum applications that were pending for one year or more 4/5/25-9/30/25 and administratively final as of 9/30/25. EOIR will apply the fee to applications pending for one year or more as of 10/1/25.

1/2/26 AILA Doc. No. 26010603. Asylum & Refugees, Removal & Relief
Accessible to Public.
Examples & Questions

Enforcement Tracker - Feedback Form

Use this form to update an item that was previously submitted to AILA’s Enforcement Tracker or to provide feedback, report inaccurate information, or request further information as a member of AILA chapter leadership in relation to the Enforcement Tracker.

1/1/26 AILA Doc. No. 26011605. Employer Compliance, Removal & Relief
Accessible to: Member, Student, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Finds IJ Erred in Continuing Proceedings Where Respondent Failed to Appear After Proper Notice and Where DHS Established Removability

The BIA held that where the respondent did not appear at a hearing, was properly served with notice, and DHS provided evidence of their removability, the IJ erred in continuing proceedings rather than entering an in absentia removal order. Matter of Laurent Castro, 29 I&N Dec. 419 (BIA 2026)

12/30/25 AILA Doc. No. 26012902. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA1 Upholds Asylum Denial as to Guatemalan Petitioners Who Were Targeted for Extortion

The court held that substantial evidence supported the denial of asylum and related relief, finding that the Guatemalan petitioners were targeted for criminal extortion rather than a protected ground and could reasonably relocate within Guatemala. (Ramos-Hernandez, et al. v. Bondi, 12/22/25)

12/22/25 AILA Doc. No. 25122931. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA5 Holds Texas Indecency with a Child Conviction Was Categorically a Crime of Child Abuse

The court held that the petitioner’s Texas conviction for indecency with a child by sexual contact was categorically a “crime of child abuse” under INA §237(a)(2)(E)(i), and found that statutory authentication methods for conviction records are not exclusive. (Campuzano v. Bondi, 12/22/25)

12/22/25 AILA Doc. No. 25122932. Crimes, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA9 Upholds Asylum Denial After Finding Nicaraguan Petitioner’s Childhood Trauma Did Not Excuse Untimely Filing

The court held that it had jurisdiction to review the BIA’s extraordinary circumstances determination, but found that substantial evidence supported the BIA’s conclusion that childhood trauma did not excuse the petitioner’s 13-year delay in filing for asylum. (Ruiz v. Bondi, 12/22/25)

12/22/25 AILA Doc. No. 25122933. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA4 Finds BIA Abused Its Discretion by Ignoring Evidence That Honduras Was Unable or Unwilling to Control MS-13

The court held that the BIA abused its discretion when it ignored credible, unrebutted, and legally significant evidence in the record and concluded that petitioner failed to demonstrate that the Honduran government was unable or unwilling to control MS-13. (Ramos Marquez v. Bondi, 11/19/25)

12/19/25 AILA Doc. No. 25120101. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Finds IJ Did Not Err in Terminating Proceedings Without Prejudice Where DHS Did Not Appear or Present Evidence of Removability

The BIA held that where neither the respondent nor DHS appears at the hearing and DHS does not present evidence of removability in advance of the hearing, the IJ does not err in terminating proceedings without prejudice. Matter of Tepec-Garcia, et al., 29 I&N Dec. 371 (BIA 2025)

12/19/25 AILA Doc. No. 25122231. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Federal Agencies, Agency Memos & Announcements

EOIR Announces New Appellate Immigration Judge

EOIR announced the investiture of Appellate Immigration Judge Roman Marian Chaban who was sworn in on 12/19/25. Judge Chaban previously served as EOIR Acting Deputy Director.

12/19/25 AILA Doc. No. 25122235. Removal & Relief
Accessible to Public.
Cases & Decisions, DOJ/EOIR Cases

BIA Finds Firm Resettlement Bar Applied Where Nepalese Respondent Had Indefinite Rights to Live and Work in India

The BIA held that evidence that a respondent had a legal right to enter, live, work, and own property indefinitely in the country of proposed resettlement demonstrates that the respondent was offered “some other type of permanent resettlement.” Matter of L–T–A–, 29 I&N Dec. 362 (BIA 2025)

12/18/25 AILA Doc. No. 25121961. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA5 Grants Government’s Motion to Summarily Deny Petition for Review as Untimely under INA §242(b)(1)

The court held that the petition was untimely under INA §242(b)(1), that the 30-day filing deadline is a mandatory claim-processing rule, that the government did not waive its timeliness objection, and that the prison mailbox rule did not render the petition timely. (Liao v. Bondi, 12/17/25)

12/17/25 AILA Doc. No. 25122432. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, DOJ/EOIR Cases

BIA Reinstates Matter of Laparra and Holds Compliant Notice of Hearing Supports In Absentia Order Despite Defective NTA

The BIA held that Matter of Laparra is reinstated in the First Circuit and is good law in circuits without contrary precedent, finding that a compliant notice of hearing supports an in absentia removal order despite a defective NTA. Matter of Laparra-Deleon, 29 I&N Dec. 389 (BIA 2026)

12/17/25 AILA Doc. No. 26011561. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA6 Finds Petitioner Failed to Exhaust Challenge to Numerical Bar on Second Motion to Reopen

The court held that the petitioner failed to exhaust her challenge to the IJ’s determination that her second motion to reopen was numerically barred, and found that it lacked jurisdiction to review the BIA’s discretionary refusal to reopen proceedings sua sponte. (Herrera v. Bondi, 12/15/25)

12/15/25 AILA Doc. No. 25121761. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA6 Upholds Asylum and Withholding Denial as to Honduran Petitioner Who Was Targeted by MS-13

The court held that it lacked jurisdiction to review the denial of the petitioner’s untimely asylum application and dismissed his withholding of removal claim, finding that he failed to exhaust the issue of government protection from gang violence. (Osabas-Rivera v. Bondi, 12/8/25)

12/8/25 AILA Doc. No. 25121503. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA1 Upholds Asylum Denial as to Peruvian Survivor of Domestic Violence Based on Lack of Nexus and Speculative Future Harm

The court held that substantial evidence supported the denial of asylum, withholding, and CAT relief as to the petitioner, a Peruvian survivor of domestic violence, finding there was no nexus to a protected ground and a speculative fear of future torture. (De La Cruz-Quispe v. Bondi, 12/5/25)

12/5/25 AILA Doc. No. 25121502. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Cases & Decisions, Federal Court Cases

CA5 Holds That Petitioner’s New Mexico Child Abuse Conviction Was a “Crime of Child Abuse” under the INA

The court held that the petitioner’s New Mexico child abuse conviction was categorically a “crime of child abuse” under INA §237(a)(2)(E)(i), and that his state conviction for aggravated assault with a deadly weapon was an aggravated felony under the INA. (Silva de Santiago v. Bondi, 12/4/25)

12/4/25 AILA Doc. No. 25121106. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Featured Issues

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

The U.S. immigration court system plays a critical role in ensuring due process and fair hearings for people facing deportation. But the Trump Administration has made significant changes that challenge the integrity of these courts. On this page, you will find news and resources on these changes.

Accessible to Public.
Cases & Decisions, Federal Court Cases

CA9 Denies Motion to Stay Removal Where Petitioners Failed to Show Likelihood of Success or Irreparable Harm

The court denied the petitioners’ motion for a stay of removal pending disposition of their petition for review, finding they failed to show a likelihood of success on their asylum and related claims or particularized irreparable harm. (Rojas-Espinoza v. Bondi, 10/24/25, amended 11/25/25)

12/3/25 AILA Doc. No. 25102803. Asylum & Refugees, Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Congressional Updates

AILA Endorses The Temporary Immigration Judge Integrity Act

Sen. Adam Schiff (D-CA) and Rep. Juan Vargas (CA-52) introduced the Temporary Immigration Judge Integrity Act. This proposed bill would ensure temporary immigration judges have essential expertise in immigration law to enhance the fairness and accuracy of adjudications. AILA endorses this bill.

12/3/25 AILA Doc. No. 25120301. Removal & Relief
Accessible to Public.
Cases & Decisions, Federal Court Cases

CA6 Finds BIA Abused Its Discretion in Rejecting Petitioners’ Brief Based on Address Discrepancy and Summarily Dismissing Appeal

The court held that the BIA abused its discretion by rejecting petitioners’ brief because it listed an address for their attorney that was different from the address on the attorney’s notice of appearance and then summarily dismissing their appeal. (Pineda-Guerra, et al. v. Bondi, 12/3/25)

12/3/25 AILA Doc. No. 25121105. Removal & Relief
Accessible to: Member, Student, Govt/Policy, Paralegal.
Accessible to Public.