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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Association of Immigration Judges Says DOJ’s “Myths v. Facts” Fact Sheet Filled with Errors and Misinformation

On May 13, 2019, the National Association of Immigration Judges (NAIJ) responded to EOIR’s Myths vs. Fact memo issued on May 8, 2019. Their response outlines key assertions made in the EOIR memo that “mischaracterize or misrepresent the facts.”

5/13/19 AILA Doc. No. 19051334. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Says Second-Degree Assault Conviction in New York Is an Aggravated Felony Crime of Violence

The court denied the petition for review, finding that the petitioner’s conviction for second-degree assault in violation of New York Penal Law §120.05(1) was an aggravated felony crime of violence under INA §101(a)(43)(F) and 18 USC §16. (Thomson v. Barr, 5/13/19)

5/13/19 AILA Doc. No. 19052137. Crimes, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Terminates Proceedings Due to Lack of Affirmative DHS Opposition

Unpublished BIA decision terminates proceedings so respondent can pursue an adjustment of status application before USCIS in light of DHS’s lack of affirmative opposition. Special thanks to IRAC. (Matter of Abreha, 5/13/19)

5/13/19 AILA Doc. No. 20011301. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Reopens Proceedings Sua Sponte Under Dimaya for Deported Respondent

Unpublished BIA decision reopens and terminates proceedings sua sponte in light of Supreme Court decision finding 18 U.S.C. 16(b) unconstitutionally vague and notwithstanding respondent’s lawful removal to Mexico in the interim. Special thanks to IRAC. (Matter of Navarro, 5/13/19)

5/13/19 AILA Doc. No. 20011302. Crimes, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds Burning of Meeting House in Massachusetts Not a CIMT

Unpublished BIA decision holds that burning of a meeting house under Mass. Gen. Laws Ann. ch. 266 § 2 is not a CIMT because it applies to the owner setting fire to their own property. Special thanks to IRAC. (Matter of Rosa Pena, 5/10/19)

5/10/19 AILA Doc. No. 20011300. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Finds California Felony Conviction Reclassified as a Misdemeanor Retains Its Immigration Consequences

The court found that the petitioner’s felony conviction for possession of marijuana for sale in California rendered the petitioner removable, even though the conviction had been recalled and reclassified as a misdemeanor under California’s Proposition 64. (Prado v. Barr, 5/10/19)

5/10/19 AILA Doc. No. 19052138. Crimes, Removal & Relief

CRS Releases Legal Sidebar on Matter of M-S-

CRS released a Legal Sidebar on the statutes and regulations governing expedited removal and the detention of individuals placed in formal removal proceedings, including how the AG’s ruling in Matter of M-S- modified immigration authorities’ prior interpretation of these legal authorities.

Cases & Decisions, Federal Court Cases

CA2 Finds Conspiracy in the Second Degree in New York Is an Aggravated Felony

The court denied the petition for review, finding that the petitioner’s conviction for conspiracy in the second degree to commit a felony—namely, murder in the second degree—under New York law constitutes an aggravated felony. (Santana-Felix v. Barr, 5/9/19)

5/9/19 AILA Doc. No. 19051638. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Says It Lacks Jurisdiction to Review Prior Removal Order in Reinstatement Proceedings

The court dismissed the petition for review, holding that, under the plain language of 8 USC §1231(a)(5), it lacked jurisdiction to review the petitioner’s underlying 2005 removal order in the context of his reinstatement proceedings. (Villa v. Barr, 5/9/19)

5/9/19 AILA Doc. No. 19051642. Removal & Relief
Federal Agencies, Practice Resources

AILA Update: Feeing in a Motion with EOIR at a Local USCIS Office

AILA provides results from the recent call for examples survey concerning feeing in a motion with EOIR at local USCIS field offices, as well as updates on subsequent actions taken with both USCIS and the CIS Ombudsman’s office.

5/9/19 AILA Doc. No. 19050933. Removal & Relief

CRS Report on “Migrant Protection Protocols”: Legal Issues Related to DHS’s Plan to Require Arriving Asylum Seekers to Wait in Mexico

CRS provided an updated analysis of the Migrant Protection Protocol, discussing recent litigation, the rollout of the policy, expedited removal, statutory authority for the policy, and other legal issues.

Federal Agencies, FR Regulations & Notices

NARA Notice of Records Schedules Including USCIS Records on Notices to Appear

National Archives and Records Administration (NARA) notice and request for comments with proposed records schedules from agencies in which the agencies propose to dispose of certain records. This notice includes a USCIS records schedule relating to Notices to Appear. (84 FR 20166, 5/8/19)

5/8/19 AILA Doc. No. 19050830. Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Releases “Myths vs. Facts About Immigration Proceedings”

EOIR released a purposed “Myths vs. Facts About Immigration Proceedings” factsheet.

5/8/19 AILA Doc. No. 19051331. Asylum & Refugees, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

Immigration Judge Grants Motion to Reopen In Absentia Order of Removal

Immigration Judge finds that if a party does not receive Notice of Hearing and is removed in absentia, said party may re-open proceedings to hear the case on its merits. The court relied on lack of evidence produced by the government in coming to its conclusion. Courtesy of Roopal Patel.

5/8/19 AILA Doc. No. 19052135. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Rules in Favor of Government Where Asylum-Seeking Appellants Were Separated from Children and Deported

The court affirmed the district court’s judgment in favor of the government, holding that nothing in INA §235(b)(1)(A)(ii) prevents the government from initiating a criminal prosecution before or during the mandated asylum process. (United States v. Vasquez-Hernandez, et al., 5/8/19)

5/8/19 AILA Doc. No. 19092010. Asylum & Refugees, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds Offering to Transport Cocaine in California Not an Aggravated Felony

Unpublished BIA decision holds that offering to transport cocaine under Cal. Health & Safety Code 11352(a) is not an aggravated felony because solicitation offenses are not punishable under the Controlled Substances Act. Special thanks to IRAC. (Matter of Escobar, 5/7/19)

5/7/19 AILA Doc. No. 19121306. Crimes, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds Minnesota Threats of Violence Not a CIMT

Unpublished BIA decision holds that threat of violence under Minn. Stat. 609.713, subd. 1 is not a CIMT in light of the state court cases cited in Avendano v. Holder, 770 F.3d 731 (8th Cir. 2014). Special thanks to IRAC. (Matter of Osman, 5/7/19)

5/7/19 AILA Doc. No. 19121307. Crimes, Removal & Relief
Federal Agencies, FR Regulations & Notices

EOIR 60-Day Notice and Request for Comments on Form EOIR-26

EOIR 60-day notice and request for comments on proposed revisions to Form EOIR-26, Notice of Appeal From a Decision of an Immigration Judge. Comments are due 7/8/19. (84 FR 19960, 5/7/19)

5/7/19 AILA Doc. No. 19050730. Removal & Relief
Federal Agencies, FR Regulations & Notices

DHS Notice of Meeting of Homeland Security Advisory Council

DHS notice that the Homeland Security Advisory Council will meet in person in Washington, D.C. on 5/21/19. Part of the meeting will be open to the public. During the meeting, the council will receive an update from the Families and Children Care Panel subcommittee. (84 FR 19928, 5/7/19)

Cases & Decisions, Federal Court Cases

CA5 Finds BIA Did Not Err in Declining to Evaluate Reformulated PSG

The court affirmed the BIA’s order denying the petitioners’ applications for asylum and withholding of removal, finding that the BIA did not err by refusing to consider the petitioners’ reformulated particular social group (PSG) on appeal. (Cantarero-Lagos, et al., v. Barr, 5/6/19)

5/6/19 AILA Doc. No. 19051637. Asylum & Refugees, Removal & Relief
Federal Agencies, Agency Memos & Announcements

ICE Creates Program for Local Law Enforcement to Honor Immigration Detainers

ICE created the Warrant Service Officer (WSO) program designed for local law enforcement that wish to honor immigration detainers but are prohibited due to state/local policies that restrict cooperation. The new program is “limited in scope” but allows these jurisdictions to cooperate with ICE.

5/6/19 AILA Doc. No. 19050633. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Grants Motion to Change Venue Denied by IJ in Atlanta

Unpublished BIA decision grants change of venue from Atlanta to Los Angeles where IJ repeatedly denied prior motions in summary fashion and where respondent, her attorney, and all witnesses resided in California. Special thanks to IRAC. (Matter of Padilla, 5/6/19)

5/6/19 AILA Doc. No. 19121305. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Vacates Denial of Cancellation of Removal Because DHS Did Not Oppose Grant of Relief

Unpublished BIA decision states that “[w]hen DHS gives notice to the court that it does not oppose a grant of a requested form of relief, that relief ordinarily should be granted absent a compelling reason not do to so.” Special thanks to IRAC. (Matter of I-S-M-H-, 5/3/19)

5/3/19 AILA Doc. No. 19121304. Cancellation, Suspension & 212(c), Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Finds Honduran Boy Should Have Been Advised of Apparent Eligibility for SIJ Status

The court granted the petition for review and remanded, concluding that the IJ erred by failing to advise the 14-year-old Honduran petitioner that he was an at-risk child potentially eligible for relief as a Special Immigrant Juvenile (SIJ). (C.J.L.G. v. Barr, 5/3/19)

5/3/19 AILA Doc. No. 19050912. Removal & Relief, Special Immigrant Juveniles
Cases & Decisions, Federal Court Cases

CA2 Finds Petitioner Convicted of Third-Degree Burglary in Connecticut Is No Longer Subject to Removal Proceedings

The court held that petitioner was no longer subject to removal proceedings in light of the Supreme Court’s ruling in Sessions v. Dimaya, because the basis for his removal was the finding that his conviction was a crime of violence as defined in 18 USC §16(b). (Genego v. Barr, 5/2/19)

5/2/19 AILA Doc. No. 19050911. Crimes, Removal & Relief