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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TRAC Finds Lawsuits Challenging Confinement of Noncitizens Increasing

TRAC found that habeas corpus filings in federal courts challenging the confinement of noncitizens continue to rise. The latest available data show that during August 2018 the government reported 174 new habeas corpus civil filings by noncitizens. This is up 27.9 percent over the previous month.

9/20/18 AILA Doc. No. 18092032. Detention & Bond, Removal & Relief

AILA Quicktake #251: Attorney General's Decision in Matter of S-O-G- & F-D-B-

AILA's Associate Director of Government Relations Kate Voigt discusses the Attorney General's decision in Matter of S-O-G- & F-D-B-, which limits the ability of immigration judges to terminate cases. Join fellow AILA members in signing a petition calling for independent immigration courts.

9/20/18 AILA Doc. No. 18092037. Removal & Relief
AILA Public Statements, Press Releases

Attorney General’s Concerted Effort to Strip Immigration Judges of Judicial Independence Continues

In response to the AG's decision in Matter of S-O-G- & F-D-B-, which will prevent judges from terminating a case except in exceptionally narrow circumstances and waste the court's time and resources, AILA again called on Congress to create an independent Article I immigration court.

9/19/18 AILA Doc. No. 18091938. Removal & Relief

CRS Publishes Report on the Legal Framework of Expedited Removal of Noncitizens

The Congressional Research Service (CRS) published a report on the expedited removal of noncitizens and its legal framework.

9/19/18 AILA Doc. No. 18100803. Expedited Removal, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Remands, Holds Prima Facie Case Made to Exclude Evidence and Terminate Removal Proceedings Due to Egregious Violation of 8 CFR 287.8(b)(2)

The court found I-213 excludable because Coast Guard racially profiled and detained petitioner with no reasonable suspicion; confirmed prima facie case for termination without prejudice because violation predated any hearing, rendering new hearing insufficient. (Sanchez v. Sessions, 9/19/18)

9/19/18 AILA Doc. No. 18102301. Admissions & Border, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Orders En Banc Rehearing of C.J.L.G. v. Sessions

The court ordered that C.J.L.G. v. Sessions, in which the three-judge panel found no categorical right to court-appointed counsel at government expense for minors in immigration proceedings, be reheard en banc. (C.J.L.G. v. Sessions, 9/19/18)

9/19/18 AILA Doc. No. 18121736. Removal & Relief, Special Immigrant Juveniles
Cases & Decisions, DOJ/EOIR Cases

BIA Finds Returning LPR Was Not Seeking Admission Based on Pre-IIRIRA Conviction

Unpublished BIA decision holds that returning LPR was improperly regarded as applicant for admission based on pre-IIRIRA conviction and remands to consider whether trip abroad was innocent, casual, and brief. Special thanks to IRAC. (Matter of Suero, 9/19/18)

9/19/18 AILA Doc. No. 19071204. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Holds Petitioner Failed to Prove Lozada Claims and Rejects Argument that Ineffective Assistance Implicates Due Process

The court held it had no jurisdiction to review sham marriage determination; BIA was correct that Lozada challenge failed; and refused to link ineffective assistance to 5th Amendment due process violation. (Al-Saka v. Sessions, 9/18/18)

ICE Issues Statement to Senate Committee on Flores Settlement

ICE Executive Associate Director Matthew T. Albence issued a statement to the Senate Homeland Security and Governmental Affairs Committee on reinterpretation of Flores settlement and its impact on family separation and “catch and release.”

9/18/18 AILA Doc. No. 18092138. Congress, Detention & Bond, Removal & Relief

GAO Statement on Progress and Challenges in the Management of Immigration Courts and Alternatives to Detention Program

The GAO issued a statement before the Senate Homeland Security and Governmental Affairs Committee, addressing EOIR’s caseload and participation in and the cost of the ATD program and the extent to which ICE has measured the performance of the ATD program.

9/18/18 AILA Doc. No. 18091856. Detention & Bond, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

AG Refers Case to Himself Relating to Authority to Hold Bond Hearings

The Attorney General referred a BIA decision to himself for review of issues relating to the authority to hold bond hearings for certain individuals screened for expedited removal proceedings. Amicus briefs are due by 10/16/18. Matter of M-G-G-, 27 I&N Dec. 469 (A.G. 2018)

9/18/18 AILA Doc. No. 18091900. Expedited Removal, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

AG Issues Decisions in Accordance with Matter of Castro Tum

Consistent with Matter of Castro-Tum on dismissal or termination of removal proceedings, the Attorney General issued decisions in two related cases. Matter of S-O-G- & F-D-B-, 27 I&N Dec. 462 (A.G. 2018)

9/18/18 AILA Doc. No. 18091970. Removal & Relief
Professional Resources

An Attorney’s Ethical and Legal Obligations to Pereira-Affected Clients

Identify the ethical obligations counsel must consider when advising clients in relation to Pereira. By following ethical parameters, attorneys and clients can properly arrive at the best strategic decision for that client’s case and take the action that the informed client decides is best.

9/18/18 AILA Doc. No. 18091831. Ethics, Removal & Relief
Federal Agencies, FR Regulations & Notices

HHS Notice of Intent to Fund 3,800 Additional Beds to Keep Unaccompanied Children in Custody

HHS (Department of Health and Human Services) notice of intent to provide up to $367,860,381 of funding for 3,800 beds to keep unaccompanied children in custody. (83 FR 47176, 9/18/18)

Cases & Decisions, DOJ/EOIR Cases

BIA Holds Colorado Theft Statute Not an Aggravated Felony

Unpublished BIA decision holds that theft under Colo. Rev. Stat. 18-4-401(1) is not an aggravated felony because it applies to the acquisition of property with consent that was obtained through deception. Special thanks to IRAC. (Matter of Garay-Gomez, 9/18/18)

9/18/18 AILA Doc. No. 19071203. Crimes, Removal & Relief
AILA Public Statements, Correspondence

AILA and Council Issue Statement to Senate HSGAC Committee on Flores Settlement Agreement

AILA and American Immigration Council statement submitted to the Senate Committee on Homeland Security and Governmental Affairs (HSGAC) addressing recently proposed regulations that would undermine the 1997 Flores Settlement Agreement.

AILA Public Statements, Correspondence

Sign-On Letter Opposing Legislation That Would Expand Family Detention

On 9/14/18, AILA joined national and state/local organizations to urge the Senate Homeland Security and Governmental Affairs Committee to reject any legislation that would expand the scale and length of immigrant family detention.

9/14/18 AILA Doc. No. 18092134. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Upholds BIA Denial of MTR for Original Removal Now Amenable to Cancellation, Based on §241(a)(5)

The court held that although petitioner’s original removal grounds no longer trigger removability, and he could have challenged it from abroad, his unlawful reentry and its consequent application of §241(a)(5) deprive BIA authority to reopen. (Rodriguez-Saragosa v. Sessions, 9/14/18)

9/14/18 AILA Doc. No. 18101537. Cancellation, Suspension & 212(c), Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Grants in Part, Remanding Reasonable Fear Review MTR for Sua Sponte Consideration; Denies in Part, Affirming IJ/AO Negative Reasonable Fear Determ

The court held substantial evidence did not compel a conclusion that IJ erred by not specifically addressing all evidence in reasonable fear review, which are statutorily abbreviated, yet IJ abused his discretion by denying jurisdiction to reopen proceedings. (Bartolome v. Sessions, 9/14/18)

9/14/18 AILA Doc. No. 18101704. Asylum, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Finds Texas Unlawful Restraint Not a CIMT

Unpublished BIA decision holds that attempted unlawful restraint under Tex. Penal Code § 20.02(c)(1) not a CIMT because persons could be convicted for seeking to assume lawful control of their own child with the acquiescence of the victim. Special thanks to IRAC. (Matter of S-K-, 9/14/18)

9/14/18 AILA Doc. No. 19071101. Crimes, Removal & Relief

Congressional Letter Requesting Information Regarding Initiative to Recalendar Administratively Closed Cases

A 9/13/18 letter from Senator Cortez Masto and others expressing concerns about ICE plans to recalendar potentially hundreds of thousands of administratively closed cases following the Attorney General’s decision in Matter of Castro-Tum, and requesting information on the initiative.

9/13/18 AILA Doc. No. 18091404. Congress, Prosecutorial Discretion, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Finds Non-Aggravated Felony Drug Offense Not a Presumptive Particularly Serious Crime

Unpublished BIA decision holds that possession with intent to distribute marijuana under Md. Code Ann., Crim. Law 5-602 is not a presumptive particularly serious crime because it is not an aggravated felony. Special thanks to IRAC. (Matter of J-F-B-, 9/13/18)

9/13/18 AILA Doc. No. 19071100. Crimes, Removal & Relief

ABA Issues Statement Regarding Immigration Lawyers and Judges

In response to a speech by Attorney General Sessions, ABA President Bob Carlson issued a statement in support of immigration lawyers and judges, stating that the ABA strongly supports the independence of immigration judges and immigration courts and applauds the work of immigration lawyers.

9/11/18 AILA Doc. No. 18091200. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Dismisses Respondent’s Appeal and Defines “Obstruction of Justice”

The BIA found that the respondent’s conviction for accessory to a felony is categorically an aggravated felony offense relating to obstruction of justice that renders him removable under INA §237(a)(2)(A)(iii). Matter of Valenzuela Gallardo, 27 I&N Dec. 449 (BIA 2018)

9/11/18 AILA Doc. No. 18091201. Crimes, Removal & Relief

AILA Quicktake #250: Proposed Changes to Flores Settlement Agreement

AILA's Associate Director of Government Relations Kate Voigt discusses the proposed changes to the Flores Settlement Agreement and their possible impact on the detention of immigrant children.

9/11/18 AILA Doc. No. 18091170. Admissions & Border, Detention & Bond, Removal & Relief