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

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Practice Resources

AILA Key Takeaways from 2024 EOIR Spring Conference Panel

On March 21, 2024, AILA hosted an open forum at the 2024 Spring Conference with EOIR leadership. The EOIR National Committee provides the following key takeaways.

3/21/24 AILA Doc. No. 24043004. Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Upholds Asylum Denial to Petitioner Targeted by Extortionists in Honduras

The court held that substantial evidence supported the BIA’s determination that the petitioner, who claimed she was targeted by extortionists in Honduras, had not established that she had been, and would continue to be, persecuted on account of a protected status. (Cruz v. Garland, 3/21/24)

3/21/24 AILA Doc. No. 24041080. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Remands Petitioner’s Withholding Claim Where BIA Mischaracterized Her Gender-Based PSG

The court held that the BIA’s mischaracterization of the petitioner’s proposed particular social group (PSG)—which the court found could be restated simply as “Trinidadian women who oppose gender-based domestic violence”—was a legal error. (Ferreira v. Garland, 3/21/24)

3/21/24 AILA Doc. No. 24040974. Asylum, Removal & Relief
Agency Memos & Announcements

EOIR Experiencing Intermittent Systemwide Outages

EOIR posted an alert that it has been experiencing intermittent systemwide outages and is working to resolve the issues. EOIR will issue new Notices of Hearing to anyone whose hearings were affected by these outages.

3/21/24 AILA Doc. No. 24032271. Removal & Relief
Liaison Minutes

AILA’s EOIR Liaison Committee Meeting with EOIR (3/20/24)

AILA’s EOIR Liaison Committee provides the unofficial minutes and agenda from its liaison meeting with EOIR on March 20, 2024.

3/20/24 AILA Doc. No. 24031100. Removal & Relief
Liaison Minutes

AILA’s ICE Committees Meets with ICE (3/20/24)

AILA’s ICE Liaison Committee met with ICE's OPLA and ERO on March 20, 2024. Read the agenda, key takeaways, and official minutes.

3/20/24 AILA Doc. No. 24030161. Removal & Relief
Practice Resources

Practice Alert: Padilla v. ICE and Delays in Credible Fear Interviews

AILA shares an updated practice alert regarding the Padilla v. ICE settlement. This practice alert includes more detailed information on contacting class counsel regarding potential violations of the settlement in individual cases, as well as the current status of the litigation.

3/20/24 AILA Doc. No. 24040871. Asylum, Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Finds Petitioner’s Virginia Convictions for Attempted Sexual Battery and Electronic Solicitation of a Minor Were CIMTs

The court affirmed the BIA’s determination that petitioner’s two Virginia convictions for attempted sexual battery and electronic solicitation of a minor were crimes involving moral turpitude (CIMTs) that rendered him removable under INA §237(a)(2)(A)(ii). (Gomez-Ruotolo v. Garland, 3/20/24)

3/20/24 AILA Doc. No. 24041076. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Upholds Asylum Denial After Finding No Nexus Between Petitioner’s Harm and Her Identity as a Mayan Akateko Woman

The court upheld the BIA’s and IJ’s conclusions that petitioner had failed to demonstrate a nexus between her particular social group (PSG) and the harm she experienced, and had not shown that the Guatemalan government had acquiesced in her mistreatment. (Sabastian-Andres v. Garland, 3/20/24)

3/20/24 AILA Doc. No. 24041078. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

Supreme Court Issues Ruling That Allows Texas to Enforce SB4

The Supreme Court denied the applications to vacate the stay of the preliminary injunction against Texas Senate Bill 4 (SB4) but later in the day, the Fifth Circuit again paused the law from going into effect. (United States v. Texas, 3/19/24)

3/19/24 AILA Doc. No. 24032071. Admissions & Border, Removal & Relief
Cases & Decisions, Federal Court Cases

Supreme Court Rules That Courts Have Jurisdiction to Review Hardship Determinations in Cancellation of Removal Cases

The U.S. Supreme Court held that the application of the exceptional and extremely unusual hardship standard to an established set of facts is a mixed question of law and fact that is reviewable as a question of law under INA §242(a)(2)(D). (Wilkinson v. Garland, 3/19/24)

3/19/24 AILA Doc. No. 24032072. Cancellation, Suspension & 212(c), Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Upholds Asylum Denial Where Guatemalan Petitioner Failed to Exhaust Imputed Membership and Race-Based Claims

The court held that the petitioner had failed to exhaust her race-based claims and her claim of imputed membership in the particular social group (PSG) consisting of “communal landowners of Ixchiguán, Guatemala, that refused to cooperate with criminal gangs.” (Chun Mendez v. Garland, 3/15/24)

3/15/24 AILA Doc. No. 24040973. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA11 Finds No Indication That BIA Applied Incorrect Legal Standard in Determining Petitioner Did Not Warrant Discretionary Relief

The court upheld the BIA’s dismissal of the petitioner’s appeal for adjustment of status and its subsequent denial of his motion to reconsider, finding that there was no indication that the BIA had applied a substantially incorrect legal standard. (Navarro Guadarrama v. Att’y Gen., 3/15/24)

3/15/24 AILA Doc. No. 24041175. Adjustment of Status, Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Concludes That BIA Engaged in Improper De Novo Factfinding When Analyzing Petitioner’s Family-as-a-PSG Claim

The court held that the BIA’s conclusions as to the nexus required to prove asylum for the Salvadoran petitioner’s proposed particular social group (PSG) consisting of her family lacked support in the record and constituted improper de novo factfinding. (Vasquez-Rivera v. Garland, 3/15/24)

3/15/24 AILA Doc. No. 24041077. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Holds That BIA Failed to Apply Correct Legal Standard in Finding Petitioner’s Conviction Was a Particularly Serious Crime

The court held that the BIA erred in finding that petitioner’s money laundering conspiracy conviction in violation of 18 USC §1956(h) was a particularly serious crime barring withholding of removal, and thus vacated the BIA decision and remanded. (Annor v. Garland, 3/15/24, amended 5/22/24)

3/15/24 AILA Doc. No. 24040977. Crimes, Removal & Relief
Agency Memos & Announcements

ICE Announces Initial Deployment of 1,600 Body-worn Cameras

ICE announced the initial deployment of 1,600 body-worn cameras to HSI and ERO. During this phase, ICE will distribute body-worn cameras and provide specific training to ERO and HSI personnel in the Baltimore, Philadelphia, Washington, Buffalo, and Detroit areas of responsibility.

3/13/24 AILA Doc. No. 24031474. Employer Compliance, Removal & Relief
AILA Blog

Think Immigration: A Look Inside DHS’ Family Expedited Removal Management Program

AILA Law Student Member Araceli Garcia describes how University of Texas Law students were able to help families in the expedited removal program and how the expansion of the FERM program has meant the need for counsel has only grown.

3/13/24 AILA Doc. No. 24031300. Asylum, Expedited Removal, Removal & Relief
Agency Memos & Announcements

EOIR Announces Relocation of Orlando Immigration Court

EOIR announced that the Orlando Immigration Court will suspend regular court functions at its current location at the close of business on March 13, 2024, to prepare for the court’s relocation. Staff will remain onsite to accept phone calls and filings until March 15, 2024.

3/11/24 AILA Doc. No. 24031103. Removal & Relief
FR Regulations & Notices

DHS Notice of Employment Authorization for Venezuelan F–1 Students Experiencing Severe Economic Hardship

DHS notice suspending certain regulatory requirements for F-1 nonimmigrant students whose country of citizenship is Venezuela and who are experiencing severe economic hardship as a direct result of the crisis in Venezuela. Action is effective 3/11/24 through 9/10/25. (89 FR 17500, 3/11/24)

3/11/24 AILA Doc. No. 24031104. Removal & Relief, Students & Schools
Agency Memos & Announcements

OIDO Invitation to March Roundtable Discussions

The Office of the Immigration Detention Ombudsman will hold two roundtable discussions in March to collect feedback. On March 14, it will hold a MyOIDO feedback webinar and on March 21, it will hold a legal access webinar. Notice includes registration information.

3/11/24 AILA Doc. No. 24030801. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Finds That BIA’s Retroactive Application of Its “Minimum Constitutional Protections” Test Was Appropriate

The court held that the BIA’s retroactive application of its “minimum constitutional protections” test was appropriate, and thus concluded that the petitioner had twice been convicted of crimes for removal purposes under INA §101(a)(48)(A) and INA §237(a)(2)(A)(ii). (Wong v. Garland, 3/11/24)

3/11/24 AILA Doc. No. 24040971. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Remands for BIA to Properly Consider Whether Supporting Documents Independently Proved Petitioner’s Past Persecution Claim

The court held that the BIA did not properly evaluate whether the petitioner’s documentary evidence independently supported her claims of past persecution in her native Zambia on account of her sexual orientation. (Kalulu v. Garland, 3/11/24, amended 2/13/25)

3/11/24 AILA Doc. No. 24041171. Asylum, LGBTQ, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Denies Rehearing En Banc in Mejia-Alvarenga v. Garland

The court denied the petition for en banc rehearing, but withdrew its previous opinion and substituted in its place a new decision that upheld the BIA’s denial of asylum as to the Salvadoran petitioner. (Mejia-Alvarenga v. Garland, 3/8/24)

3/8/24 AILA Doc. No. 24031371. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA8 Finds BIA Did Not Err in Vacating IJ’s Grant of CAT Relief as to South Sudanese Petitioner

The court held that the BIA did not err in rejecting the petitioner’s claim under the Convention Against Torture (CAT) for deferral of his removal to South Sudan, finding that the evidence was insufficient to establish a likelihood of torture. (Yar v. Garland, 3/8/24)

3/8/24 AILA Doc. No. 24031473. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA11 Grants Rehearing in Case Concerning Retroactive Application of Matter of Thomas and Matter of Thompson

The court granted the petition for rehearing and withdrew its previous opinion, which held that petitioner’s modification order did not change his term of imprisonment for purposes of federal immigration law, and thus that petitioner was an aggravated felon. (Edwards v. Att’y Gen., 3/6/24)

3/6/24 AILA Doc. No. 24031874. Crimes, Removal & Relief