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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Cases & Decisions, Federal Court Cases

CA1 Upholds Denial of Asylum to Ecuadorian Petitioner Who Feared Harm Due to His Quechua Heritage

The court held that the IJ’s and BIA’s determinations that the petitioner could safely relocate within Ecuador were supported by substantial evidence, where the petitioner had testified that there were perhaps some Ecuadorian states in which he could live safely. (Caz v. Garland, 10/11/23)

10/11/23 AILA Doc. No. 23110431. Asylum, Removal & Relief
Practice Resources

Practice Advisory: Representing Detained Clients in the Virtual Landscape

AILA and the CAIR Coalition provide a practice advisory that focuses on the challenges unique to the detention context and how best to address some of the key issues to effectively providing remote representation to detained noncitizens.

10/10/23 AILA Doc. No. 23101001. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Finds BIA Applied Wrong Legal Standard in Evaluating Ineffective Assistance Claim

The court held that BIA applied an incorrect standard in reviewing petitioner’s ineffective assistance claim, overlooked and mischaracterized petitioner’s new hardship evidence, and failed to follow precedent when denying his request for remand. (Paucar v. Garland, 7/12/23, amended 10/10/23)

10/10/23 AILA Doc. No. 23072001. Removal & Relief, T & U Status
Practice Resources

Practice Alert: EOIR Issues Guidance on DHS Enforcement Priorities

On September 28, 2023, Director David L. Neal, published a Director's Memorandum issuing guidance for EOIR adjudicators in light of the Mayorkas Memorandum and the Doyle Memorandum.

10/3/23 AILA Doc. No. 23100302. Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Upholds Asylum Denial to Guatemalan Petitioner Who Feared Persecution on Account of Her Mayan Ancestry

The court held that substantial evidence supported the IJ’s determination that the Guatemalan petitioner had failed to establish that the Guatemalan government was unable or unwilling to protect her. (Perez v. Garland, 10/3/23)

10/3/23 AILA Doc. No. 23111603. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA11 Find Petitioner’s Massachusetts Armed Robbery Conviction Constituted an Aggravated Felony

The court held that the petitioner was removable as an aggravated felon, finding that his Massachusetts conviction for armed robbery constituted a theft offense under INA §101(a)(43)(G), and was thus an aggravated felony under INA §237(a)(2)(A)(iii). (Kemokai v. Att’y Gen., 10/2/23)

10/2/23 AILA Doc. No. 23111606. Crimes, Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Issues Flyer on Cancellation of Removal

EOIR issued a flyer on cancellation of removal, including information on how an individual can apply for cancellation.

9/29/23 AILA Doc. No. 23100205. Cancellation, Suspension & 212(c), Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Issues Memo with Guidance on Enforcement Priorities and Prosecutorial Discretion

EOIR issued a Director’s Memorandum (DM) that provides guidance to adjudicators on the enforcement priorities and exercises of prosecutorial discretion of DHS. This DM rescinds Policy Memorandum 21-25. Guidance is effective 9/28/23.

9/28/23 AILA Doc. No. 23092900. Prosecutorial Discretion, Removal & Relief
Chapter Documents

Southern California Chapter: Q&A from Liaison Meeting with DHS OPLA-LA and ERO (9/27/23)

Notes from Southern California Chapter’s liaison meeting with DHS OPLA-LA and ERO on 9/27/23.

9/27/23 AILA Doc. No. 23112004. Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds That Petitioner’s DUI Conviction in Pennsylvania Did Not Render Him Removable Under INA §237(a)

The court held that the BIA erred in concluding that the petitioner’s 2018 Pennsylvania conviction for driving under the influence (DUI) of marijuana constituted an offense involving a controlled substance that rendered him removable under INA §237(a). (Pesikan v. Att’y Gen., 9/26/23)

9/26/23 AILA Doc. No. 23100301. Crimes, Removal & Relief
Congressional Updates

Congressional Leaders Request USCIS Guidance on Cases Terminated by ICE

Congressional leaders wrote a letter to USCIS requesting guidance, so asylum seekers and their counsel know how to navigate affirmative asylum claims and applications for work authorization before the immigration court if a case is terminated.

9/25/23 AILA Doc. No. 23100304. Asylum, Prosecutorial Discretion, Removal & Relief
Federal Agencies, FR Regulations & Notices

NARA Notice of Agency Records Schedules

National Archives and Records Administration (NARA) notice with records schedules in which agencies propose to dispose of certain records. This notice includes a records schedule from ICE called “Video and Audio Surveillance Records.” (88 FR 65757, 9/25/23)

9/25/23 AILA Doc. No. 23092514. Removal & Relief
Federal Agencies, Agency Memos & Announcements

White House Announces New Actions to Increase Border Enforcement and Accelerate Processing for Work Authorizations

The White House announced new measures to enhance border security, including an expansion of FERM, increasing DHS holding and processing capacity, accelerated processing for EADs filed by parolees who scheduled an appointment through CBP One, and more.

AILA Public Statements, Correspondence

AILA Joins Sign-on Letter Requesting Further Transparency into the FERM Program

AILA joined 45 other organizations in requesting DHS to provide additional transparency into the impact and operation of the Family Expedited Removal Management (FERM) program.

9/19/23 AILA Doc. No. 23092204. Expedited Removal, Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Provides Office of the Chief Immigration Judge Staff Directory

EOIR provides the staff directory for the Office of the Chief Immigration Judge, broken down by court.

9/19/23 AILA Doc. No. 23031503. Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Holds That Petitioner’s Pending Post-Conviction Motion to Vacate Did Not Disturb Finality of Conviction for Immigration Purposes

The court held that BIA did not abuse its discretion in finding that petitioner’s pursuit of post-conviction relief neither destroyed the finality of her underlying conviction for immigration purposes nor invalidated the basis for the removal order based on it. (St. John v. Garland, 9/19/23)

9/19/23 AILA Doc. No. 23100300. Crimes, Removal & Relief
Federal Agencies, Agency Memos & Announcements

USCIS Clarifies Guidance for Filing DACA Applications

USCIS issued an update after a U.S. district court decision found the DACA final rule unlawful. USCIS will continue to accept and process DACA renewals and accompanying applications for EADs. USCIS will continue to accept initial requests, but per the order, not process initial DACA requests.

9/18/23 AILA Doc. No. 23091801. DACA, Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Remands Asylum Claim of Honduran Petitioner Who Feared Persecution Based on Her Past Experiences of Abuse and Sexual Violence

The court remanded for the BIA to determine whether the petitioner’s proposed particular social group (PSG) was cognizable in light of the specific country conditions in Honduras. (Avila v. Att’y Gen., 9/14/23)

9/14/23 AILA Doc. No. 23092502. Asylum, Removal & Relief
Cases & Decisions, Amicus Briefs/Alerts

AILA Submits Amicus on If DHS Can Remedy a Non-compliant NTA with an Amendment

AILA submitted an amicus brief to the BIA in response to Amicus Invitation No. 23-01-08, arguing that the Board should hold that if DHS serves a putative Notice to Appear that does not comply with Niz-Chavez, termination with prejudice is warranted.

9/14/23 AILA Doc. No. 23092705. Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Holds That Stop-Time Rule Refers to Date an INA §212(a)(2) Offense Is Committed

The court held that the BIA did not err in concluding that the stop-time rule set forth in INA §240A(d)(1)(B) is calculated from the date a petitioner committed the criminal offense that rendered him removable, rather than the date they were convicted. (Rudnitskyy v. Garland, 9/14/23)

9/14/23 AILA Doc. No. 23092606. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Finds Mexican Petitioner’s Credible Testimony Established Reasonable Fear of Persecution or Torture

Granting the petition for review, the court held that the petitioner’s own credible testimony at the screening stage sufficiently established a reasonable fear of persecution or torture to warrant a hearing before an IJ on the merits of his claims for relief. (Hermosillo v. Garland, 9/14/23)

9/14/23 AILA Doc. No. 23092608. Asylum, Removal & Relief
Liaison Minutes

AILA’s EOIR Liaison Committee Meets with EOIR (9/14/23)

AILA’s EOIR Liaison Committee met with EOIR in person as well as virtually in September 2023. Topics discussed included specialized dockets, pre-hearing conferences and DHS non-appearance, default hearing mediums and Webex issues, technology issues, and more. View the minutes as well as the agenda.

9/14/23 AILA Doc. No. 23090605. Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Declines to Give Retroactive Effect to New York’s Modification of Sentencing Scheme for Class A Misdemeanors

Declining to give retroactive effect to New York’s modification of its sentencing scheme for purposes of federal immigration law, the court upheld the BIA’s conclusion that petitioner was removable because he committed a crime involving moral turpitude. (Peguero Vasquez v. Garland, 9/13/23)

9/13/23 AILA Doc. No. 23092501. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Says Business Owners Are Not a Protected Social Group for Purposes of Asylum and Withholding of Removal

Denying the petition for review, the court agreed with the BIA that the petitioners’ proposed social group of “Salvadoran business owners” was not cognizable under the INA, because “business owner” is not an immutable trait. (Munoz-De Zelaya v. Garland, 9/12/23)

9/12/23 AILA Doc. No. 23092508. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Finds IJ Erred by Failing to Inform Petitioner of Bond Amount and Deadline Before Granting Voluntary Departure

The court held that the BIA erred in concluding that the IJ was not required to advise petitioner of the bond requirement before granting voluntary departure, and found that it was insufficient for the IJ to provide the required advisals in the order itself. (Solis-Flores v. Garland, 9/11/23)