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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Federal Agencies, Practice Resources

Practice Alert on Long-Pending DACA Cases at the Nebraska Service Center (Updated 12/30/13)

The AILA NSC Liaison Committee alerts members of long-pending DACA cases at the Nebraska Service Center and summarizes common factors in some cases that may explain slow processing times.

Cases & Decisions, Federal Court Cases

CA11 Holds Florida Possession with Intent to Deliver Controlled Substance Is Not Aggravated Felony

The court granted the petition, vacated and remanded, applying the categorical approach and holding that a conviction under Fla. Stat. §893.13(1)(a)(2) for the possession of cannabis with the intent to sell or deliver is not an aggravated felony. (Donawa v. U.S. Att’y Gen., 11/7/13)

11/7/13 AILA Doc. No. 13110803. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Overturns Asylum Denial for Pakistani Petitioner

The court overturned the termination of Petitioner’s asylum status, finding that DHS failed to give proper notice of its witnesses or exhibits, and since Petitioner refused to testify, the exhibits could not be used as impeachment evidence. (Urooj v. Holder, 11/6/13)

11/6/13 AILA Doc. No. 13110746. Asylum, Removal & Relief
Federal Agencies, FR Regulations & Notices

DOJ Requests Comments on Voluntary Form EOIR 31A

DOJ 60-day comment request on the Request by Organization for Accreditation of Non-Attorney Representative (Voluntary Form EOIR-31A). Comments are due 1/6/14. (78 FR 66382, 11/5/13)

11/5/13 AILA Doc. No. 13110548. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Remands Case of Unrepresented Respondent With Limited English Skills

Unpublished BIA decision remands to allow unrepresented respondent who was unfamiliar with English to apply for relief from removal. (Matter of Gomez-Amaya, 11/5/13) Special thanks to IRAC.

11/5/13 AILA Doc. No. 14010345. Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Remands Pentecostal Russian Asylum Claim

The court vacated and remanded, finding that the BIA erred when it found that the persecution the petitioner experienced in Russia was not “on account of” his Pentecostal faith. (Ivanov v. Holder, 11/5/13)

11/5/13 AILA Doc. No. 13111802. Asylum, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

IJ Finds Marijuana Conviction Is Not Categorically an Aggravated Felony

Immigration judge issued an order that applies Moncrieffe and concludes that the respondent is not removable as an aggravated felon for his conviction of possessing marijuana with intent to distribute and remains eligible to be considered for cancellation. Courtesy of Joshua Sleper.

11/5/13 AILA Doc. No. 13112133. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds E-2 Spouses Not Required to Obtain EAD

Unpublished BIA decision reverses denial of adjustment application and holds respondent was not required to obtain an employment authorization document as the spouse of an E-2 treaty investor. Special thanks to IRAC. (Matter of Lee, 11/5/13)

Cases & Decisions, Federal Court Cases

CA1 Upholds Adverse Credibility Finding for Guatemalan Petitioner

The court denied the application for CAT relief and upheld the adverse credibility finding due to the Petitioner’s inconsistencies in his submissions and testimony. (Martinez v. Holder, 11/4/13)

11/4/13 AILA Doc. No. 13110543. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Denies Asylum to Former 18th Street Gang Member from El Salvador

The court denied the petition for review, upholding the BIA’s finding that membership in a violent criminal street gang cannot serve as the basis for protected-group status under the INA. (Cantarero v. Holder, 10/31/13)

10/31/13 AILA Doc. No. 13110140. Asylum, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Finds Criminal Indictment Is Not Clear and Convincing Evidence of Date of Offense

Unpublished BIA decision finds statement in criminal indictment saying offense occurred “on or about” a particular date does not constitute clear and convincing evidence that the offense actually occurred on that date. Special thanks to IRAC. (Matter of Clase, 10/31/13)

10/31/13 AILA Doc. No. 13122442. Crimes, Removal & Relief
Cases & Decisions, Amicus Briefs/Alerts

AILA Amicus Brief on When an Order of Removal is Final for Purposes of Judicial Review

AILA amicus brief urging the Ninth Circuit Court of Appeals to grant rehearing in Abdisalan v. Holder to clarify when a final order of removal exists for purposes of filing a petition for review in cases where the BIA denies one immigration benefit and remands for consideration of another.

10/31/13 AILA Doc. No. 13103159. Removal & Relief
Cases & Decisions, Federal Court Cases

District Court Awards $20,000 in Attorney’s Fees in FOIA Lawsuit

Settlement agreement reached in district court in a FOIA lawsuit seeking the release of asylum officer notes. The agreement stipulated that DHS pay $20,000 in attorney’s fees. DHS handed over the asylum officer notes prior to settlement. (Hemed v. DHS, 10/30/13)

10/30/13 AILA Doc. No. 14011345. Asylum, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Finds Respondent Failed to Appear Due to Alleged Clerical Error

Unpublished BIA decision finds alleged clerical error by immigration court regarding date of hearing constitutes exceptional circumstances justifying failure to appear. Special thanks to IRAC. (Matter of Mendez, 10/30/13)

10/30/13 AILA Doc. No. 13122441. Removal & Relief
Federal Agencies, Agency Memos & Announcements

ICE FAQs on Immigration Detainers

Undated ICE FAQs on immigration detainers.

10/29/13 AILA Doc. No. 13102941. Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Holds LPRs With Serious Offenses Are Treated as “Seeking Admission” When Entering from Abroad

The court denied the petition, holding that the Fleuti doctrine did not survive IIRIRA’s enactment, and that LPRs who commit serious offenses are always treated as “arriving” aliens when entering from abroad and subject to removal under §101(a)(13)(C)(v), 212(a)(2). (Othi v. Holder, 10/29/13)

10/29/13 AILA Doc. No. 13103142. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA10 Upholds Cancellation of Removal Denial

The court denied the petition for review, finding that since the Petitioner had been granted suspension of deportation during prior deportation proceedings, he was ineligible for cancellation of removal under INA §240A. (Velasco v. Holder 10/29/13)

10/29/13 AILA Doc. No. 13110546. Asylum, Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Federal Agencies, FR Regulations & Notices

ICE Proposed Rulemaking on Interest Rates on Cash Bond Deposits

ICE notice of proposed rulemaking amending its regulations to explicitly provide that the Treasury Department will set the interest rate for cash bonds deposits. The current interest rate paid on deposits securing case bonds is set at 3 percent per annum. (78 FR 64183, 10/28/13)

10/28/13 AILA Doc. No. 13102842. Detention & Bond, Removal & Relief
Federal Agencies, Liaison Minutes

AILA Liaison CBP Meeting Minutes with Supplemental Committee Notes (10/28/13)

The AILA CBP Liaison Committee provides approved Q&As and supplemental notes from their meeting with CBP on 10/28/13. Topics include I-94 automation, DOMA, preclearance operations, provisional waivers, nonimmigrant adjudications, credible fear interview, and prioritizing petition adjudication.

Cases & Decisions, Federal Court Cases

CA10 Dismisses Untimely Petition for Review for Lack of Jurisdiction

The court dismissed the untimely petition for review for lack of jurisdiction, finding that the initial removal order was final, notwithstanding a subsequent remand to the IJ regarding voluntary departure. (Batubara v. Holder, 10/28/13)

10/28/13 AILA Doc. No. 13102950. Asylum, Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Immigration Court Practice Manual Updates

EOIR alert that the Immigration Court Practice Manual has been updated to reflect the new zip code for all EOIR components located in Falls Church, VA, as well as a new address for the Portland Oregon Immigration Court.

10/28/13 AILA Doc. No. 13102840. Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Upholds Denial of Inadmissibility Waiver as a Matter of Discretion

The court upheld the denial of the inadmissibility waiver, finding that Petitioner’s extensive criminal record that extended through his removal proceedings outweighed any additional hardship caused to his USC daughter with special education needs. (Reyes-Cornejo v. Holder, 10/28/13)

Cases & Decisions, DOJ/EOIR Cases

BIA Holds Ammunition Possession by Felon is Aggravated Felony

The Board held that unlawful possession of ammunition by a convicted felon under 18 USC §922(g) is an aggravated felony under INA §101(a)(43)(E)(ii). Matter of Oppedisano, 26 I&N Dec. 202 (BIA 2013)

10/25/13 AILA Doc. No. 13102559. Crimes, Removal & Relief

Report Calls for Improvements to DHS Notice to Appear (NTA) Procedure

Center for Immigrants’ Rights report, “To File or Not to File a Notice to Appear: Improving the Government’s Use of Prosecutorial Discretion,” arguing that DHS should consistently consider prosecutorial discretion (PD) and increase its use of favorable PD in the issuance and filing of NTAs.

10/25/13 AILA Doc. No. 13102844. Prosecutorial Discretion, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Denies Withholding and CAT Relief to Ecuadorian National

The court upheld the denials of the motions to reopen, agreeing with the BIA that the Petitioner failed to establish a statutorily protected ground of persecution and failed to demonstrate ineffective assistance of counsel. (Muyubisnay-Cungachi v. Holder, 10/25/13)

10/25/13 AILA Doc. No. 13102848. Asylum, Removal & Relief