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 Report Shows Unlawful Re-Entry as Most Common Lead Charge

Transactional Records Access Clearinghouse (TRAC) report finds that 18,552 new unlawful re-entry prosecutions were reported during the first half of FY2011, based on data from DOJ, making unlawful re-entry under 8 U.S.C. §1326 the most commonly recorded lead charge.

6/10/11 AILA Doc. No. 11080170. Admissions & Border, Crimes, Removal & Relief
Federal Agencies, Cases & Decisions, DOJ/EOIR Cases, Practice Resources

ICE Exercises Prosecutorial Discretion in Case Involving Same-Sex Spouse of USC

In a 6/10/11 joint motion, ICE Chief Counsel exercised its prosecutorial discretion by moving to administratively close proceedings against the same-sex spouse of a U.S. citizen with a pending I-130. The IJ granted the motion on 6/13/11. Courtesy of Lavi S. Soloway.

Cases & Decisions, Amicus Briefs/Alerts

AILA Amicus Brief Urges BIA to Reconsider Administrative Closure Policy

AILA amicus brief urging the BIA to reconsider and modify its previous decisions requiring no opposition by either party before the immigration judge or BIA can administratively close a case.

6/9/11 AILA Doc. No. 11061061. Prosecutorial Discretion, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Addresses Whistleblowing as a Basis for Asylum

The BIA held that retaliation for opposition to state corruption may form the basis for a claim based on political opinion if, post-REAL ID, the actual or imputed anti-corruption belief was one central reason for the harm. Matter of N-M-, 25 I&N Dec. 526 (BIA 2011)

6/9/11 AILA Doc. No. 11062862. Asylum, Removal & Relief
Federal Agencies, Agency Memos & Announcements

USCIS Asylum Division Memo on Notifying Certain Asylum Applicants How To Seek Release From Detention

USCIS Asylum Division memo dated 6/9/11 regarding updated information notification of ICE's parole guidelines to arriving aliens found to have a credible fear of persecution or torture, including copies of the updated information notification.

6/9/11 AILA Doc. No. 11060959. Asylum, Detention & Bond, Removal & Relief
Media Tools

AILA Summary of Keep Our Communities Safe Act of 2011 (H.R. 1932)

AILA summary of the Keep Our Communities Safe Act of 2011 (H.R. 1932), a bill that would expand the use of immigration detention.

6/8/11 AILA Doc. No. 11060835. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 on Burden of Proof and Evidence of Good Faith Marriage

The court held that the burden is on the alien to prove a good faith marriage for waiver of the joint removal of conditions and that the IJ did not err in attaching significance to the couple’s post-marriage actions. (Boluk v. Holder, 6/7/11)

TRAC Report on the Growing Immigration Case Backlog Despite Additional Judge Appointments

Transactional Records Access Clearinghouse (TRAC) report finding that the number of cases awaiting resolution before the immigration courts reached a new all-time high of 275,316 by the end of May 2011, despite the addition of 44 new immigration judges to the bench.

6/7/11 AILA Doc. No. 11060862. Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Responds to AILA Regarding the Application of DOMA in Proceedings

A 6/6/11 letter from Juan P. Osuna, Director, EOIR, responding to a 4/6/11 letter from AILA and other organizations, stating that until the Defense of Marriage Act (DOMA) is repealed or struck down EOIR will continue to apply DOMA as interpreted in the immigration context.

6/6/11 AILA Doc. No. 11061065. Family Immigration, LGBTQ, Removal & Relief
Cases & Decisions, Federal Court Cases

Grand Jury Indicts Couple on Charges Involving Domestic Servitude

Federal grand jury indictment charging a MD couple with forced labor conspiracy and harboring a domestic worker for financial gain. The indictment alleges the defendants procured a fraudulent B-1 visa to bring the victim to the U.S. to work as their domestic servant. (U.S. v. Edwards, 6/6/11)

DHS PIA for the Automated Threat Prioritization Web Service

DHS/ICE Privacy Impact Assessment describing the general functionality of the Automated Threat Prioritization (ATP) web service, which receives, processes, and transmits criminal history information about individuals who are the subjects of enforcement actions.

6/6/11 AILA Doc. No. 11062770. Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Says EAD Grant Does Not Confer Admission Status for Cancellation of Removal

The court held that the grant of work authorization pending the approval of adjustment of status does not confer admission status on an undocumented alien for purposes of calculating seven years continuous residence for cancellation. (Guevara v. Holder, 6/3/11)

Cases & Decisions, Federal Court Cases

CA9 on “Admitted in Any Status” for Cancellation of Removal

The court held that an approved I-130 Petition for Alien Relative does not confer admission status on an undocumented alien for purposes of showing seven years of continuous residence for cancellation of removal. (Vasquez de Alcantar v. Holder, 6/3/11)

Cases & Decisions, DOJ/EOIR Cases

BIA Says Arriving Aliens Subject to Expedited Removal May Be Placed in §240 Proceedings

The BIA held that DHS has the discretion to place arriving aliens in removal proceedings under INA §240, even if they may also be subject to expedited removal under INA §235(b)(1)(A)(i). Matter of E-R-M- & L-R-M, 25 I&N Dec. 520 (BIA 2011)

Federal Agencies, FR Regulations & Notices

USCIS Additional 30-Day Comment Request on Form I-212 Extension (Updated 6/2/11)

USCIS notice of an additional 30-day comment period on the extension of the validity of Form I-212, Application for Permission to Reapply for Admission into the U.S. after Deportation or Removal. Comments are due 07/05/11. (76 FR 31971, 6/2/11) (76 FR 14419, 3/16/11)

Cases & Decisions, Federal Court Cases

CA9 Says Reinstatement Does Not Apply to Petitioner Who Sought Relief Pre-IIRIRA

The court held that reinstatement of removal under INA §241(a)(5) is impermissibly retroactive when applied to individuals who applied for discretionary relief prior to IIRIRA’s effective date. (Chay Ixcot v. Holder, 6/1/11)

6/1/11 AILA Doc. No. 11060299. Asylum, Removal & Relief
Federal Agencies, Agency Memos & Announcements

DOJ OIL May 2011 Litigation Bulletin

DOJ Office of Immigration Litigation (OIL) May 2011 Litigation Bulletin covers the BIA’s clear error standard of review, the Supreme Court’s consideration of whether tax crimes other than tax evasion may be aggravated felonies, proposed changes to the EB-5 Program, and more.

DHS Annual Report on Immigration Enforcement Activities in FY2010

DHS Office of Immigration Statistics Annual Report released June 2011, finding that DHS made 517,000 apprehensions and removed 387,000 foreign nationals from the U.S. in FY2010. ICE detained approximately 363,000 foreign nationals.

PHR Report: Indefinite Detention in the U.S.

A Physicians for Human Rights (PHR) report on the use of indefinite detention in the national security and immigration contexts, finds that the harms endured by indefinite detainees are unconstitutionally punitive and violate domestic and international law.

6/1/11 AILA Doc. No. 11070171. Detention & Bond, Removal & Relief

BIA Dismisses Appeal of Derivative Spouse Who Cannot Independently Qualify for TPS

The BIA held that an alien seeking TPS as a derivative spouse must be from a state designated for TPS eligibility and found that the IJ properly denied the respondent’s application for TPS as a late initial registrant. Matter of Echeverria, 25 I&N Dec. 512 (BIA 2011)

Cases & Decisions, Federal Court Cases

CA9 Affirms Oh v. Gonzales, Says 30-Day Appeal Deadline Is Not Jurisdictional

Finding no ambiguity, the court refused to apply Brand X and Chevron deference to the BIA’s decision in Liadov and concluded that the 30 day deadline for appeals under 8 CFR §1003.38 is not jurisdictional. (Irigoyen-Briones v. Holder, 5/31/11)

5/31/11 AILA Doc. No. 11060263. Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Remands for BIA Clarification on the Concept of Legitimation

In a case involving a claim for derivative citizenship, the court remanded to the BIA to clarify how it interprets “legitimation” under INA §101(c)(1) and to explain how its understanding of legitimation applies to Jamaican law. (Watson v. Holder, 5/31/11)

5/31/11 AILA Doc. No. 11060160. Naturalization & Citizenship, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Asks BIA to Reconsider Continuance for Arriving Alien

In a case involving an arriving alien adjustment of status, the court found that the BIA erred in denying Petitioner’s continuance on the ground that it lacked jurisdiction to adjudicate adjustment applications for arriving aliens. (Freire v. Holder, 5/27/11)

5/27/11 AILA Doc. No. 11052764. Adjustment of Status, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Says Inconclusive Conviction Record Is Insufficient to Meet Cancellation Burden

The court rejected the argument that Petitioner satisfied his burden of proof to demonstrate he had not been convicted of an aggravated felony by presenting an inconclusive, though complete, record of conviction. (Salem v. Holder, 5/24/11)

5/24/11 AILA Doc. No. 11052561. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Finds Conviction for Violating Kansas No-Contact Provision Is a Removable Offense

The BIA held that a conviction for violation of the no-contact provision of a protection order issued under the Kansas Protection from Abuse Act constitutes a removable offense under INA §237(a)(2)(E)(ii). Matter of Strydom, 25 I&N Dec. 507 (BIA 2011)

5/24/11 AILA Doc. No. 11060967. Crimes, Removal & Relief