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 Rejects Social Group Claim of Senegalese Woman

The court held that women who had a child out of wedlock, and are considered adulterers because they gave birth to a child allegedly not their husband’s and have been abused by their husbands is not a protected social group. (Faye v. Holder, 9/2/09)

9/2/09 AILA Doc. No. 09092878. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Says No Natz Adjudication While While Removal Proceedings are Pending

The court held that INA §318 bars DHS from considering a naturalization application where removal proceedings are pending and that individuals in removal proceedings may not avail themselves of 8 CFR §1239.2(f). (Perriello v. Napolitano, 9/1/09)

9/1/09 AILA Doc. No. 09092969. Naturalization & Citizenship, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 on “Grandfathering” Under INA §245(i)

A derivative spouse is only eligible for §245(i) adjustment if he or she is “accompanying or following to join” the principal alien. Status as a mere registrant for the RAW program does not grandfather petitioner into §245(i). (Landin-Molina v. Holder, 9/1/09)

9/1/09 AILA Doc. No. 10100874. Adjustment of Status, Removal & Relief
Federal Agencies, Agency Memos & Announcements

Immigration Law Advisor, August 2009 (Vol. 3, No. 8)

Immigration Law Advisor, a legal publication from EOIR, with an article on changed circumstances and country conditions for asylum cases, federal court activity for July 2009, an article on the REAL ID act, and a regulatory update.

9/1/09 AILA Doc. No. 14041643. Asylum, Removal & Relief

MPI Report on Immigration Detention

In September 2009, MPI released a report on ICE’s responsibilities for immigration detention facilities.

9/1/09 AILA Doc. No. 09091171. Asylum, Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Holds Board Abused Discretion by Rejecting Brief as Out of Time

The court held that the Board abused its discretion when it rejected Petitioner’s brief as out of time where Petitioner never received notice of the briefing schedule. (Dakaj v. Holder, 8/31/09)

8/31/09 AILA Doc. No. 09100219. Removal & Relief
Federal Agencies, FR Regulations & Notices

ICE Extends Information Collection on Electronic Bonds Online Access

ICE extension of the information collection on Electronic Bonds Online (eBonds) Access. Related forms are Form I-352SA, Surety eBonds Access Application and Agreement and Form I-352RA, eBonds Rules of Behavior Agreement. Comments are due 9/30/09. (74 FR 44865, 8/31/09)

8/31/09 AILA Doc. No. 09083163. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

USCIS Issues Guidance for Surviving Spouses of U.S. Citizens

On 8/31/09 USCIS issued guidance on requesting deferred action for surviving spouses of U.S. citizens who died before the second anniversary of their marriage. FAQs and Fact Sheet follow.

Cases & Decisions, Federal Court Cases

CA9 Finds UCMJ Article 92 Is Not Categorically an Aggravated Felony

The court held that a violation of Article 92 of the Uniform Code of Military Justice is not categorically an aggravated felony where Petitioner pled guilty to using a government computer to access pornography. (Aguilar-Turcios v. Holder, 9/29/09; withdrawn 8/29/11)

8/29/09 AILA Doc. No. 09102164. Crimes, Removal & Relief
Federal Agencies, Practice Resources

Practice Pointer: How to Inform USCIS When TPS Is Granted by an Immigration Judge

AILA Liaison reminds practitioners to inform USCIS when late-registration Temporary Protected Status (TPS) is granted by an immigration judge in order to apply for a TPS renewal and work authorization document.

Cases & Decisions, Federal Court Cases

CA7 Remands to Board for Failure to Consider Petitioner’s Changed Circumstances Motion To Reopen

The Court held that the Board erred when it failed to consider Petitioner’s argument that her parent’s threat of forced marriage in Pakistan constituted a changed circumstance, allowing a second motion to reopen to be filed out of time. (Joseph v. Holder, 8/27/09)

8/27/09 AILA Doc. No. 09100260. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Upholds Adverse Credibility Absent Corroborating Evidence

The court denied the petition for review, finding that the immigration judge’s adverse credibility finding was supported by substantial evidence and that Petitioner failed to provide corroborating evidence to clear up inconsistencies. (Zheng v. Holder, 8/27/09)

8/27/09 AILA Doc. No. 09092877. Asylum, Removal & Relief
Federal Agencies, Agency Memos & Announcements

United States and Mexico Resume Voluntary Humanitarian Interior Repatriation Program

DHS announced that it has resumed the Mexican Interior Repatriation Program (MIRP) for the sixth consecutive summer.

8/25/09 AILA Doc. No. 09082560. Removal & Relief
Cases & Decisions, Amicus Briefs/Alerts

AILF and AILA Urges BIA to Vacate Matter of Perez-Vargas

AILF and AILA amicus brief arguing that Matter of Perez-Vargas, 23 I&N Dec. 829 (BIA 2005) should vacated because it deprives skilled foreign workers in removal proceedings the ability to change jobs under AC21.

8/24/09 AILA Doc. No. 09090863. Adjustment of Status, Business Immigration, Removal & Relief
Cases & Decisions, Amicus Briefs/Alerts

AILA Amicus Brief Regarding Application of Nijhawan v. Holder

AILA amicus brief arguing that Nijhawan v. Holder overturned the BIA's decision in Matter of Babaisakov regarding the type of evidence/procedures IJs can use when an element of the aggravated felony definition may be proven beyond the record of conviction.

8/20/09 AILA Doc. No. 09082162. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Affirms BIA Denial of Ugandan Asylum Claim

The court affirmed the BIA’s denial of asylum, withholding, and CAT, finding that Petitioner’s evidence was inconsistent, vague and lacked corroboration. (Matovu v. Holder, 8/20/09)

8/20/09 AILA Doc. No. 09092965. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Remands Asylum Claim: IJ’s Denial of Asylum for FGM Persecution Claim in Error

The court held that immigration judge’s ruling that female genital mutilation was not persecution was not supported by law. (Gatimi v. Holder, 8/20/09)

8/20/09 AILA Doc. No. 09100217. Asylum, Removal & Relief
Federal Agencies, Liaison Minutes

VSC Stakeholder Qs & As with Meeting Minutes (8/20/09)

The 8/20/08 joint Stakeholder questions and answers with meeting minutes address H-1B, 3rd party worksites, I-94, J-1, Premium Processing, H-2B, L-1A/L-1B, specialized knowledge, Q-1, F-1, I-765, OPT, U, T, I-601, customer service, G-28, TPS, Consular returns, 212(e) waivers, NVC, I-539, and more.

Federal Agencies, FR Regulations & Notices

USCIS Extends Information Collection on Form I-243

USCIS extension of an information collection for Form I-243, Application for Removal. Comments are due 9/21/09. (74 FR 42083, 8/20/09)

8/20/09 AILA Doc. No. 09082068. Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Upholds Denial of Motion to Reopen in Kenyan Withholding Case

The court denied the petition for review, finding that Petitioner failed to raise any new evidence or changed circumstances regarding her claims for withholding of removal from Kenya and CAT. (Warui v. Holder 8/19/09)

8/19/09 AILA Doc. No. 09092876. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Holds that Section 1256(a) only Applies to Rescission Proceedings

CA6 held that because petitioners were in removal proceedings due to fraud in their asylum applications and had no valid documents at the time of adjustment, the 5- year limitation on rescission proceedings does not bar the government from removing Petitioner. (Stolaj v. Holder, 8/19/09).

8/19/09 AILA Doc. No. 09100215. Adjustment of Status, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Finds No Nexus in Guatemalan Asylum Claim

The court affirmed the BIA’s denial of withholding, finding that Petitioner’s testimony was speculative and did not furnish an adequate nexus between the events and a protected ground. (Lopez-Castro v. Holder, 8/18/09)

8/18/09 AILA Doc. No. 09092888. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Affirms Denial of Indonesian Christian Withholding Claim

The court found that the immigration judge adequately addressed reports of country conditions in Indonesia and the testimony of each witness, and did not err in denying withholding of removal. (Pakasi v. Holder, 8/18/09)

8/18/09 AILA Doc. No. 09092881. Asylum, Removal & Relief
Federal Agencies, Liaison Minutes

ICE Briefing on Enforcement & Detention Issues

In a telephonic briefing moderated by the White House, ICE Assistant Secretary Morton discussed current policies & perspectives on detention, worksite enforcement, 287(g), and residential raids.

8/18/09 AILA Doc. No. 09081860. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

ICE Detainee Passes Away at Florida Hospital

On August 14, 2009, Huluf Guangule Negusse, a 24-year-old Ethiopian national being held with a final order of removal pending the receipt of his travel documents, passed away at Tallahassee Memorial Hospital in Florida.

8/18/09 AILA Doc. No. 09081863. Detention & Bond, Removal & Relief