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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Federal Agencies, Agency Memos & Announcements

EOIR Fact Sheet on Video Teleconferencing

A 3/13/09 EOIR fact sheet provides an overview of the law authorizing hearings conducted using video teleconferencing and the role of video teleconferencing in the Criminal Alien Program.

3/13/09 AILA Doc. No. 09031767. Removal & Relief
AILA Blog

Treating Immigrants Worse than Criminals

We all know that, if you get caught breaking the law, you risk getting arrested and a trip to jail.But we've got a pretty fair system, right?You can make a free phone call, talk to a lawyer, and get a hearing in front of a judge, pretty much right away, don't you?The bad guys go […]

Cases & Decisions, DOJ/EOIR Cases

BIA on Whether Electronic Monitoring and Home Confinement Constitute Custody

The BIA held that because DHS released the foreign national from actual physical detention, he was released from custody within the meaning of 8 C.F.R.§ 1236.1(d)(1). Matter of Jose Aguilar-Aquino, 24 I&N Dec. 747 (BIA 2009)

3/12/09 AILA Doc. No. 09031364. Detention & Bond, Removal & Relief
Federal Agencies, Practice Resources

Practice Alert: TSC NTA Issuance After I-140 Approvals

AILA Liaison provides this Practice Alert in light of reports from several members that the TSC has begun issuing NTAs to out-of-status beneficiaries after the approval of an I-140 petition filed for the alien.

Federal Agencies, Agency Memos & Announcements

Fairfax County, VA Detainee Prints to Be Checked Against DHS Biometrics Database

On 3/9/09 ICE announced that Fairfax County, Virginia has joined the list of jurisdictions that will check the fingerprints of every booked individual against immigration records in DHS's biometric database. The ICE administered program is called Secure Communities.

3/10/09 AILA Doc. No. 09031062. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Finds Possession of Green Card Obtained by False Statement is Prosecutable Offense

The court concluded that 18 U.S.C. § 1546(a) prohibits the possession of an otherwise authentic document that one knows has been procured by false claim, rejecting a statute of limitations argument, as it was a possession rather than false statement offense. (United States v. Krstic, 3/10/09)

3/10/09 AILA Doc. No. 09041565. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Finds Petitioner Did Not Knowingly Waive Appellate Rights in Accepting Voluntary Departure

CA4 finds the BIA erred in denying motion to reconsider for lack of jurisdiction, and that petitioner did not knowingly and intelligently waive his right to appeal before the IJ in accepting voluntary departure. Courtesy of Alexandru I. Craciunescu. (Narine v. Holder, 3/9/09).

3/9/09 AILA Doc. No. 09031060. Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Affirms Denial of Application for Cancellation for CIMT

CA7 denies petition for review, dismissing petitioner’s arguments for failure to exhaust, and finding that a violation of 18 U.S.C. § 1001 is a crime involving moral turpitude, thus petitioner is barred from applying for cancellation of removal. (Ghani v. Holder, 3/9/09)

3/9/09 AILA Doc. No. 09041672. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

IJ Addresses ISAP as “Custody”

Orlando Immigration Court IJ finds that the Intensive Supervision Appearance Program (ISAP) is a form of custody and orders release from ISAP upon payment of bond. Courtesy of Andy Strickland.

3/6/09 AILA Doc. No. 09031268. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Finds Appellant Indicted for Re-entry After Removal Fails to Show Statute of Limitations Has Run

CA4 denies appeal, finding that §276 does not encompass constructive knowledge, and that the appellant failed to show federal immigration authorities were aware of his identity and presence in the U.S. on the date required for a reentry violation.(United States v. Uribe-Rios, 3/4/09).

3/4/09 AILA Doc. No. 09040376. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Concludes Lack of Jurisdiction Due to Petitioner’s Failure to Exhaust Administrative Remedies

The court concludes that that it does do not have the authority to excuse petitioner’s failure to exhaust, and that allowing “effective” exhaustion, rather than actual exhaustion, runs contrary to the purpose of the applicable statute. (Omari v. Holder, 3/4/09)

3/4/09 AILA Doc. No. 09033167. Cancellation, Suspension & 212(c), Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 En Banc Decision Addresses DUI and Crimes Involving Moral Turpitude

Petition for review denied on basis that the determination that DUI offenses committed with the knowledge that one’s driver’s license has been suspended or otherwise restricted are crimes involving moral turpitude is a reasonable interpretation of the INA. (Marmolejo-Campos v. Holder, 3/4/09)

3/4/09 AILA Doc. No. 09041460. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds Appellant Failed to Prove Invalidity of Written Waiver of Rights

The court denied the appeal concluding that when challenging the validity of a written waiver of rights in a deportation proceeding, the alien bears the burden of proving that the waiver is invalid. (Richardson v. U.S., 3/4/09)

3/4/09 AILA Doc. No. 09041560. Removal & Relief
Cases & Decisions, Federal Court Cases

Supreme Court Reverses and Remands in Negusie v. Holder

The Supreme Court reverses and remands to the BIA, finding error in the misapplication of Fedorenko regarding coerced conduct and the persecutor bar to asylum. (Negusie v. Holder, 3/3/09)

3/3/09 AILA Doc. No. 09030363. Asylum & Refugees, Removal & Relief
AILA Public Statements, Correspondence

Sign-On Letter to Attorney General Holder Regarding Matter of Silva-Trevino

A 3/3/09 AILF sign-on letter to Attorney General Holder urges the withdrawal of Attorney General Mukasey's opinion in Matter of Silva-Trevino, which discards categorical analysis in determining whether a prior conviction is a crime involving moral turpitude.

3/3/09 AILA Doc. No. 09030565. Crimes, Removal & Relief

Testimony Before House Appropriations Committee on Medical Care for Immigrant Detainees

On 3/3/09, the Subcommittee on Homeland Security of the House Appropriations Committee held a hearing on “Health Services for Detainees in U.S. Immigrations and Customs Enforcement Custody.”

3/3/09 AILA Doc. No. 09030460. Congress, Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Concludes Petitioner’s Claim that Statements Made to Arresting Officer were Unlawfully Obtained is Meritless

Court rejects the petition for review, finding that the petitioner failed to demonstrate that INS violated its regulations in obtaining the information used to prepare the Form I-213, Record of Deportable/Inadmissible Alien. Samayoa-Martinez v. Holder (3/3/09)

3/3/09 AILA Doc. No. 09032775. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Upholds Denial of Application for Cancellation of Removal for Petitioner with Pre-IIRIRA Conviction for Marriage Fraud

CA7 concludes that the petitioner’s visa-fraud conviction disqualifies him from cancellation of removal. Finds that the petitioner cannot show that he has been harmed by his reliance on pre-IIRIRA law because he would have been ineligible under the pre-IIRIRA regime. (Obi v. Holder, 3/3/09)

3/3/09 AILA Doc. No. 09033060. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Federal Agencies, Agency Memos & Announcements

Immigration Law Advisor, February 2009 (Vol. 3, No. 2)

Immigration Law Advisor, a legal publication from EOIR, with an article on differentiating the material support and persecutor bars in asylum claims, federal court activity for January 2009, and a regulatory update.

3/1/09 AILA Doc. No. 14041651. Asylum & Refugees, Removal & Relief

EOIR FY2008 Statistical Yearbook

The EOIR Statistical Yearbook for FY2008 provides data on proceedings reviewed and completed by the immigration courts and the BIA.

3/1/09 AILA Doc. No. 09040936. Removal & Relief

DHS OIG Releases Report on Tracking and Transfer of Detainees

The DHS Office of Inspector General released a March 2009 report on the results of an audit of ICE's detainee tracking, transfer processes, and medical screenings and physical examinations.

3/1/09 AILA Doc. No. 09041362. Detention & Bond, Removal & Relief
Media Tools

Section-by-Section Analysis of Immigration Oversight and Fairness Act (H.R. 1215)

Section-by-section analysis of the Immigration Oversight and Fairness Act (H.R. 1215), introduced by Rep. Roybal-Allard (D-CA) on 2/26/09. This document was produced by AILA and the Lutheran Immigration and Refugee Service.

2/27/09 AILA Doc. No. 09022767. Detention & Bond, Removal & Relief

Bill Text of Immigration Oversight and Fairness Act

On 2/26/09, Rep. Roybal-Allard introduced the Immigration Oversight and Fairness Act (H.R. 1215), a bill which aims to reform immigration detention procedures.

2/26/09 AILA Doc. No. 09022765. Asylum & Refugees, Congress, Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Says BIA Erred in Focusing on Date of Conviction Rather Than Date Proceedings Began

The court found the petitioner eligible for 212(c) relief because IIRIRA's repeal of 212(c) does not apply to foreign nationals whose deportation proceedings predate the Act's effective date. (Garcia-Padron v. Holder, 2/26/09)

2/26/09 AILA Doc. No. 09031361. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Federal Agencies, Practice Resources

Fact Sheet Regarding Asylum-Related Provisions of the TVPRA

The AILA Asylum committee offers a February 23, 2009, Fact Sheet from USCIS Asylum Division concerning the implementation of the asylum-related provisions of the Trafficking Victims Protection Reauthorization Act (TVPRA).

2/25/09 AILA Doc. No. 09022563. Humanitarian Parole, Removal & Relief, Unaccompanied Children