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

USCIS and ICE Q&A on Procedures Implementing EOIR Regulations on Background and Security Checks

USCIS and ICE issued a Q&A regarding EOIR background check regulations for aliens seeking relief from removal.

8/17/06 AILA Doc. No. 06081768. Adjustment of Status, Asylum, Removal & Relief
Federal Agencies, Agency Memos & Announcements

USCIS and ICE Fact Sheet: Procedures Implementing EOIR Regulations on Background and Security Checks

USCIS/ICE fact sheet discussing procedures implemented on 4/1/05 in order to facilitate compliance with EOIR regulations prohibiting IJs and the BIA from granting relief from removal or protection benefits to an alien before DHS reports that the identity, background and security checks are complete.

8/17/06 AILA Doc. No. 06081767. Adjustment of Status, Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Finds Jurisdiction to Stay BIA’s Order of Voluntary Departure

The court held that INA §242(a)(1) permits it to stay a BIA order of voluntary departure, and that a BIA order granting voluntary departure with an alternate order of removal is a final order subject to judicial review. (Thapa v. Gonzales, 8/16/06)

8/16/06 AILA Doc. No. 06101265. Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Holds “Grandfathered” Status under INA §245(i) Does Not Preclude Removal

The court held that “grandfathered” status under INA §245(i) did not preclude Petitioner from being removed when a visa number was unavailable. The court further held that INA §242(g) bars jurisdiction to review Petitioner’s equal protection challenge. (Hadayat v. Gonzales, 8/15/06)

Cases & Decisions, Federal Court Cases

CA1 Upholds IJ’s Finding of Changed Country Conditions in Albania

The court found that the IJ correctly afforded Petitioner a presumption of a well-founded fear based on past persecution, but that substantial evidence indicated that there had been a fundamental change in conditions in Albania. (Tota v. Gonzales, 8/14/06)

8/14/06 AILA Doc. No. 06091912. Asylum, Removal & Relief

GAO Releases Study on EOIR’s Caseload Performance Reporting

The GAO study addresses the trend in immigration court caseloads, how cases are assigned and managed by the OCIJ, and how the EOIR/OCIJ evaluate the performance of immigration courts.

8/11/06 AILA Doc. No. 06091926. Removal & Relief
Federal Agencies, Agency Memos & Announcements

Attorney General Announces Measures Intended to Improve Immigration Courts and BIA

Attorney General Alberto Gonzales directs the implementation of 22 measures intended to improve the immigration courts and Board of Immigration Appeals, based on the recommendations of a review team assembled by the Deputy Attorney General and Associate Attorney General.

8/9/06 AILA Doc. No. 06080968. Removal & Relief
Federal Agencies, Agency Memos & Announcements

Attorney General Gonzales Outlines Reforms for Immigration Courts and BIA

AG Alberto Gonzales announced that DOJ will implement new measures to improve the Immigration Courts and BIA. The measures include performance evaluations, an immigration law exam, a proposal for the authority to sanction, budget increases, technological improvements and streamlining practices.

8/9/06 AILA Doc. No. 06091260. Removal & Relief
Federal Agencies, Agency Memos & Announcements

DOJ Press Release on Reforms Intended to Improve Immigration Courts and BIA

Press release from DOJ announcing Attorney General Alberto Gonzales' directive to implement 22 measures intended to improve the immigration courts and Board of Immigration Appeals.

8/9/06 AILA Doc. No. 06080969. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA10 Holds VWP Entrant Has No Right to Contest Removal Through Adjustment of Status

The court held that a VWP entrant who overstays and files for adjustment of status before issuance of a removal order has waived his right to contest the removal order. (Ferry v. Gonzales, 8/8/06)

Cases & Decisions, Federal Court Cases

CA2 Holds Issue Exhaustion Is Not Required by INA §242(d)(1)

The court held that INA §242(d)(1) does not make issue exhaustion a statutory jurisdictional requirement and that failure to exhaust specific issues may be waived by the Attorney General. (Zhong v. DOJ, 8/8/06)

8/8/06 AILA Doc. No. 06101315. Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Finds Violation of Asylum Applicant’s Right to Confidentiality

The court held that the government violated 8 CFR §208.6 and rejected its post hoc rationale for the breach. The court also held that the adverse credibility finding, based on a consular report, was not supported by substantial evidence. (Lin v. Gonzales, 8/3/06)

8/3/06 AILA Doc. No. 06091915. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 on Burden of Showing Effect of Vacated Convictions

The court held that the BIA did not err in placing the burden on the petitioner to show that a conviction that was vacated after a final order of removal had been entered was vacated based on a procedural defect. (Rumierz v. Gonzales, 8/3/06)

8/3/06 AILA Doc. No. 06101264. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Discusses Retroactivity of Cancellation of Removal Under INA §240A

CA9 held that Congress clearly intended to limit the availability of cancellation of removal under INA §240A to those who had not previously been granted relief under former §212(c). The court also held that §240A did not have a retroactive effect. (Maldonado-Galindo v. Gonzales, 8/3/06)

Federal Agencies, Agency Memos & Announcements

President Bush on Comprehensive Immigration Reform in Texas

In an address on comprehensive immigration reform, President Bush discussed increased funding for border security, the end of "catch and release", worksite enforcement, documentation for temporary workers, and deportation.

Cases & Decisions, DOJ/EOIR Cases

BIA Holds Domestic Battery Not a CIMT or “Crime of Domestic Violence”

The BIA held that a conviction for domestic battery under the California Penal Code does not qualify categorically as a conviction for a “crime involving moral turpitude” under INA or, in Ninth Circuit removal proceedings, as a “crime of violence”. Matter of Sanudo, 23 I&N Dec. 968 (BIA 2006)

8/1/06 AILA Doc. No. 06080360. Crimes, Removal & Relief
Federal Agencies, Agency Memos & Announcements

Outline for CBP Officer Basic Training Law Course

CBP student outline of the Officer Basic Training Law Course dated 8/1/06. Information discussed includes the Fourth Amendment, border searches, border crimes and violations, the role of a CBP officer, and more. Guidance obtained through the CBP FOIA Library.

8/1/06 AILA Doc. No. 06080190. Admissions & Border, Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Remands for Further Proceedings After Reversing In Absentia Removal Order Resulting from Slight Lateness

The court granted the petition for review after finding there was no failure to appear after petitioner arrived 15-20 minutes late and the in absentia order was entered in violation of petitioner’s right to due process. (Cabrera-Perez v. Gonzales, 8/1/06)

8/1/06 AILA Doc. No. 19021131. Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds “Fundamental Defect” in Reinstatement Proceedings

The court held that the INS’s failure to inform Appellant of his right to appeal his reinstatement order, combined with misleading language in the reinstatement notice was a fundamental defect which, if prejudicial, rendered the proceeding fundamentally unfair. (U.S. v. Charleswell, 8/1/06)

8/1/06 AILA Doc. No. 06100699. Removal & Relief

TRAC Study on Immigration Judges and Requests for Asylum

Study from Transactional Records Access Clearinghouse (TRAC) at Syracuse University focuses on the disparities between immigration judges, and between represented and unrepresented cases, in asylum decisionmaking.

7/31/06 AILA Doc. No. 06073169. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Holds Accessory After the Fact is Crime Involving Moral Turpitude

CA9 held that a conviction under California Penal Code §32, accessory after the fact, is a crime involving moral turpitude. Conviction requires a knowing, affirmative act to conceal a felony with the specific intent to hinder prosecution. (Navarro-Lopez v. Gonzales, 7/31/06)

Cases & Decisions, Federal Court Cases

CA7 Remands Asylum Claim For Lack of Analysis of in BIA Decision

The court found that, where the BIA’s one-sentence opinion assumed that Petitioner was credible but found that he had not met his burden of proof, the opinion lacked sufficient analysis to support the conclusion that the IJ and BIA’s errors were harmless. (Pramatarov v. Gonzales, 7/27/06)

7/27/06 AILA Doc. No. 06082866. Asylum, Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Says Torture Does Not Include Deprivation of Property

The court reviewed the CAT regulations and found no indication that the definition of torture was intended to encompass destruction, thefts, expropriations, or other deprivations of property. (Jo v. Gonzales, 7/27/06)

7/27/06 AILA Doc. No. 06090566. Asylum, Removal & Relief
Federal Agencies, Agency Memos & Announcements

BIA to Grant Fewer and Shorter Extensions of Initial Briefing Deadlines

Beginning 8/14/06, the BIA will grant fewer and shorter extensions of initial briefing deadlines in detainee cases.

7/27/06 AILA Doc. No. 06072771. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds “Criminal Deportees” to Haiti Not a Particular Social Group

The court held that the BIA properly denied CAT protection because Petitioner did not demonstrate the specific intent element for torture and joined other circuits in finding that criminal deportees are not a social group. (Toussaint v. Atty. Gen. of U.S., 7/26/06)

7/26/06 AILA Doc. No. 06090877. Asylum, Removal & Relief