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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Fairness in Immigration Litigation Act

Senators Hatch (R-UT), Kyl (R-AZ), Chambliss (R-GA) and Cornyn (R-TX) on 5/19/04 introduced the Fairness in Immigration Litigation Act, which claims to “restore fairness to the immigration litigation process and integrity to our immigration system.” AILA opposes as a broad attack on judicial review.

5/19/04 AILA Doc. No. 04052062. Congress, Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Holds False Tax Filing Is Not an Aggravated Felony

The court held that a conviction for filing false tax returns does not fall within INA §101(a)(43)(M)(i), reasoning that (M)(ii), which classifies tax evasion as an aggravated felony, would be superfluous if (M)(i) were construed to apply to tax offenses. (Ki Se Lee v. Ashcroft, 5/19/04)

5/19/04 AILA Doc. No. 04062861. Crimes, Removal & Relief
Federal Agencies

EOIR FY2003 Statistical Year Book

EOIR FY2003 Statistical Year Book for the OCIJ, the BIA, and OCAHO, covering work during the past five years. The Year Book contains data and charts on, among other things, proceedings received and completed by type, disposition, and nationality.

Cases & Decisions, Federal Court Cases

CA8 Holds that It Lacks Authority to Review BIA Issuance of Affirmance Without Opinion

CA8 held it lacked jurisdiction to review the claim that the BIA improperly employed its Affirmance Without Opinion (AWO) procedure.(Ngure v. Ashcroft, 5/17/04)

5/17/04 AILA Doc. No. 04070910. Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Holds that Excessively High Bonds that Have the Effect of Preventing Release are Presumptively Unreasonable

CA5 held that a reasonable and “appropriate in the circumstances” bond is permissible under Zadvydas; and that a bond which prevents release because of inability to pay, resulting in potentially permanent detention, is presumptively unreasonable. (Shokeh v. Thompson, 5/10/04)

5/10/04 AILA Doc. No. 04052163. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Chief Immigration Judge Defends Video Hearings

Chief Immigration Judge Michael Creppy defends the use of video hearings in response to a letter from Christina DeConcini of CLINIC.

5/10/04 AILA Doc. No. 04070864. Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Finds No Jurisdiction to Review Denial of I-751 Waiver

The court held that INA §242(a)(2)(B)(ii) barred jurisdiction to review the denial of an application for a waiver of the joint filing requirement for removal of conditions on permanent resident status under INA §216(c)(4). (Urena-Tavarez v. Ashcroft, 5/7/04)

Federal Agencies, Agency Memos & Announcements

USCIS Memo Addresses Deferred Action for U Nonimmigrant Applicants

A 5/6/04 memo from William Yates, USCIS Associate Director for Operations, regarding VSC authority to assess deferred action for aliens seeking U relief while in removal proceedings.

Cases & Decisions, Federal Court Cases

CA1 Rejects Ineffective Assistance of Counsel Claim

The court rejected Petitioner’s ineffective assistance of counsel claim as inadequate where Petitioner’s affidavit did not adequately describe the scope of the attorney-client agreement. (Wang v. Ashcroft, 5/5/04)

5/5/04 AILA Doc. No. 04051162. Removal & Relief
Media Tools

This Week in Congress: May 3, 2004

This is an active week in Congress on immigration issues, with the introduction of a Democratic comprehensive immigration reform bill, and both the House and Senate Judiciary Committees reviewing issues of concern.

Cases & Decisions, Federal Court Cases

CA7 Upholds IJ's Instruction to Unprepared Counsel to Proceed on Relief Applications

The Court held that the phrasing of counsel's Motion to Expedite Hearing was the cause of any confusion regarding what would be heard at the expedited hearing, and thus there was no due process violation in the IJ's insistence on proceeding.(Kuschchak v. Ashcroft, 5/3/04)

5/3/04 AILA Doc. No. 04051266. Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Rejects Government's Arguments on Exception to Zadvydas' Indefinite Detention Bar

CA9 rejected the govt's argument of an exception to Zadvydas' 6-month limitation on detention of post-final order permanent residents for particularly dangerous individuals where there are circumstances, such as mental illness, that help to create the danger. (Tuan Thai v. Ashcroft, 5/3/04)

5/3/04 AILA Doc. No. 04051161. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

USCIS Manual on Crimes Involving Moral Turpitude

USCIS manual outlining issues related to crimes involving moral turpitude.

5/1/04 AILA Doc. No. 07082460. Crimes, Removal & Relief

Better Data Needed to Ensure ICE Compliance with Zadvydas

Following a study of ICE's compliance with the Supreme Court decision in Zadvydas, the GAO recommends that ICE collect complete and accurate information to assure compliance, determine ICE deportation officer staffing needs, and provide guidance to deportation officers on prioritizing.

5/1/04 AILA Doc. No. 04062915. Detention & Bond, Removal & Relief
Federal Agencies, Liaison Minutes

State Bar of Texas Meeting Minutes (4/30/04)

The 4/30/04 minutes from the last quarterly meeting of the State Bar of Texas, Committee on Laws Relating to Immigration & Nationality, address a variety of issues. The committee met with various directors and discussed current procedures, policies, staffing levels, and more.

4/30/04 AILA Doc. No. 04062164. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

CBP Memo Clarifying a 2002 “Zero Tolerance Policy” for Exercising Discretion

CBP 4/30/04 memo clarifying a 3/22/02 INS memo, “Zero Tolerance Policy” and reminding CBP directors that while discretion must be exercised consistent with homeland security concerns, appropriate and principled discretion should be exercised. Received through American Immigration Council FOIA.

CRS Report on Legislation on Immigration-Related Detention

The Congressional Research Service (CRS) report on the detention of noncitizens, including changes related to the creation of DHS, authority for detention, when mandatory detention is warranted, detention statistics, and legislation in the 108th Congress related to detention.

4/28/04 AILA Doc. No. 04042963. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Fact Sheet on the Immigration Court Process (Updated 4/28/05)

EOIR fact sheet addressing the immigration court process and outlining the types of immigration hearings, including removal, bond redetermination, relief from removal, asylum, expedited removal, CAT protection, and more.

4/28/04 AILA Doc. No. 04080165. Asylum, Detention & Bond, Expedited Removal, Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Holds Parolees Are Subject to INA §238(b)

Rejecting the argument that INA §238(b) should apply only to nonimmigrants, the court held that a parolee can be subject to administrative removal without a hearing. (Bamba v. Rile, 4/27/04)

4/27/04 AILA Doc. No. 04043068. Admissions & Border, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Holds Conviction Under Drive-By Shooting Statute To Be a Crime of Violence

The Fifth Circuit held that a conviction under the Oklahoma drive-by shooting statute, for driving a vehicle from which a shot was fired, is a crime of violence and thus an aggravated felony. (Nguyen v. Ashcroft, 4/27/04)

4/27/04 AILA Doc. No. 04050362. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Withdraws Prior Decision Finding No Aggravated Felony in Drug Case

To review whether jurisdiction vests with the Court, CA9 withdrew its prior decision holding that a state felony drug offense is not an aggravated felony unless the offense contains a drug trafficking element or is punishable under federal law. (Cazarez-Gutierrez v. Ashcroft, 04/26/04)

4/26/04 AILA Doc. No. 04051163. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Upholds Regulation Barring Parolees Who Are “Arriving Aliens” From Adjusting While In Removal Proceedings

Joining the Eight Circuit and rejecting the rationales of the First, Third, Ninth and Eleventh Circuits, the court upheld the validity of 8 CFR §1245.1(c)(8) as “a valid exercise of the Attorney General’s discretion under [INA §245(a)].” (Momin v. Gonzales, 4/24/06)

4/24/04 AILA Doc. No. 06050360. Adjustment of Status, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Holds Failure to Notify Petitioner of Impact of Departure Is Violation of Due Process

The Ninth Circuit held that application of the rule that a departure while a BIA appeal is pending results in withdrawal of the appeal, where the petitioner was not notified of the impact of the departure, violates due process. (Martinez De Bojorquez v. Ashcroft, 4/22/04)

4/22/04 AILA Doc. No. 04043071. Removal & Relief
Federal Agencies, Agency Memos & Announcements

CBP Memo: Enforcement Activities at Schools and Places of Worship

These two legacy border patrol memoranda relate to enforcement activities in schools, places of worship, funerals, and other religious ceremonies.

4/20/04 AILA Doc. No. 08050774. Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Applies Bar to Relief for Overstaying VD To Motion to Reopen Petitioner

The Ninth Circuit held that the bar to relief for overstaying voluntary departure applies to an individual who filed a motion to reopen for adjustment of status after the VD period ended but before the end of the 90-day period for a motion to reopen. (DeMartinez v. Ashcroft, 4/16/04)

4/16/04 AILA Doc. No. 04043066. Removal & Relief