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

CA5 Says It Lacks Jurisdiction to Review IJ’s and BIA’s Findings That Conspiracy to Commit Wire Fraud Was a “Particularly Serious Crime”

The court held that it lacked jurisdiction to review petitioner’s argument that the IJ and BIA erred in finding his conspiracy to commit wire fraud offense was a “particularly serious crime” rendering him statutorily ineligible for withholding of removal. (Tibakweitira v. Wilkinson, 2/1/21)

2/1/21 AILA Doc. No. 21021632. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA7 Finds IJ and BIA Mischaracterized Evidence Pertaining to Asserted Hardship Where Petitioner Sought Cancellation of Removal

The court held that the BIA and the IJ failed to consider evidence that the petitioner’s removal would result in exceptional and extremely unusual hardship to his daughter, given that her hardship—a speech impairment—is aggravated by her emotional turmoil. (Martinez-Baez v. Wilkinson, 2/1/21)

2/1/21 AILA Doc. No. 21021634. Cancellation, Suspension & 212(c), Removal & Relief
AILA Public Statements, Correspondence

AILA and Partners Send Letter to President Biden on DOJ Reform of Immigration Courts and Enforcement Priorities

On February 1, 2021, AILA, along with 164 immigration, civil rights, and human rights organizations, sent a letter to President Biden urging reforms to ensure that the Department of Justice (DOJ) establishes fairness and integrity in the immigration courts and the immigration enforcement system.

2/1/21 AILA Doc. No. 21020137. Removal & Relief
Federal Agencies, Practice Resources

Practice Alert:  ICE Interim Enforcement Priorities

This alert provides a summary of President Biden’s Executive Order on the Revision of Civil Immigration Enforcement Policies and Priorities along with its implementing DHS memo. It also provides practice tips for members to consider based on the new priorities.

2/1/21 AILA Doc. No. 21020132. Prosecutorial Discretion, Removal & Relief
Practice Resources, Litigation Resources, Sample Briefs

Motion for Enlargement of Time to File Reply Brief - First Circuit

Sample motion to extend the briefing deadline for first circuit court of appeals. (Petition for Review; Miscellaneous Motion)

2/1/21 AILA Doc. No. 21050734. Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Says BIA Erred in Finding Petitioner’s Credible Testimony About Attempted Rape Did Not Show Persecution

The court held that petitioner’s credible testimony about her attempted gang rape in India was sufficient to establish past persecution, and that the BIA erred in imposing evidentiary requirements of ongoing injury or treatment beyond the attempted sexual assault. (Kaur v. Wilkinson, 1/29/21)

1/29/21 AILA Doc. No. 21021134. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Finds BIA Abused Its Discretion in Denying Petitioner’s Motion to Reopen and Remand to IJ

Where petitioner had filed a motion to reopen and remand his case to the IJ in light of his placement by USCIS on the U visa waiting list, the court held that the BIA abused its discretion in denying the motion by failing to follow its own precedents. (Granados Benitez v. Wilkinson, 1/28/21)

1/28/21 AILA Doc. No. 21021130. Humanitarian Parole, Removal & Relief, T & U Status
Cases & Decisions, DOJ/EOIR Cases

BIA Rules Individuals Who Cooperate with Law Enforcement May Constitute a Particular Social Group if Their Cooperation Is Public in Nature

BIA ruled that individuals who cooperate with law enforcement may constitute a particular social group if their cooperation is public and the evidence reflects that the society in question recognizes and provides protection for such cooperation. Matter of H-L-S-A, 28 I&N Dec. 228 (BIA 2021)

1/28/21 AILA Doc. No. 21012833. Removal & Relief
AILA Public Statements, Press Releases

U.S. Government Records Reveal Expanded Methods to Rush Deportations at Border

AILA, the Council, HRW, and Winston & Strawn LLP obtained documents about the Migrant Protection Protocols which reveal U.S. immigration agencies' efforts in 2019 to rapidly deport thousands of people from the United States through the little-known Electronic Nationality Verification (ENV) program.

1/27/21 AILA Doc. No. 21012700. Admissions & Border, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Finds Petitioner’s Conviction for Use of Unauthorized Social Security Number Was a CIMT

The court held that the petitioner’s conviction for the use of an unauthorized social security number in violation of 42 USC §408(a)(7)(B) was a crime involving moral turpitude (CIMT), such that the petitioner was ineligible for cancellation of removal. (Munoz-Rivera v. Wilkinson, 1/27/21)

1/27/21 AILA Doc. No. 21021133. Crimes, Removal & Relief

GAO Says ICE Can Further Enhance Its Planning and Oversight of 287(g) Agreements

GAO reviewed ICE’s management and oversight of the 287(g) program and found that while ICE has expanded the program, it has not established performance goals to cover all program activities, including oversight of law enforcement agency partners or measures to assess the program’s performance.

1/27/21 AILA Doc. No. 21022635. Removal & Relief
Practice Resources, Litigation Resources

Respondent’s Request for Extension of Briefing Period - BIA

Sample motion for a respondent’s request for extension of the briefing deadline for the Board of Immigration Appeals (BIA).

1/27/21 AILA Doc. No. 21050739. Removal & Relief

CRS Releases Legal Sidebar on Whether Mandatory Detention of Unlawful Entrants Seeking Asylum Is Constitutional

CRS updated its legal sidebar addressing the constitutionality of mandatory detention for certain asylum seekers after the Supreme Court’s decision to vacate the Ninth Circuit’s decision in Padilla v. ICE and to remand for further consideration in light of DHS v. Thuraissigiam.

1/27/21 AILA Doc. No. 19090935. Asylum & Refugees, Detention & Bond, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Finds Subsequent NTA Perfects Deficient NTA and Ends Accrual of Physical Presence for Purposes of Voluntary Departure

BIA ruled that if an NTA fails to specify time/place of initial removal hearing, a subsequent NTA with the information perfects the deficient NTA and ends the accrual of physical presence for purposes of voluntary departure. Matter of Viera-Garcia and Ordonez-Viera, 28 I&N Dec. 223 (BIA 2021)

1/26/21 AILA Doc. No. 21012636. Removal & Relief
Federal Agencies, FR Regulations & Notices

President Biden Issues Memorandum on Preserving and Fortifying DACA

On 1/20/21, President Biden issued a memorandum directing the DHS Secretary, in consultation with the Attorney General, to take all actions he deems appropriate, consistent with applicable law, to preserve and fortify DACA. (86 FR 7053, 1/25/21)

1/25/21 AILA Doc. No. 21012130. DACA, Removal & Relief
Federal Agencies, FR Regulations & Notices

President Biden Issues Executive Order Revising Civil Immigration Enforcement Policies and Priorities

On 1/20/21, President Biden issued an Executive Order revoking EO 13768 of 1/25/17, Enhancing Public Safety in the Interior of the United States, and directing officials to review any agency actions developed pursuant to EO 13768 and to take action as appropriate. (86 FR 7051, 1/25/21)

1/25/21 AILA Doc. No. 21012135. Removal & Relief
Federal Agencies, FR Regulations & Notices

USCIS and EOIR Delay Effective Date of Final Rule on Pandemic-Related Security Bars to Asylum and Withholding of Removal

USCIS and EOIR document delaying the effective date of the final rule “Security Bars and Processing” (85 FR 84160, 12/23/20), which was scheduled to become effective on 1/22/21. The effective date is delayed until 3/22/21. (86 FR 6847, 1/25/21)

1/25/21 AILA Doc. No. 21012143. Asylum & Refugees, Expedited Removal, Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Holds That BIA Erred in Finding Petitioner’s “Former Salvadoran MS-13 Members” PSG Lacked Particularity

Granting in part the petition for review, the court found to be unreasonable the BIA’s determination that the petitioner’s proposed particular social group (PSG) of “former Salvadoran MS-13 members” lacked particularity, and thus remanded his withholding claim. (Amaya v. Rosen, 1/25/21)

1/25/21 AILA Doc. No. 21021131. Asylum & Refugees, Removal & Relief
Federal Agencies, Practice Resources

Practice Alert: Federal Court Grants Partial Injunction of Proposed EOIR Fee Increases

AILA’s EOIR/ICE Liaison Committee provides a Practice Alert on a recent partial injunction that delayed implementation of the more egregious increases in immigration court fees for individuals in removal proceedings. The enjoined fee increases were scheduled to take effect on January 19, 2021.

1/23/21 AILA Doc. No. 21012236. Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Rules §58-37-8(2)(a)(i) of the Utah Code Is Divisible with Respect to the Specific Controlled Substance Involved in Statute Violation

The BIA ruled that §58-37-8(2)(a)(i) of the Utah Code, which criminalizes possession or use of a controlled substance, is divisible with respect to the specific “controlled substance” involved in a violation of that statute. Matter of Dikhtyar, 28 I&N Dec. 214 (BIA 2021)

1/22/21 AILA Doc. No. 21012237. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA3 Remands Where BIA Failed to Consider Petitioner’s Request for Equitable Tolling on the Merits

Vacating the BIA’s order denying the petitioner’s motion to reopen and remanding, the court held that the BIA erred in failing to consider the petitioner’s request for equitable tolling on the merits, because she had properly raised the issue before the BIA. (Nkomo v. Att’y Gen., 1/21/21)

1/21/21 AILA Doc. No. 21012536. Removal & Relief
Cases & Decisions, Amicus Briefs/Alerts

AILA and Partners Submit Amicus Brief on the Meaning and Application of “Arriving” Language in INA §235(b)(2)(C)

AILA and partners submitted a brief in response to BIA’s amicus invitation on determining an “arriving alien,” arguing that returning noncitizens apprehended 50 miles inside U.S. to Mexico for pending removal proceedings is improper because it runs afoul of the plain language of INA §235(b)(2)(C).

1/21/21 AILA Doc. No. 21021031. Admissions & Border, Removal & Relief
Federal Agencies, Agency Memos & Announcements

DHS Acting Secretary Issues Memorandum on Immigration Enforcement Policies

Acting DHS Secretary Pekoske issued a memorandum directing DHS components to conduct a review of immigration enforcement policies, and setting interim policies for civil enforcement during that review. Beginning 1/22/21, DHS will pause removals of certain noncitizens ordered deported for 100 days.

1/20/21 AILA Doc. No. 21012136. Prosecutorial Discretion, Removal & Relief

The Office of the Immigration Detention Ombudsman Releases 2020 Annual Report

The Office of the Immigration Detention Ombudsman provided its 2020 annual report with information about the office’s mission, detention facilities and standards, detention challenges faced during the year, existing challenges with compliance, site visits and medical findings, and more.

1/19/21 AILA Doc. No. 21012637. Detention & Bond, Removal & Relief
Federal Agencies, Agency Memos & Announcements

EOIR Releases Policy Memo on Adjudicator Independence and Impartiality

EOIR issued a policy memo (PM 21-15) reiterating and memorializing EOIR’s policy regarding adjudicator independence and impartiality. The memo notes that it remains EOIR policy that adjudicator decisions should be based solely on the record before the adjudicator and the applicable law.

1/19/21 AILA Doc. No. 21012033. Removal & Relief