Featured Issues

Featured Issue: Representing Clients Before ICE

2/3/25 AILA Doc. No. 25010904. Removal & Relief

This resource page combines resources for attorneys representing clients before ICE. For information about why AILA is calling for the reduction and phasing out of immigration detention, please see our Featured Issue Page: Immigration Detention and Alternatives to Detention.

Quick Links

Communicating with OPLA, ERO, and CROs

The Office of the Principal Legal Advisor (OPLA) includes 1300 attorneys who represent the Department of Homeland Security (DHS) in immigration removal proceedings before the Executive Office for Immigration Review (EOIR). OPLA litigates all removal cases as well as provides legal counsel to ICE personnel. At present, there are 25 field locations throughout the United States.

Enforcement and Removal Operations (ERO) manages all aspects of immigration enforcement from arrest, detention, and removal. ERO has 24 field office locations. ERO also manages an “alternative to detention” program that relies almost exclusively on the “Intensive Supervision Appearance Program (ISAP)” to monitor individuals in removal proceedings.

Since 2016, ICE has had an Office of Partnership and Engagement (formerly Office of Community Engagement) to be a link between the agency and stakeholders. As part of this office, Community Relations Officers (CROS) are assigned to every field office to work with local stakeholders such as attorneys and nonprofit organizations.

*Headquarters does not provide direct contact numbers or emails for individual employees.* (AILA Liaison Meeting with ICE on April 26, 2023)(AILA Doc. No. 23033004). However, attorneys can contact Chapter Local ICE Liaisons as they may have this information provided to them via local liaison engagement.

Latest on Enforcement Priorities & Prosecutorial Discretion

Executive Order 14159 (90 FR 8443, 1/29/25) directs DHS to set priorities that protect the public safety and national security interests of the American people, including by ensuring the successful enforcement of final orders of removal, enforcement of the INA and other Federal laws related to the illegal entry and unlawful presence of [noncitizens] in the United States and the enforcement of the purposes of this order. Given the January 25, 2025, confirmation of DHS Secretary Kristi Noem, a memorandum detailing enforcement priorities may be issued in the coming weeks.

An unpublished ICE memo from acting ICE Director Caleb Vitello entitled “Interim Guidance: Civil Immigration Enforcement Actions in or near Courthouses” makes reference to targeted noncitizens and includes:

  • National security or public safety threats;
  • Those with criminal convictions;
  • Gang members;
  • Those who have been ordered removed from the United States but have failed to depart; and/or
  • Those who have re-entered the country illegally after being removed.

Procedures and email inboxes created under the Biden Administration to request Prosecutorial Discretion no longer appear on the ICE website. AILA members are encouraged to review current DOJ regulations entitled “Efficient Case and Docket Management in Immigration Proceedings” for alternative basis for seeking termination or administrative closure.

Access to Counsel

Filing Administrative Complaints on Behalf of Detained and Formerly Detained Clients

Selected ICE Policies and Current Status

For comprehensive comparison of current and prior ICE policies, please review the “Immigration Policy Tracker (IPTP).” The IPTP is a project of Professor Lucas Guttentag working with teams of Stanford and Yale law students and leading national immigration experts.

Pre Jan 20, 2025 Status Current Status
  • Unclear but attorneys should proceed with extreme caution in pursuing any relief under this process.
  • No recission has been announced.
  • No recission has been announced.
  • The 2021 Victim Centered Approach Memo and the 2011 Prosecutorial Discretion for Victims and Witness have allegedly been rescinded though no public updated guidance available at the time of this updated. Media reports suggest that the requirements of 1367 protections should still be followed.
  • No recission has been announced.
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Cases & Decisions, Federal Court Cases

CA4 Finds BIA Abused Its Discretion by Ignoring Evidence That Honduras Was Unable or Unwilling to Control MS-13

The court held that the BIA abused its discretion when it ignored credible, unrebutted, and legally significant evidence in the record and concluded that petitioner failed to demonstrate that the Honduran government was unable or unwilling to control MS-13. (Ramos Marquez v. Bondi, 11/19/25)

12/19/25 AILA Doc. No. 25120101. Asylum & Refugees, Removal & Relief
Featured Issues

Featured Issue: U.S. Immigration Courts under Trump 2.0

The U.S. immigration court system plays a critical role in ensuring due process and fair hearings for people facing deportation. But the Trump Administration has made significant changes that challenge the integrity of these courts. On this page, you will find news and resources on these changes.

Cases & Decisions, Federal Court Cases

CA9 Denies Motion to Stay Removal Where Petitioners Failed to Show Likelihood of Success or Irreparable Harm

The court denied the petitioners’ motion for a stay of removal pending disposition of their petition for review, finding they failed to show a likelihood of success on their asylum and related claims or particularized irreparable harm. (Rojas-Espinoza v. Bondi, 10/24/25, amended 11/25/25)

12/3/25 AILA Doc. No. 25102803. Asylum & Refugees, Removal & Relief
Congressional Updates

AILA Endorses The Temporary Immigration Judge Integrity Act

Sen. Adam Schiff (D-CA) and Rep. Juan Vargas (CA-52) introduced the Temporary Immigration Judge Integrity Act. This proposed bill would ensure temporary immigration judges have essential expertise in immigration law to enhance the fairness and accuracy of adjudications. AILA endorses this bill.

12/3/25 AILA Doc. No. 25120301. Removal & Relief
Examples & Questions

Call for Examples: Harmful Impacts of Expedited Removal on Paroled Individuals in Support of Amicus Brief

AILA’s Amicus Committee is preparing a “stories” amicus brief to illustrate the real-world human and systemic harms caused by the government’s unlawful application of expedited removal to paroled individuals—from the perspective of immigration attorneys and their clients.

12/1/25 AILA Doc. No. 25120109. Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Adopts Time-of-Conviction Rule for Controlled Substance Removability

Denying the petition for review, the court held that the relevant Controlled Substances Act (CSA) definition for determining removability under INA §237(a)(2)(B)(i) is the one in effect at the time of the noncitizen’s conviction, not at the time of removal proceedings. (Dor v. Bondi, 12/1/25)

12/1/25 AILA Doc. No. 25120801. Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Upholds Asylum Denial as to Single Salvadoran Female Salon Owner

The court held that substantial evidence supported the denial of asylum and other relief, finding that petitioner’s proposed PSGs were not cognizable, that internal relocation was reasonable, and that she failed to show a likelihood of torture. (Cristales-de Linares, et al. v. Bondi, 12/1/25)

12/1/25 AILA Doc. No. 25120804. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA9 Upholds Denial of Asylum as to Sikh Mann Party Member from India

The court held that threats from masked men, two brief beatings, and a short detention of the Sikh Mann party member petitioner did not rise to the level of past persecution, and found that he could avoid future persecution by relocating within India. (Singh v. Bondi, 12/1/25)

12/1/25 AILA Doc. No. 25120805. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA1 Upholds BIA’s Finding That Colombian Government Was Able to Protect Bakery Owner from Gang Threats

The court held that substantial evidence supported the BIA’s finding that the Colombian government was able to protect petitioner and his family from gang threats, and thus found he failed to show the required nexus for his asylum or withholding claims. (Restrepo Castano v. Bondi, 11/26/25)

11/26/25 AILA Doc. No. 25120363. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Denies Stay of Removal, Noting That Equitable Relief Is Not a Right

The court issued a published an order denying the petitioner’s request for a stay of removal, emphasizing that equitable relief, even if it is temporary or short, is never a matter of right or convenience. (Labrador Gutierrez v. Bondi, 11/26/25)

11/26/25 AILA Doc. No. 25120364. Removal & Relief
Cases & Decisions, Federal Court Cases

CA2 Finds Agency Failed to Address Whether Guatemalan Government Would Acquiesce to Petitioner’s Torture by a Private Actor

The court held that the BIA and IJ failed to properly assess whether the Guatemalan government would acquiesce to petitioner being tortured in prison by private parties who would target him if he returned to Guatemala, and thus remanded his claim for CAT relief. (B.G.S. v. Bondi, 11/24/25)

11/24/25 AILA Doc. No. 25120362. Asylum & Refugees, Removal & Relief
Federal Agencies, FR Regulations & Notices

DOJ 30-Day Notice of Revision and Extension of Forms EOIR-42A and EOIR-42B

DOJ notice of revision and extension of Form EOIR-42A, Application for Cancellation of Removal for Certain Permanent Residents and Form EOIR-42B, Application for Cancellation of Removal and Adjustment of Status for Certain Nonpermanent Residents. Comments are due 12/22/25. (90 FR 52708, 11/22/25)

11/21/25 AILA Doc. No. 25112101. Adjustment of Status, Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Holds That Age of Qualifying “Child” under INA §240A(b)(1)(D) Is Ascertained When IJ Renders Its Decision

The court reversed BIA’s order finding petitioner no longer qualified as a “child” under the INA because she was over 21 at the time of the BIA’s decision, holding that age for cancellation under §240A(b)(1)(D) is determined when the IJ issues its decision. (Perez-Perez v. Bondi, 11/21/25)

11/21/25 AILA Doc. No. 25120102. Cancellation, Suspension & 212(c), Removal & Relief
Cases & Decisions, Federal Court Cases

CA6 Upholds BIA’s Finding That No Extraordinary Circumstances Excused VAWA Petitioner’s Six-Year Delay in Filing Motion to Reopen

The court held that the BIA did not err in concluding that the Violence Against Women Act (VAWA) petitioner failed to show extraordinary circumstances that would excuse his six-year delay in seeking reopening under the special rule for VAWA petitioners. (Sarkisov v. Bondi, 11/21/25)

11/21/25 AILA Doc. No. 25120103. Removal & Relief, VAWA
Practice Resources

Updated Practice Pointer: USCIS Transition to “Electronic Payments” and Implements ACH Debit Payment Option for Filing Fees

AILA's USCIS Operations Committee share an updated practice pointer on the implementation of ACH debit payments following updated information released by USCIS post implementation.

11/20/25 AILA Doc. No. 25093003. Business Immigration, Family Immigration, Removal & Relief
Federal Agencies, FR Regulations & Notices

ICE Notice of FY26 Adjustments for Inflation for Certain Fees Required by H.R. 1

ICE announced FY26 inflationary adjustments to certain fees required by H.R. 1, effective 12/1/25. The adjusted fee amounts for individuals removed in absentia and inadmissible individuals arrested between ports of entry are $5,130. (90 FR 52425, 11/20/25)

11/20/25 AILA Doc. No. 25112031. Admissions & Border, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That VAWA Waiver Excuses Only Time Limits, Not Numerical Bar on Motions to Reopen

The BIA held that under INA §240(c)(7)(C)(iv)(III), the extraordinary circumstances or extreme hardship waiver for motions to reopen only applies to temporal limitations for filing a motion to reopen to apply for relief under VAWA. Matter of B–S–H–, 29 I&N Dec. 313 (BIA 2025)

11/19/25 AILA Doc. No. 25112004. Removal & Relief, VAWA
Cases & Decisions, Federal Court Cases

CA9 Holds That Minor Defects in Petition for Review Did Not Warrant Dismissal Under INA §242(c)

The court held that the petitioner’s failure to comply with the precise requirements of INA §242(c) did not warrant dismissing or denying his petition, finding that imperfections in his filing did not deprive the government of notice or result in prejudice. (Kazarian v. Bondi, 11/18/25)

11/18/25 AILA Doc. No. 25112508. Removal & Relief
Federal Agencies, FR Regulations & Notices

DHS Notice of U.S.-Ecuador Agreement on Transfer of Third-Country Nationals to Ecuador

DHS published the Agreement between the Government of the United States of America and the Government of the Republic of Ecuador relating to the transfer of third-country nationals to Ecuador, effected by exchange of diplomatic notes on 7/16/25 and 7/23/25. (90 FR 51376, 11/17/25)

11/17/25 AILA Doc. No. 25111700. Asylum & Refugees, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Holds That Isolated Police Refusal Does Not Establish Government Unwillingness to Protect

The BIA held that a single attempt to report harm by private actors to local police, without further police harm or evidence of widespread collusion with the alleged persecutors, does not show the government is unable or unwilling to protect. Matter of K-S-H-, 29 I&N Dec. 307 (BIA 2025)

11/17/25 AILA Doc. No. 25111701. Asylum & Refugees, Removal & Relief
Cases & Decisions, Federal Court Cases

CA10 Holds That Recidivist DUI Conviction Showed Lack of Good Moral Character for Cancellation of Removal Purposes

The court found that the BIA properly concluded that the recidivist nature of the petitioner’s 2017 DUI conviction, his fourth such offense, demonstrated lack of good moral character under INA §240A(b)(1)(B) within the 10-year period. (Luna-Corona v. Bondi, 11/17/25)

11/17/25 AILA Doc. No. 25112501. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Cases & Decisions, DOJ/EOIR Cases

BIA Finds IJ Improperly Granted Administrative Closure Absent Prima Facie SIJ Eligibility

The BIA held that, given the respondent’s failure to submit evidence of his prima facie eligibility for SIJ classification and the extended delay in the availability of a visa, the IJ erred in granting administrative closure. Matter of Cahuec Tzalam, 29 I&N Dec. 300 (BIA 2025)

11/14/25 AILA Doc. No. 25111401. Removal & Relief, Special Immigrant Juveniles
Practice Resources

Practice Alert: Information on New Temporary Immigration Judges

AILA National shares a practice alert with information on twenty-five recently appointed temporary immigration judges (TIJ) who began adjudicating cases on 10/27/25. Available information includes judge name, court of practice, personal biographies, and more.

11/13/25 AILA Doc. No. 25110608. Removal & Relief
Cases & Decisions, Federal Court Cases

CA4 Holds That Petitioner’s Virginia Conviction for Receipt of Stolen Property Was a CIMT

On remand from the Supreme Court in light of Loper Bright, the court held that the petitioner’s conviction in Virginia for receipt of stolen property was a crime involving moral turpitude (CIMT) rendering him ineligible for cancellation of removal. (Solis-Flores v. Bondi, 11/13/25)

11/13/25 AILA Doc. No. 25112500. Cancellation, Suspension & 212(c), Crimes, Removal & Relief
Cases & Decisions, Federal Court Cases

CA5 Holds Forfeiture Order Can Constitute Clear and Convincing Evidence of Funds Laundered under INA §101(a)(43)(D)

The court held that an unrebutted forfeiture order entered against a noncitizen finding a specific amount of laundered funds attributable to their conduct of conviction can be clear and convincing evidence of the funds amount under INA §101(a)(43)(D). (Dominguez Reyes v. Bondi, 11/6/25)

11/12/25 AILA Doc. No. 25111200. Crimes, Removal & Relief