Trump Administration 2.0 Immigration Updates

The information in this blog post is current as of Tuesday, July 29, 2025.

The information in this blog post is current as of July 2025. We are now over six months into the second Trump administration, and we understand that it can be overwhelming to keep up with the executive orders, actions, and updates that are released on a near daily basis during this administration. CILA is focused on what the executive orders and other administrative actions mean for unaccompanied immigrant children. With this post, we hope that those working with unaccompanied children can get an understanding of policies and actions that may affect their clients, in addition to knowing the key players and certain agency updates relevant to children’s immigration cases as we move forward in “Trump 2.0.”

This post will analyze select policies and actions by the Trump administration on immigration and how they may impact immigrant children. CILA first added this blog post in February 2025, and we have added content to include additional information and new updates. CILA’s review of the different immigration executive orders and agency actions is non-exhaustive.

Relevant actions are generally sectioned by agency, with the most recent update or action appearing at the top. Many of the actions relate to an Executive Order issued during this administration, with those actions detailed towards the end of the blog post. We have also included select large-scale immigration law changes at the end of this post, below Executive Orders and Actions.

It is important for advocates to know the names of those carrying out and further promoting this administration’s immigration-related goals. As of publication of this post, the relevant current heads of certain federal agencies are as follows:

Health and Human Services (HHS): Robert F. Kennedy Jr., HHS Secretary
HHS, Office of Refugee Resettlement (ORR): Angie Salazar, ORR Acting Director
Department of State (DOS): Marco Rubio, Secretary of State
Department of Justice (DOJ): Pam Bondi, Attorney General
DOJ, Executive Office of Immigration Review (EOIR): Sirce Owen, EOIR Acting Director
Department of Homeland Security (DHS): Kristi Noem, Secretary of Homeland Security
DHS, U.S. Immigration and Customs Enforcement (ICE): Todd Lyons, ICE Acting Director

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Acronyms and Abbreviations present in this blog post:

CBP = U.S. Customs and Border Protection
DHS = U.S. Department of Homeland Security
DM = Director’s Memorandum
DOD = U.S. Department of Defense
DOJ = U.S. Department of Justice
DOS = U.S. Department of State
EO = Executive Order
EOIR = Executive Office of Immigration Review
ICE = U.S. Immigration and Customs Enforcement
INA = Immigration and Nationality Act
OCIJ = Office of the Chief Immigration Judge
OPPM = Operating Policies and Procedures Memorandum
PM = Policy Memorandum
TPS = Temporary Protected Status
USCIS = U.S. Citizenship and Immigration Services

Health and Human Services (HHS) and Office of Refugee Resettlement (ORR) Updates

HHS General Updates

ACF Interim Final Rule

ACF Interim Final Rule: Administration for Children and Families (ACF) interim final rule (IFR), “Unaccompanied Children Program Foundational Rule; Update to Accord with Statutory Requirements” (published March 25, 2025).
- Summary: This IFR removes the information-sharing prohibition from the Unaccompanied Children Foundational Rule—as the Trump administration argued that this information-sharing prohibition conflicts with immigration laws. The Foundational Rule included a provision that stated, “ORR shall not disqualify potential sponsors based solely on their immigration status and shall not collect information on immigration status of potential sponsors for law enforcement or immigration enforcement related purposes. ORR shall not share any immigration status information relating to potential sponsors with any law enforcement or immigration enforcement related entity at any time.” Therefore, with this rule, ORR removed the prohibition on sharing immigration information of sponsors with law enforcement and immigration enforcement authorities. The IFR went into effect immediately.
- Litigation: Two advocacy groups filed a lawsuit, Angelica S. v. HHS, 1:25-cv-01405 (D.D.C.), challenging the Trump administration’s additional and enhanced vetting procedures for reuniting unaccompanied children in ORR custody with their sponsors. While arrivals of unaccompanied children to the United States have declined, the average time that unaccompanied children spend in ORR has increased significantly. Delays in reunification of these children with their sponsors directly stems from the administration’s changes to HHS policies, including strict vetting procedures and additional screening procedures for sponsors. In filing suit, the plaintiffs sought injunctive and declaratory relief, maintaining that HHS’s March 2025 Interim Final Rule unlawfully rescinds certain protections in the 2024 Unaccompanied Children Program Foundational Rule and that the new requirements for ORR sponsors violate procedural safeguards and the agency’s statutory mandate. While ORR maintains its policies are to ensure safe placement of unaccompanied children with sponsors and that ORR is “not a law enforcement or immigration enforcement entity,” advocates of unaccompanied children worry that these screenings for sponsors not only delay reunification and extend time children spend in federal custody but also may be used to provide information for enforcement actions against children’s sponsors without status. The court issued a preliminary injunction on June 9, 2025 and provisionally certified a class including “all unaccompanied children who were in or transferred to the custody of HHS on or before April 22, 2025, and who (a) have or had a potential sponsor who has been identified; and (b) the sponsor's family reunification application has been denied, closed, withdrawn, delayed, or cannot be completed because the sponsor is missing documents newly required on or after March 7, 2025." The preliminary injunction blocks ORR from implementing the challenged vetting policies in processing the class members’ sponsor applications. Check out the litigation and related updates on the National Center for Youth Law’s page as well as the related practice advisory for more detail.
- Related Article and Resources:
  - National Center for Youth Law, Preliminary Injunction in Angelica S. v. HHS (July 2025).
  - Lomi Kriel and Mica Rosenberg, An Agency Tasked With Protecting Immigrant Children Is Becoming an Enforcement Arm, Current and Former Staffers Say, ProPublica (May 14, 2025).

Field Guidance (FG)-27 (March 14, 2025, last revised May 15, 2025)

Field Guidance (FG)-27 (March 14, 2025, last revised May 15, 2025).
- FG-27, “DNA Testing Expansion” is the second field guidance released during Trump 2.0, and in line with other changes to the sponsor verification, assessment, and vetting process outlined by FG-26. FG-27 also enhances the sponsor vetting process between an unaccompanied child and a potential sponsor—though this FG is only applicable where the sponsor claims to be biologically related to the immigrant child. The guidance states, “ORR requires DNA results that confirm biological parentage, biological grand-parentage, avuncular relationship (when an uncle or aunt is a full sibling to a parent), or siblingship (full or half), to establish biological relationship with the unaccompanied alien child.” It also indicates that DNA testing is not mandatory and refusal to submit a sample is grounds for ORR to recategorize the sponsorship to that of an unrelated Category 3 sponsor and will require enhanced vetting procedures. Additional information is provided including information on sharing DNA test results and DNA records management. See the full list of ORR FGs here.
- Related Articles and Resources:
  - National Immigration Forum, Unaccompanied Alien Children - 2025 Update (Apr. 2, 2025).

FG-26 (February 14, 2025)

FG-26
- FG-26, “Fingerprint Background Checks and Acceptable Supporting Documentation for a Family Reunification Application” (February 14, 2025), is the first ORR field guidance released during this administration and replaces ORR background check requirements described in the ORR Policy Guide. ORR required sponsors to be vetted and go through an assessment process, but this guidance enhances certain aspects of the vetting process. For example, under this FG, ORR will require all adult sponsors and their household members aged 18 or over to be fingerprinted, with the results “received, adjudicated, and recorded in the UAC Portal prior to approval for release.” All potential sponsors will also undergo criminal history and public records background checks, and sponsors and their adult household members must also present original, unexpired versions of identification documents when fingerprinted.
- Related Articles and Resources:
  - National Center for Youth Law, Preliminary Injunction in Angelica S. v. HHS (July 2025).
  - Ximena Bustillo, ICE officers granted access to unaccompanied minors database, National Public Radio (NPR) (Feb. 14, 2025), discussing that FG-26 came at the same time that ICE personnel gained access to an information database on unaccompanied children and covering advocates’ concerns of the administration’s use of sponsors’ information for immigration enforcement.
  - National Immigration Forum, Unaccompanied Alien Children - 2025 Update (Apr. 2, 2025).
- How may this impact unaccompanied children? Historically, many unaccompanied children and youth have undocumented sponsors and rely on undocumented individuals to provide a home for them in the United States while the youth are in removal proceedings. These increased vetting procedures may deter or discourage undocumented individuals from sponsoring unaccompanied children for fear of information-sharing with agencies and risk of enforcement action. Additionally, enhanced identification verification requirements and processes are delaying reunification of unaccompanied children in ORR with sponsors residing in the community.

ORR Updates

ORR Publication

ORR Publication: ORR Publishes “Update on Efforts to Mitigate Child Labor Exploitation and Internal Audit on Placement Process Used to Transfer Custody of Unaccompanied Children to Vetted Sponsors” resource (2025).
- Summary: This ORR report outlines ORR’s approach to preventing child labor exploitation among unaccompanied minors in federal custody, with measures including bolstered collaboration with the Department of Labor to identify at‑risk youths, enhanced screening and monitoring by case managers, and improved data-sharing systems for tracking placements of unaccompanied youth with sponsors throughout the country. The report also discusses findings from an internal audit of placement transfers and calls for the need for stricter vetting of sponsors, more home visits, and clearer protocols for flagging potential labor risks. The memo concludes with planned next steps: deploying new technology tools, rolling out enhanced staff training, and establishing regular oversight reviews to ensure protections against exploitation.

Changes to Policy Guide

Changes to Policy Guide: Updates to the ORR Unaccompanied [Immigrant] Children Program Policy Guide (February to June 2025).
- Summary and Context: Since January 2025, ORR has made several updates and revisions to the ORR Unaccompanied [Immigrant] Children Bureau Policy Guide. These changes include new provisions and terminology and technical changes with several updates in line with Field Guidance 26 (FG-26), “Fingerprint Background Checks and Acceptable Supporting Documentation for a Family Reunification Application” (February 14, 2025) and Executive Order 14168 “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” (January 20, 2025).
- Specific Changes to the ORR Policy Guide: Check out ORR’s “ORR Unaccompanied [Immigrant] Children Policy Guide: Record of Posting and Revision Dates” webpage to assess the full scope of changes made to the Policy Guide. Some changes include:
  - Update to 2.4.2 Home Study Requirement: Added guidance for cases meeting the conditions for which ORR will deny release. Added Foundational Rule Mandated and Other ORR Mandated subcategories to ORR Mandated Home Studies. Added home study requirement if the potential sponsor claims a biological relationship with the child but does not comply to a DNA test; the potential Category 1 sponsor is unable to provide supporting documentation and seeks a waiver or exception; the potential Category 1 or 2 sponsor is not biologically related to the child; or the potential Category 3 sponsor is seeking to sponsor a child. Added ORR right to exempt certain sponsors from ORR mandated home study requirements. Added that FFS must obtain FFS supervisor approval to request a second full home study or a second addendum. Revised the existing requirement for home study providers to submit the written report within 10 calendar days of receipt of the referral to within 10 business days of receipt of the referral (change made July 7, 2025, in effect July 14, 2025).
  - Update to the Policy Guide Terms: Added definition for “Certified Counseling Staff,” where the new definition emphasizes the designation between licensed and unlicensed clinically trained staff who provide clinical and/or counseling services for unaccompanied children (June 25, 2025).
  - Change to 5.10.1.2 Obtaining Authorization from the Subject of the Request: Removed language limiting sharing immigration status and provided language on the process for making a case file request when immigration status is requested (June 2, 2025).
  - Update to 1.2.4 Secure and Heightened Supervision Facilities: Revises heightened supervision placement considerations to remove “isolated or petty offenses” (May 19, 2025).
  - Update to 1.3.2 ORR Placement Designation: Clarifies that out-of-network facilities are subject to the same minimum standards of care and services as in-network providers (May 19, 2025).Update to 2.2.4 Required Documents for Submission with the Application for Release: Updates terminology; Clarifies that proof of sponsor income is a mandatory part of the Sponsor Application process and provides a list of documents for sponsor to show proof of income (Apr. 15, 2025). See the above information regarding the lawsuit, Angelica S. v. HHS, 1:25-cv-01405 (D.D.C.), challenging the Trump administration’s additional and enhanced vetting procedures for reuniting unaccompanied children in ORR custody with their sponsors. Read more about the litigation and related updates on the National Center for Youth Law’s page as well as the related practice advisory for more detail.
  - Update to 2.4.1 Assessment Criteria: Updates terminology; Specifies that the case manager enters information in the Sponsor Assessment; Emphasizes that financial stability is part of the sponsor vetting process; Adds factors to consider while determining if a sponsor can provide a stable home for a child upon release (Apr. 15, 2025).
  - New Addition of 3.4.4.1 Informed Consent for Psychotropic Medication to Policy Guide: Developed in accordance with the Lucas R. Psychotropic Medications Settlement. Provides consent standards provision of psychotropic medications including who can provide informed consent; the role of the Centralized Concurrence Unit (CCU); the emergency administration of psychotropic medications; and compliance monitoring (Mar. 17, 2025).
  - Update to 2.2.4 Required Documents for Submission with the Application for Release: Updates list of acceptable documents to verify identity. Reduces the types of documents that may be used for proof of address and reduces the timeframe from which those documents may be dated in some instances from 60 days to 30 days. Indicates ORR will deny release if fraudulent documents have been submitted during the application for release process, regardless of sponsor category, with exemptions granted on a case-by-case basis when supported by clear justification (Mar. 7, 2025). See the above information regarding the lawsuit, Angelica S. v. HHS, 1:25-cv-01405 (D.D.C.), challenging the Trump administration’s additional and enhanced vetting procedures for reuniting unaccompanied children in ORR custody with their sponsors. Read more about the litigation and related updates on the National Center for Youth Law’s page as well as the related practice advisory for more detail.
  - Addition to 2.7.4 Deny Release Request: Adds that, depending on sponsor category, ORR will or may deny release to a sponsor who has knowingly provided false information, committed perjury, or submitted fraudulent documentation during the sponsor assessment process. Refusal by a sponsor, household member, or adult caregiver to complete a mandatory fingerprint check will result in automatic denial of the sponsorship (Mar. 7, 2025).
  - Update to 5.8.2 Significant Incidents: Updates reportable SIR types to include suspected document or information fraud, such as providing false information, providing false or altered documents regarding proof of address or place of residence, failing to disclose prior placement in ORR custody, and/or failing to disclose history of gang affiliation (Mar. 7, 2025).
- Related Articles and Resources:
  - National Center for Youth Law, Preliminary Injunction in Angelica S. v. HHS (July 2025).
  - National Immigration Forum, Unaccompanied Alien Children - 2025 Update (Apr. 2, 2025.

ORR Partially Terminates Contract Providing Legal Services to Unaccompanied Children (March 21, 2025).

ORR Partially Terminates Contract Providing Legal Services to Unaccompanied
- Summary: On March 21, 2025, the administration announced its decision to immediately, partially terminate the contract providing legal services to unaccompanied immigrant children living in the United States. The Unaccompanied Children Program provides legal representation to more than 26,000 children in ORR custody and released from ORR custody. Without this crucial representation, many unaccompanied children remain vulnerable in the United States and will have to navigate their removal proceedings alone and without the assistance of a dedicated attorney. This program is critical to protecting vulnerable children of all ages and directly impacts CILA’s work and that of many organizations nationwide.
- Litigation: After the administration terminated the contract with Acacia, eleven subcontractors filed a lawsuit, arguing that the government has an obligation under the Trafficking Victims Protection Reauthorization Act of 2008 (“TVPRA”) to provide unaccompanied children with legal services. At the hearing, the plaintiffs argued that the administration cannot eliminate funding for these immigrant children without creating a plan or having provisions in place for helping these children when Congress had already appropriated money to help unaccompanied children. On April 29, 2025, a federal judge granted a preliminary injunction in the lawsuit challenging the government’s decision to terminate services and ordered restoration of funding for legal services for unaccompanied children. The government appealed and sought a stay of the order during appeal, but the stay was denied. The litigation is ongoing. Follow the case with Justice Action Center’s dedicated case webpage for Community Legal Services in East Palo Alto v. HSS, 3:25-cv-2847 (N.D. Cal.). See additional details from ImmDef, one plaintiff in the matter, here.

- Related Articles and Resources:
  - Acacia Center for Justice press release, Acacia Center for Justice Welcomes Federal Court Injunction (Apr. 30, 2025).
  - Michael Gennaro, Federal Judge orders Trump administration to restore legal aid for undocumented children, COURTHOUSE NEWS SERVICE, (Apr. 29, 2025).
  - The Associated Press, Judge orders White House to restore legal aid to unaccompanied migrant children, National Public Radio (Apr. 2, 2025).
  - Janie Har, Legal services for unaccompanied migrant children still uncertain after judge orders reinstatement, Associated press (Apr. 2, 2025).
  - Sandra Sanchez, Retired immigration judge recalls unaccompanied infants in need of lawyers, BORDER REPORT (Mar. 25, 2025).
  - Rebecca Santana, Trump administration cuts legal help for migrant children traveling alone, Associated press (Mar. 21, 2025).
  - Acacia Center for Justice press release, Acacia Center for Justice Decries Administration’s Termination of Representation for Unaccompanied Children (Mar. 21, 2025).

New Name for ORR UCP

Department of Justice (DOJ) and Executive Office of Immigration Review (EOIR) Updates

DOJ General Updates

DOJ Initiative: “Operation Take Back America” (announced March 6, 2025).

DOJ Initiative: “Operation Take Back America” (announced March 6, 2025).
- Summary: through a memorandum dated March 6, 2025, DOJ announced the establishment of initiative “Operation Take Back America,” with its core policies created by President Trump and Attorney General Bondi to be: “(1) repelling the invasion of illegal immigration, (2) achieving total elimination of cartels and transnational criminal organizations (TCOs), (3) establishing DHS task forces, (4) charging the most serious, readily provably offense, and (5) restoring the death penalty.
- Related Actions: The core policies of Operation Take Back America derive from executive orders signed by President Trump soon after he took office. “Repelling the invasion of illegal immigration” and “establishing DHS task forces” derive from Executive Order 14159: "Protecting the American People Against Invasion." “Achieving Total Elimination of Cartels and TCOs” stems from Executive Order 14157: “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” “Restoring the death penalty” is an administrative goal outlined through Executive Order 14164: “Restoring the Death Penalty”—and this DOJ memorandum discusses restoring the death penalty as an essential tool to deter crime, with emphasis added on capital crimes by undocumented individuals in the United States. “Charging the most serious, readily provable offense” stems from a February 5, 2025 memorandum by Attorney General Bondi, in which she established a charging policy “in the absence of unusual facts, prosecutors should charge and pursue the most serious, readily provable offense,” and the memorandum “noted the Department’s focus on illegal immigration, human trafficking and smuggling, and crimes by Cartels and TCOs such as Tren de Aragua (TdA) and Mara Salvatrucha (MS-13)."

Select DOJ Litigation Updates

Flores Settlement Agreement

Flores Settlement Agreement: DOJ Moved to Terminate the Flores Settlement Agreement (May 2025).
- Summary: On May 22, 2025, the DOJ, DHS, and HHS filed a motion to terminate the Flores Settlement Agreement and to dissolve the injunction of agency regulations, memorandum of points, and authorities. In the motion, the Defendants move to terminate the Agreement because “continuation of the [Flores Settlement Agreement] is no longer equitable or in the public interest.” The motion further elaborates on reasons for termination, including changed conditions of immigration law and migration patterns, inconsistencies with agency policies, and that the Agreement “removes the disincentives enacted by Congress” in families and children making the “dangerous journey” to the United States. More information can be found on the case here.
- Related Article and Resources:
  - National Center for Youth Law, Amid Government’s Efforts to Terminate Flores, Counsel File Motion to Enforce Agreement, Citing Prolonged Detention of Children and ‘Culture of Cruelty’ (June 18, 2025).
  - Camilo Montoyo-Galvez, Trump administration seeks to end court settlement protecting migrant children in U.S. custody, CBS NEWS (May 22, 2025).
  - Children’s Rights, Trump Administration moves to end settlement that protects immigrant children: Flores Counsel vow to defend vital safeguards (May 22, 2025).

Southwest Keys Lawsuit

Southwest Keys Lawsuit: DOJ and HHS drop lawsuit regarding sexual abuse and harassment of unaccompanied children in shelters operated by Southwest Key Programs (March 12, 2025).
- Summary: On March 12, 2025, the DOJ announced that it was dropping the lawsuit against shelters operated by Southwest Key Programs Inc. In July 2024 during the Biden administration, the DOJ filed a civil lawsuit against Southwest Key Programs Inc.—alleging that Southwest Key employees sexually abused and harassed several unaccompanied children housed in Southwest Key facilities. In this announcement, the DOJ justified dropping the lawsuit because HHS has since stopped placing unaccompanied children in the care of Southwest Key facilities and has instead placed children in other shelters.
- Related Article: Sarah N. Lynch and Ryan Patrick Jones, US drops lawsuit against shelter provider alleging sexual abuse of migrant kids, USA TODAY (Mar. 17, 2025).

EOIR General Updates

Proposed Changes to EOIR Forms for Limited Appearance

Proposed Changes to EOIR Forms for Limited Appearance: Promulgation of Notice and Comment for Proposed Changes to EOIR Forms EOIR-60 and EOIR-61 (June 3, 2025).
- Summary: EOIR promulgated a notice and comment for proposed changes to EOIR-60 and EOIR-61, the EOIR forms allowing an attorney or accredited representative to enter limited appearance and help a pro se respondent with court filings. The proposed revisions are purportedly to provide for more electronic filing options with ECAS. Comments are due by August 4, 2025.
- Related Resource: For background information on EOIR-60 and EOIR-61, read CILA’s blog post Demystifying the “Limited Appearance” in Removal Proceedings: An Overview of EOIR-60 and EOIR-61 (Mar. 2023).

EOIR Staff Changes

EOIR Staff Changes: Federal Payouts, Layoffs, and Resignations (ongoing).
- Summary: Across the country, immigration courts have experienced changes in staffing, from court administrators to immigration judges resigning and retiring amidst layoffs by the Trump administration. The big picture effect of this staff reduction is that it will add to the court’s backlog of cases and may slow down deportations. The layoffs come at a time when the DOJ is seeking consideration of administrative law judges—including immigration judges—as at-will employees without any federal employee protections.
- Related Articles:
  - Rebecca Santana, Trump administration fires 17 immigration court judges across ten states, MSN (July 16, 2025).
  - Ximena Bustillo, Shortage of immigration judges could slow down Trump deportation goals, NPR (Apr. 8, 2025).
  - Russell Contreras, Nearly 100 immigration court staff retiring, resigning amid swelling backlog, Axios (Mar. 7, 2025).
  - Lucien Bruggeman and Laura Romero, Mass exodus of immigration officials could delay millions of deportations, ABC News (Mar. 6, 2025).
  - Eileen Sullivan, Immigration Judges and Court Staff Take Payout Offers to Leave, The New York Times (Mar. 6, 2025).

EOIR Website and Immigration Court Practice Manual

EOIR website and Immigration Court Practice Manual
- The Trump Administration made several changes to EOIR’s website and practice materials, reflecting not just changes in EOIR courtroom procedures and EOIR staff directives but also how immigration advocates can locate and access the Immigration Court Practice Manual (ICPM) and other essential documents. The Immigration Court Practice Manual is now housed in the EOIR Policy Manual within Part II – OCIJ Practice Manual. Practitioners can click “Access the full OCIJ Practice Manual” to be redirected to the Immigration Court Practice Manual webpage

EOIR Memoranda

*Note: A comprehensive list of EOIR’s Memoranda can be found on EOIR’s webpage, Part IV - EOIR Memoranda. Select memoranda are highlighted here.

PM 25-35, Statutory Fees under the One Big Beautiful Bill (July 9, 2025).

PM 25-35, Statutory Fees under the One Big Beautiful Bill (July 9, 2025).
- Summary: This PM was issued after passing of the reconciliation bill on July 4, 2025, where the bill made several changes to immigration-related fees. This PM updates PM 21‑10 to reflect new fee schedules from the legislation, including:
  - $100 filing fee for asylum applications
  - $100 annual fee to maintain pending asylum cases
  - Fees for appeals and motions before EOIR.
- Related Resource: National Immigration Project, Comparison Chart of the Immigration-Related Fee Changes Brought by H.R.1 The So-Called One Big Beautiful Bill Act (July 22, 2025).

PM 25-34, Conflicting Precedents of the Board of Immigration Appeals (July 3, 2025)

PM 25-34, Conflicting Precedents of the Board of Immigration Appeals (July 3, 2025).
- Summary: This PM requires immigration judges to explicitly address and explain which precedent line they are following when BIA decisions conflict. This PM purports to encourage reasoned analysis in the absence of an administrative mechanism for resolving such conflicting precedent.
- Related Resource: CGRS, EOIR PM-25-34: The Trump Administration’s Latest Attempt to Undermine Gender Asylum (July 2025).

PM 25-33, Neutrality and Impartiality in Immigration Court Proceedings (June 27, 2025)

PM 25-32, Imposition and Collection of Civil Penalties for Certain Immigration-Related Violations (June 27, 2025)

PM 25-32, Imposition and Collection of Civil Penalties for Certain Immigration-Related Violations (June 27, 2025).
- Summary: This PM was issued in regards to DHS and EOIR’s jointly published interim final rule (IFR) titled “Imposition and Collection of Civil Penalties for Certain Immigration-Related Violations” 90 FR 27349. The PM discusses procedures for imposing and collecting civil penalties related to immigration violations.

PM 25-31, Addendum to Policy Memorandum 25-30 (May 9, 2025)

PM 25-31, Addendum to Policy Memorandum 25-30 (May 9, 2025).
- Summary: This PM is an addendum to PM 25-30, clarifying that clerical transfers are permitted both when a respondent is released from DHS custody (from detained to non-detained court) and when a respondent is newly detained (from non-detained to detained court). It affirms that EOIR may effectuate such transfers without a motion, provided a fixed address is on file, and allows either party to later file a motion for change of venue if they object.

PM 25-30, Cancellation of Operating Policies and Procedures Memorandum 18-01 (April 25, 2025)

PM 25-30, Cancellation of Operating Policies and Procedures Memorandum 18-01 (April 25, 2025).
- Summary: This PM cancels and replaces OPPM 18-01 to modernize and clarify procedures for changes of venue (COV) in immigration court. It affirms immigration judges' authority to change venue based on a showing of “good cause,” reinforces adherence to the law of the case doctrine to prevent re-litigation of settled legal issues after venue transfers, and mandates written orders for all COV decisions. The memo also formally authorizes clerical transfers—without requiring party motions—when courts open or close, or when detained respondents are released (reflecting longstanding EOIR practice). It notes that prior guidance did not anticipate developments like electronic filing and expanded clerical transfer usage, rendering OPPM 18-01 outdated.

PM 25-29, Cancellation of Director’s Memorandum 22-03 (April 18, 2025)

PM 25-29, Cancellation of Director’s Memorandum 22-03 (April 18, 2025).
- Summary: This PM cancels Director’s Memorandum 22-03, which covered administrative closure of immigration cases, citing legal and policy concerns. EOIR argues that administrative closure lacks statutory authority, undermines DHS’s prosecutorial discretion, and has contributed to long delays and a growing case backlog. The memo criticizes the Matter of Avetisyan (2012) decision for allegedly enabling judges to close cases unilaterally, calling it a departure from precedent and potentially unlawful. Administrative closure, EOIR contends, has functioned as a de facto amnesty program without congressional approval and may violate the major questions doctrine.

PM 25-28, Pretermission of Legally Insufficient Application for Asylum (April 11, 2025)

PM 25-28, Pretermission of Legally Insufficient Application for Asylum (April 11, 2025).
- Summary: This PM clarifies that immigration judges may, and should, pretermit (summarily dismiss) asylum applications that clearly lack prima facie merit. The PM says that pretermission of such applications would assist adjudicators in more efficiently managing their large dockets and a backlog of four million pending cases by eliminating legally insufficient claims and not spending more resources on hearings for such claims.

PM 25-27, Cancellation of Director’s Memorandum 23-01 and Reinstatement of Policy Memorandum 19-13, Use of Status Dockets (March 21, 2025)

PM 25-27, Cancellation of Director’s Memorandum 23-01 and Reinstatement of Policy Memorandum 19-13, Use of Status Dockets (March 21, 2025).
- Summary: The purpose of PM 25-27 is to cancel DM 23-01, which rescinded PM 19-13, Use of Status Dockets. This PM criticizes 23-01 and certain uses of case placement on EOIR’s status docket encouraged through 23-01. For example, in 25-27, discussion about 23-01 includes that it: “encouraged—if not tacitly directed—the placement of cases on the status docket in which a continuance was not legally required, which both overrode the decisional independence of Immigration Judges and directly contradicted one of DM 23-01’s stated rationales, promoting efficiency;” “conspicuously failed to acknowledge longstanding caselaw that would have contradicted part of one of its categories directing placement on the status docket of cases continued to await visa availability;” “failed to acknowledge that there is no entitlement or right to either a continuance or placement on the status docket; and “undermined EOIR’s ability to resolve cases in a timely manner. Instead, relating to status dockets, this PM reinstates 19-13.

PM 25-26, Additional Adjudicator Personnel Matters (March 14, 2025)

PM 25-26, Additional Adjudicator Personnel Matters (March 14, 2025).
- Summary: The purpose of PM 25-26 is to “further re-establish consistent and lawful practices regarding EOIR adjudicator personnel matters,” supplementing prior PM 25-24 with additional personnel policies following “the discovery of further problematic personnel practices concerning adjudicators, particularly Immigration Judges serving temporary appointments, that called its integrity, credibility, and impartiality into serious question.” Namely, the content of the PM focuses on the termination of several immigration judges (IJs) during the Biden administration, with the terminations allegedly not following proper procedure—having the concurrence of the Attorney General. Further, in the PM, the court makes clear that it “is no longer confident in the accuracy or objectivity of performance feedback it receives from parties appearing before an adjudicator and— absent corroboration and independent verification by an EOIR or Department of Justice employee”—finding that feedback about IJ’s performance and behavior should not be used as a basis for termination.

PM 25-25, Cancellation of Director’s Memorandum 22-07, Internet-Based Hearings (March 14, 2025)

PM 25-25, Cancellation of Director’s Memorandum 22-07, Internet-Based Hearings (March 14, 2025).
- Summary: PM 25-25 calls into question DM 22-07, calling it “ineffectual, purposeless, problematic, pointless,” and “unhelpful,” stating that it directed IJs to “decide motions related to video conferencing (VC) a particular way” and that it contradicted PM 21-03 in that “no EOIR officer or employee may direct an immigration judge to grant or deny such a motion [related to appearing by VTC] or direct an immigration judge to allow or disallow an appearance by a [noncitizen] or a representative of either party by VTC.” Thus, it cancels DM 22-07.

PM 25-24, Adjudicator Personnel Matters (February 28, 2025)

PM 25-24, Adjudicator Personnel Matters (February 28, 2025).
- Summary: PM 25-24 purports to implement and re-establish fair and consistent practices for the hiring, discipline, and promotion of immigration adjudicators. The PM states, among many things, that the agency will more broadly circulate and market job announcements to multiple locations to diversify applicant pools and that EOIR will end perceived favoritism in employment determinations of immigration adjudicators. The memo emphasizes transparent, competitive hiring—especially for leadership roles—and reaffirms this administration’s preference for veterans. The PM also mandates consistent, proportionate disciplinary actions to ensure fairness and accountability across the agency.

PM 25-23, EOIR Inferior Offices (February 21, 2025)

PM 25-23, EOIR Inferior Offices (February 21, 2025).
- Summary: PM 25-23 addresses the appointment and authority of EOIR adjudicators, clarifying their roles as “inferior officers” under the Appointments Clause of the Constitution. The PM emphasizes that their appointments must comply with constitutional requirements to ensure the legitimacy of their decisions. PM 25-23 also outlines procedures for appointing such inferior officers, aiming to maintain the integrity and proper functioning of the immigration adjudication system.

PM 25-22, Access EOIR Initiative (February 20, 2025)

PM 25-22, Access EOIR Initiative (February 20, 2025).
- Summary: The purpose of PM 25-22 is to “re-establish appropriate, ethical, and lawful boundaries for the Access EOIR Initiative,” an agency system and information systems initiative which provided the public, respondents, and representatives more access to EOIR and case information. This memo criticizes Access EOIR Initiative as going beyond its original goals and providing expanded, greater access that “compromised the agency’s impartiality and integrity”—particularly noting actions in which EOIR staff would stamp documents related to service without determining if service was complete on the other party. Thus, this memo states that the initiative will return to its “original form” and will be limited to providing information online about EOIR.

PM 25-21, Cancellation of Director’s Memorandum 22-04, Filing Deadlines in Non-Detained Cases. (February 14, 2025)

PM 25-20, Cancellation of Director’s Memorandum 23-02, Language Access in Immigration Court. (February 6, 2025)

PM 25-20, Cancellation of Director’s Memorandum 23-02, Language Access in Immigration Court. (February 6, 2025).
- Summary: PM 25-20 rescinds DM 23-02, which guided immigration judges to make sure that respondents in immigration proceedings received in court interpretation in their preferred language. The rescinded DM also tasked immigration judges with ensuring that respondents had reasonable access to language services outside of the immigration court for case preparation and assistance with legal documents. The memo states that EOIR will continue to follow the DOJ’s Language Access Plan and that the plan is currently being revised.

PM 25-19, EOIR's Anti-Fraud Program (February 5, 2025)

PM 25-19, EOIR's Anti-Fraud Program (February 5, 2025).
- Summary: The purpose of PM 25-19 is to address alleged instances of immigration fraud, misrepresentation, and abuse perpetuated within the immigration legal system, with this PM specifically noting asylum fraud. This PM discusses how EOIR’s “reinvigorated” Anti-Fraud Program will provide resources to staff on identifying, reporting, and coordinating with investigators instances of immigration fraud in the immigration court as well as notifying authorities of instances of fraud, misrepresentation, or abuse involving attorneys or accredited representatives. The PM directs EOIR employees to become familiar with PM 19-07, Identifying and Reporting Fraud and Abuse, a memorandum from December 2018.

PM 25-18, Cancellation of Director’s Memorandum 22-06, Legal Advocacy by Non-Representatives in Immigration Court, and Reinstatement of Policy Memorandum 20-05 (February 4, 2025)

PM 25-18, Cancellation of Director’s Memorandum 22-06, Legal Advocacy by Non-Representatives in Immigration Court, and Reinstatement of Policy Memorandum 20-05 (February 4, 2025).
- Summary: PM 25-18 rescinds DM 22-06 on Friends of Court—which rescinded prior PM 20-25, a Trump policy barring Friends of Court in removal proceedings. DM 22-06, which was issued in 2022, discussed the Friend of Court model in immigration court and updated guidance on how it could be utilized to help pro se respondents. DM 22-06 discussed how use of the Friend of Court model helped immigration courts with effective and efficient case management. Overall, this 2025 PM 25-18 reinstates PM 20-25, once again barring Friends of Court in immigration proceedings. PM 25-18 describes that DM 22-06 changed the role of Friend of Court “into something more akin to a social worker or caretaker whose role is far beyond the authority of an immigration court to address” and therefore “risked confusion.”

- How may this affect unaccompanied children? Several practitioners working with unaccompanied youth had reported successful implementation of the Friend of Court model in their local immigration courts across the country. Friends of Court often assisted juvenile respondents navigating proceedings, helping both the juvenile and the court process run more smoothly.
- Related Resource: CILA, Ethics Advisory: Acting as Friend of Court (Mar. 12, 2025).

PM 25-17, Cancellation of Director’s Memorandum 22-05 and Reinstatement of Policy Memoranda 19-05, Guidance Regarding the Adjudication of Asylum Applications Consistent with INA § 208(d)(5)(A)(iii); 21-06, Asylum Processing; and 21-13 PM, Continuances (February 3, 2025)

PM 25-17, Cancellation of Director’s Memorandum 22-05 and Reinstatement of Policy Memoranda 19-05, Guidance Regarding the Adjudication of Asylum Applications Consistent with INA § 208(d)(5)(A)(iii); 21-06, Asylum Processing; and 21-13 PM, Continuances (February 3, 2025).
- Summary: DM 22-05 rescinded three policy memoranda. Finding no apparent reason for the rescission, PM 25-17 cancels DM 22-05 and reinstates Policy Memoranda 19-05, 21-06, and 21-13.
  - PM 19-05: This PM provides that immigration judges should adjudicate asylum applications within 180 days to the maximum extent practicable.
  - PM 21-06: This PM provides information about calculating the Asylum EAD Clock and the adjudication of affirmative versus defensive asylum applications.
  - PM 21-13: This PM provides guidance and factors for consideration for adjudicators when evaluating motions to continue during immigration proceedings, cautioning adjudicators to ensure that continuances are not used for the sole purpose of delaying proceedings and extending time in the United States.
- Related Resource: Read CLINIC’s Navigating EOIR Directives Under Trump 2.0: Practical Guidance for Advocates and Programs (Apr. 22, 2025) that covers the effect of this policy memoranda along with many.

PM 25-16, Cancellation of Director’s Memorandum 23-04 (February 3, 2025)

PM 25-16, Cancellation of Director’s Memorandum 23-04 (February 3, 2025).
- Summary: This PM cancels DM 23-04, which had instructed immigration judges and the BIA to consider DHS enforcement priorities and prosecutorial discretion when adjudicating cases. The new memo emphasizes that EOIR is an independent adjudicatory body and must not be influenced by DHS’s prosecutorial role. PM 25-16 states that DM 23-04 improperly inserted EOIR into enforcement decisions, overall undermining judicial independence. PM 25-16 also notes that DHS priorities should not dictate the outcome of individual immigration cases. By rescinding DM 23-04, PM 25-16 also nullifies the previous rescission of PM 21-25.

PM 25-14, Cancellation of Director’s Memorandum 23-03 and Reinstatement of Policy Memorandum 20-03, Child Advocates in Immigration Proceedings (January 31, 2025)

PM 25-14, Cancellation of Director’s Memorandum 23-03 and Reinstatement of Policy Memorandum 20-03, Child Advocates in Immigration Proceedings (January 31, 2025).
- Summary: PM 25-14 reinstates PM 20-03, Child Advocates in Immigration Proceedings, which had been rescinded by DM 23-03. The reinstated PM 20-03 provides information about the child advocate’s duties and role as well as the authority of the secretary of the Health and Human Services to appoint child advocates “’only for child trafficking victims and other vulnerable unaccompanied [immigrant] children’—not for all UAC.”

PM 25-11, Laken Riley Act (January 30, 2025)

PM 25-11, Laken Riley Act (January 30, 2025).
- Summary: PM 25-11 provides guidance to EOIR on the categories of immigrants subject to mandatory detention under the Laken Riley Act and further clarifies the terms relevant for the acts leading to detention—as relevant to immigration court proceedings.
- Related Actions: President Trump signed S.5, the Laken Riley Act, into law on January 29, 2025. See more information below.

PM 25-10, Cancellation of Director’s Memorandum 24-01, Children’s Cases in Immigration Court and Reinstatement of Operating Policies and Procedures Memorandum 17-03 (January 29, 2025)

PM 25-10, Cancellation of Director’s Memorandum 24-01, Children’s Cases in Immigration Court and Reinstatement of Operating Policies and Procedures Memorandum 17-03 (January 29, 2025).
- Summary: PM 25-10 rescinds DM 24-01, which was issued in December 2023, and reinstates OPPM 17-03, Guidelines for Immigration Court Cases Involving Juveniles, Including Unaccompanied Alien Children, which was previously issued in 2017. It also mentions that for clarity, OPPM 17-03 may be referred to as Policy Memorandum or PM 17-03.
- Related Resource: When DM 24-01 was released in December 2023, CILA wrote a blog post about the DM—summarizing the key elements of the memorandum and how DM 24-01 differed from OPPM 17-03. This blog post also includes a side-by-side comparison chart of DM 24-01 and OPPM 17-03. Because PM 25-10 reinstates OPPM 17-03 and rescinds DM 24-01, practitioners can still reference CILA’s blog post, “EOIR Updates Guidance on Children’s Cases in Immigration Court & Creates Specialized Juvenile Dockets” (Jan. 12, 2024), to compare the memoranda, their key differences, and the similarities.

PM 25-08, Cancellation of Director’s Memorandum 22-01 and Reinstatement of Policy Memorandum 21-08, Pro Bono Legal Services (January 29, 2025)

PM 25-08, Cancellation of Director’s Memorandum 22-01 and Reinstatement of Policy Memorandum 21-08, Pro Bono Legal Services (January 29, 2025).
- Summary: PM 25-08 rescinds DM 22-01 and reinstates PM 21-08, Pro Bono Legal Services. PM 21-08 consolidated and updated EOIR policies related to pro bono legal services, emphasizing the importance of pro bono representation and advocacy in immigration proceedings. The reinstatement aims to enhance access to competent legal representation for individuals in removal proceedings with EOIR and with cases before the Board of Immigration Appeals (BIA).

PM 25-07, Cancellation of Policy Memorandum 21-27, Terminology (January 29, 2025)

PM 25-07, Cancellation of Policy Memorandum 21-27, Terminology (January 29, 2025).
- Summary: PM 25-07 cancels PM 21-27—where PM 21-27 encouraged the use of humanizing language to refer to respondents and individuals in removal proceedings, including not referring to such individuals as “aliens.” PM 25-07 states that 21-27 was “fundamentally misguided” and to use “legally accurate terminology” instead.

PM 25-06, Cancellation of Operating Policies and Procedures Memorandum 23-01, Enforcement Actions in or Near OCIJ Space (January 28, 2025)

PM 25-06, Cancellation of Operating Policies and Procedures Memorandum 23-01, Enforcement Actions in or Near OCIJ Space (January 28, 2025).
- Summary: PM 25-06 cancels OPPM 23-01, which rescinded prior OPPM 96-6 and prohibited some—but not all—DHS civil immigration enforcement actions in or near EOIR space operated by Office of the Chief Immigration Judge (OCIJ). OPPM 23-01 relied upon a DHS document from 2021, Civil Immigration Enforcement Actions in or near Courthouses, but that guidance was rescinded and superseded by ICE’s Interim Guidance: Civil Immigrant Enforcement Actions in or near Courthouses as of January 21, 2025. Then the January 2025 guidance was superseded by ICE’s memorandum Civil Immigration Enforcement Actions In or Near Courthouses issued on May 27, 2025. See more information below.

PM 25-05, Cancellation of Policy Memorandum 21-26, Migrant Protection Protocols and Motions to Reopen (January 27, 2025)

PM 25-05, Cancellation of Policy Memorandum 21-26, Migrant Protection Protocols and Motions to Reopen (January 27, 2025).
- Summary: PM 25-05 rescinds and cancels PM 21-26, which addressed the immigration court aspects of the Migrant Protection Protocols (MPP). PM 21-26 provided guidance to all immigration court and BIA staff about how to adjudicate motions to reopen MPP cases. PM 25-05 states that PM 21-26 does not accurately reflect the current Executive Branch’s policy and that some adjudicators had felt it was “problematic” and “inappropriately pressured them to rule in cases a certain way.”

PM 25-02, EOIR’s Core Policy Values (January 27, 2025)

PM 25-02, EOIR’s Core Policy Values (January 27, 2025).
- Summary: PM 25-02 discusses how EOIR will intend to carry out the Executive Branch’s vision for the next four years and “re-establish EOIR as a model administrative adjudicatory body.” Through this PM, EOIR informs practitioners and the public of the centralized EOIR Policy Manual and reorganization and restructuring of certain practice materials and certain EOIR components. For example, the PM includes the fact that DMs are likely to be rescinded and relabeled as PMs and discusses EOIR being “One EOIR” made up of several components including three adjudicating components (which includes the Board of Immigration Appeals and the Office of the Chief Immigration Judge) and four supporting components.

Department of Homeland Security (DHS) Updates, Policies, and Actions

This section includes DHS’s regulatory actions, including proposed and final regulations, agency policy documents, agency statements, and more.

General DHS Updates

DHS Press Release: “ICYMI: Secretary Noem Deputized State Department Officials as Immigration Officers” (Feb. 20, 2025)

Processing Forms for Asylees and Refugees: DHS Pauses Processing for Certain adjustment of status (AOS) Forms, Including for Asylees and Refugees (March 25, 2025).
- Summary: CBS reported that USCIS directed officials to stop processing green card applications filed by refugees and asylees. DHS stated: “USCIS is placing a temporary pause on finalizing certain Adjustment of Status applications pending the completion of additional screening and vetting to identify potential fraud, public safety, or national security concerns.”
- Related Action: DHS attributed the suspension of processing the applications with Executive Order 14161: “Protecting the United States from Foreign Terrorists and Other National Security and Public Safety Threats” and Executive Order 14157: “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists."

CBP Home: DHS launches CBP Home App with Self-Deporting Feature (Mar. 10, 2025)

CBP Home: DHS launches CBP Home App with Self-Deporting Feature (Mar. 10, 2025).
- Summary: DHS announced the launch of CBP Home, a phone software application with a “self-deportation” feature.
- Related Articles:
  - Pedro Camacho, Migrants Seeking Self-Deportation Say CBP App Leaves Them Stranded: ‘They Took My Documents at the Border,’ MSN (July 17, 2025).
  - Tedd Hesson, Trump administration launches new 'self-deportation' app, Reuters (Mar. 10, 2025).

DHS Press Release: “ICYMI: Secretary Noem Deputized State Department Officials as Immigration Officers” (Feb. 20, 2025)

DHS Press Release: “ICYMI: Secretary Noem Deputized State Department Officials as Immigration Officers” (Feb. 20, 2025).
- Summary: This DHS press release details how Secretary Noem signed a memorandum granting 600 DOS special agents with the authority to assist with apprehensions and deportations. The press release later includes information that certain IRS employees and DOJ employees can also assist with immigration enforcement actions.

DHS Memorandum: Guidance Regarding How to Exercise Enforcement Discretion (January 23, 2025)

DHS Memorandum: Guidance Regarding How to Exercise Enforcement Discretion (January 23, 2025).
- Summary: With DHS’s memorandum, Guidance Regarding How to Exercise Enforcement Discretion, DHS Acting Secretary Benjamine Huffman provided guidance to DHS regarding the implementation of expedited removal for those who were not previously designated, along with guidance for dealing with those noncitizens who were granted parole during the Biden administration.
- Related Actions: This guidance relates to the January 20, 2025 memorandum titled Exercising Appropriate Discretion Under Parole Authority and the January 21, 2025 Federal Register Notice, Designating Aliens for Expedited Removal. See more below.

Federal Register Notice: DHS Expands Expedited Removal to the Maximum Extent Authorized by Statute (January 21, 2025)

Federal Register Notice: DHS Expands Expedited Removal to the Maximum Extent Authorized by Statute (January 21, 2025).
- Summary: The purpose of the DHS notice, Designating Aliens for Expedited Removal, is to restore the scope of expedited removal to the fullest extent possible that is authorized by Congress. This notice is immediately effective. Under the notice, in addition to those already designated for expedited removal, it states that DHS has the authority to modify discretionary limits on the scope of expedited removal based on the INA. This action extended the scope of expedited removal to apply to an individual who falls into the following categories of noncitizens:
  - “(1) [Noncitizens] who did not arrive by sea, who are apprehended anywhere in the United States more than 100 air miles from a U.S. international land border, and who have been continuously present in the United States for less than two years; and
  - (2) [Noncitizens] who did not arrive by sea, who are apprehended within 100 air miles from a U.S. international land border, and who have been continuously present in the United States for at least 14 days but for less than two years."
- Notable sections and provisions:
  - The notice’s footnotes indicate DHS’s strong push to use the word “alien” moving forward in this administration—a change from the Biden administration. See footnote 2: “The term ‘alien’ is defined in statute as “any person not a citizen or national of the United States.” 8 U.S.C. 1101(a)(3). Going forward, DHS will adhere to statutory language and use the proper terminology.”
- How may this affect unaccompanied children? While unaccompanied children should be exempt from expedited removal, the expansion of categories of individuals subject to expedited removal may have consequences for mixed status families or affect an unaccompanied child’s sponsor or loved ones.
- Related Action or Policy: This action directly stems from Executive Order 14159: "Protecting the American People Against Invasion" (January 20, 2025).
- Litigation: A complaint for Make the Road New York v. Huffman, 1:25-cv-00190 (D.D.C.) was filed on January 22, 2025, challenging the expansion of expedited removal. The litigation is ongoing. Read more about the case from the ACLU.
- Related Resources:
  - National Immigration Litigation Alliance (NILA), Everything Expedited Removal (Feb. 7, 2025).
  - Eric S. Hause, DHS Expands Categories of Individuals Subject to Expedited Removal (Deportation), The National Law Review (Jan. 27, 2025).
  - National Immigration Law Center (NILC), Know Your Rights: Expedited Removal Expansion (Jan. 24, 2025).

DHS Press Release: DHS Reinstates Migrant Protection Protocols or “Remain in Mexico” (January 21, 2025)

DHS Press Release: DHS Reinstates Migrant Protection Protocols or “Remain in Mexico” (January 21, 2025).
- Summary: DHS issued a press release reinstating the Migrant Protection Protocols (MPP), that initially started in 2019.
- Litigation: CGRS, ImmDef, and other partners filed a motion for a stay on the reimplementation of MPP in Immigrant Defenders Law Center v. Noem, 2:20-cv-09893 in the United States District Court Central District of California – Eastern Division. Read more on the litigation from CGRS.
- Related Articles and Resources:
  - CGRS, Court Stays Remain in Mexico Reimplementation for Clients of ImmDef (July 21, 2025).
  - American Immigration Council (AIC), The “Migrant Protection Protocols”: an Explanation of the Remain in Mexico Program (Feb. 12, 2025).
  - CGRS, Immigrant Rights Organizations Asks Court to Halt Remain in Mexico Restart (Feb. 12, 2025).
  - Ximena Bustillo, Jasmine Garsd, Trump reinforces use of his ‘Remain in Mexico’ policy, National Public Radio (Jan. 20, 2025).

DHS Press Release: Statement from a DHS Spokesperson on Directive Expanding Immigration Law Enforcement to Some Department of Justice Officials (January 23, 2025)

DHS Press Release: Statement from a DHS Spokesperson on Directive Expanding Immigration Law Enforcement to Some Department of Justice Officials (January 23, 2025).
- Summary: An internal DHS memo was circulated on January 22, 2025, indicating that officers beneath the Department of Justice have been granted the authority to engage in “investigating, determining the location of, and apprehending, any [noncitizen] who is in the United States” without status. The memo further specifies who has this authority within the DOJ, including law enforcement agents within the U.S. Marshals Service, the Drug Enforcement Administration (DEA), the Bureau of Alcohol, Tobacco, Firearms, and Explosives, and the Federal Bureau of Prisons. This DHS press release confirms the memo and how President Trump plans to use other entities to carry out his mass deportation plans.
- How may this affect unaccompanied children? Under this administration, unaccompanied children may feel unsafe and untrusting of their surroundings, and they may also be more fearful of law enforcement officers—even if they are in a situation where they may need their assistance. It is important for attorneys and other advocates to explain these different agencies and the role they may play in enforcing immigration now.

DHS Press Release: Statement from a DHS Spokesperson on Directives Expanding Law Enforcement and Ending the Abuse of Humanitarian Parole (January 21, 2025)

DHS Press Release: Statement from a DHS Spokesperson on Directives Expanding Law Enforcement and Ending the Abuse of Humanitarian Parole (January 21, 2025).
- Summary: This press release discusses DHS’s two directives for carrying out the Trump administration’s plans to secure the southern border. According to the press release, “the first directive rescinds the Biden Administration’s guidelines for ICE and CBP’s enforcement actions that thwart law enforcement in or near so-called ‘sensitive’ areas. The second directive ends the broad abuse of humanitarian parole and returns the program to a case-by-case basis. ICE and CBP will phase out any parole programs that are not in accordance with the law.”
- Related Action: This stems from Executive Order 14165: “Securing Our Borders” (January 20, 2025).

Related Resource: International Refugee Assistance Project (IRAP), IRAP Explainer on Initial Trump Actions Attacking Parole and Parolees (Feb. 19, 2025).

DHS to ICE: Enforcement Actions in or Near Protected Areas (January 20, 2025)

DHS to ICE: Enforcement Actions in or Near Protected Areas (January 20, 2025).
- Summary: Previously, there had been a longstanding policy to discourage enforcement actions at sensitive locations, including an ICE policy statement from October 2011 and additional guidance from April 2021 and October 2021. The Biden administration strongly discouraged ICE to carry out enforcement in medical facilities, schools and daycares, playgrounds, social service centers, crisis centers, disaster relief sites, or places of worship—all of which were protected areas. The Biden administration considered an area to be “protected” if an enforcement action in the area would restrain people’s access to essential services or engagement in essential activities. The Biden administration only allowed immigration enforcement to take place in sensitive or protected areas when there was an immediate danger to the public. On January 20, 2025, DHS issued a memo to rescind the October 2021 guidelines on enforcement actions in protected areas and instead says that law enforcement officers should use discretion along with a “healthy dose of common sense” in choosing where to engage in enforcement actions.
- Related Actions or Policies:
  - This action directly stems from Executive Order 14159: "Protecting the American People Against Invasion" (January 20, 2025).
  - ICE Directive: Common Sense Enforcement Actions in or Near Protected Areas (January 31, 2025): This memo states that DHS will not issue rules on where immigration laws are to be enforced and rather, through this ICE memorandum, ICE has the responsibility to make individual determinations on when and where to engage in an enforcement action in a protected area.
  - ICE Memorandum: Civil Immigration Enforcement Actions In or Near Courthouses (May 27, 2025, superseding guidance issued in January 21, 2025): This guidance provides that ICE agents or officers may conduct civil immigration enforcement operations in or near courthouses if they have credible information that the targeted noncitizen will be at present at that specific location.
- How may this affect unaccompanied children?
  - Many unaccompanied children and their families frequent areas that were previously considered protected such as schools, playgrounds, and places of worship. Now, there is more fear in communities when individuals are just going about their daily lives, even when they may be in the system and seeking relief. It is important for unaccompanied children to know their rights and be prepared.
  - Additionally, some unaccompanied children or their sponsors may choose to forego or skip school for fear of immigration enforcement, so advocates should talk with families about the effects of absenteeism and state law.
  - Families and undocumented loved ones arriving to court together should be aware of the risks involved in going to immigration court and ICE’s potential presence.
- Litigation: Litigation on this policy is ongoing in Philadelphia Yearly Meeting of the Religious Society of Friends v. DHS, 8:25-cv-00243 (D. Md.); Denver Public Schools v. Noem, 1:25-cv-00474 (D. Colo.); Mennonite Church USA et al. v. DHS et al., 1:25-cv-00403 (D.D.C.); and Pineros y Campesinos Unidos del Noroeste v. Noem, 6:25-cv-00699-AA (D. Or.). Updates on the litigation can be found on Just Security’s Litigation Tracker.
- Related Articles and Resources:
  - Michael Kunzelman and Lindsay Whitehurst, Judge blocks Trump immigration policy allowing arrests in churches for some religious groups, MSN (Feb. 24, 2025).
  - Moriah Balingit, Bianca Vazquez Toness, and Jocelyn Gecker, Schools around the US confront anxiety over Trump’s actions on immigration, Associated Press (Feb. 17, 2025).
  - Victoria Bisset, 27 religious groups sue to block immigration arrests at houses of worship, MSN (Feb. 12, 2025).
  - April Ferguson, Navigating Policy Changes Related to Schools and Immigration and Customs Enforcement (ICE), National Association of Social Workers (NASW) (Feb. 2025).
  - Lynn Damiano Pearson, Factsheet: Trump’s Rescission of Protected Areas Policies Undermines Safety for All, National Immigration Law Center (NILC) (Jan. 21, 2025).
  - Kalyn Belsha, Immigration arrests at schools loom after Trump changes longstanding policy, Chalkbeat (Jan. 21, 2025).

U.S. Citizenship and Immigration Services (USCIS)

USCIS Alert on Fees: USCIS Updates Fees based on H.R. 1 (July 18, 2025)

USCIS Alert on Fees: USCIS Updates Fees based on H.R. 1 (July 18, 2025).
- Summary: USCIS announced that it is publishing a federal register notice based on H.R. 1 Reconciliation Bill. On or after July 22, 2025, those submitting applications or petitions with USCIS must submit their immigration-related forms with the new fees. New fees include: a new fee of $250 for SIJ-eligible individuals who file Form I-360; a new fee of $100 asylum applicants filing Form I-589; a new Annual Asylum Fee (AAF) of $100 (which must be paid online) asylum applicants with a pending Form I-589 for each calendar year the application pends; a new fee for those seeking employment authorization and filing Form I-765 under the (a)(4), (a)(12), (c)(8), (c)(11), (c)(19), and (c)(34) categories; a new fee of $550 for initial EAD applications; and a fee of $275 for renewal or extension of EAD applications. Generally, information is available on USCIS’s website regarding filing fees.
- Related Resource: National Immigration Project, Comparison Chart of the Immigration-Related Fee Changes Brought by H.R.1 The So-Called One Big Beautiful Bill Act (July 22, 2025).

Changes to SIJS Deferred Action

Changes to SIJS Deferred Action
- Summary: On June 6, 2025, USCIS terminated its policy of granting deferred action (and related employment authorization) for special immigrant juveniles (SIJs, those with approved I-360 petitions with special immigrant juvenile status) who are ineligible to apply for adjustment of status to lawful permanent resident (LPR) status due to visa unavailability. The USCIS alert also provides that USCIS may terminate deferred action and revoke SIJS-based employment authorization before the validity period expires. These changes are reflected in the USCIS Policy Manual in Volume 6: Immigrants, Part J, Special Immigrant Juveniles, Chapter 4, Adjudication. As background on SIJS-related deferred action, beginning on March 27, 2022, USCIS implemented policy to automatically consider granting deferred action on a case-by-case basis to SIJs with an approved Form I‑360. SIJS-based deferred action was generally granted for four years, with employment authorization eligibility under the (c)(14) category. Many SIJs (if not the majority) were routinely granted deferred action and work authorization as a bridge until they could adjust their status. Under the new policy, USCIS will no longer consider SIJ classification alone as a basis for deferred action, effectively ending this crucial protection for many youth stuck in the visa backlog. Those with SIJS-based deferred action will no longer be able to renew their deferred action once it expires.
- On July 24, 2025, the USCIS announced that it had revealed "significant national security and integrity vulnerabilities" within the SIJS program--determining that certain SIJs were members of gangs. This announcement came after USCIS terminated deferred action to SIJs and in parallel with this administration's scrutiny to humanitarian forms of relief. While the announcement and related report seems to paint the SIJ program in a negative light, advocates and allies should remember this announcement relates to a small minority of SIJ beneficiaries. Overall, SIJS is a significant protection to the majority of recipients and survivors of familial abuse, with profound impact to children and juveniles in seeking safety in the United States.
- Litigation: On July 17, 2025, nine immigrant youth and legal services providers CARECEN-NY and Centro Legal de La Raza filed a class action lawsuit in the U.S. District Court for the Eastern District of New York to challenge the government’s termination of SIJS-based deferred action, arguing violation of the Administrative Procedure Act. Advocates and allies can read more about the lawsuit, A.C.R. et al. v. Noem et al., No. 1:25-03962 here.
- Related Action: USCIS also released proposed revisions to Form G-325A, Biographic Information (for Deferred Action) to specifically exclude SIJs. This form is used for consideration of deferred action and previously included SIJS deferred action.
- Related Articles and Resources:
  - National Immigration Project, Practice Alert: Termination of the SIJS Deferred Action Policy (July 22, 2025).
  - Solcyré Burga, Trump Sued by Immigrant Youth Over Deportation Risk, Time (July 19, 2025).
  - Albinson Linares and Daniella Silva, Abused and abandoned immigrant youths sue Trump administration over deportation fears, NBC NEWS (July 17, 2025).
  - CILA blog post, USCIS Termination of SIJS-Based Deferred Action (July 17, 2025).

Policy Alert on Statelessness Memo Removal: USCIS removes its Statelessness Policy (June 5, 2025)

USCIS PM-602-0187, Issuance of Notices to Appear (NTAs) in Cases Involving Inadmissible and Deportable Aliens (February 28, 2025)

USCIS PM-602-0187, Issuance of Notices to Appear (NTAs) in Cases Involving Inadmissible and Deportable Aliens (February 28, 2025).
- Summary: Through this PM, USCIS updated its NTA policy to no longer exempt classes or categories of removable individuals from potential enforcement, which includes referring cases to ICE and issuance of NTAs. Under this memorandum, USCIS employees can issue NTAs to individuals whose immigration benefit requests have been denied and to those who are not lawfully present in the United States or who are subject to other grounds of removal.
- Related Action or Policy: This 2025 PM appears to reinstate the June 2018 PM issued under the prior Trump administration.
- Related Resource: CLINIC, USCIS Issues New NTA Guidance Memo (Mar. 2025).

[Noncitizen] Registration Requirement (published February 25, 2025)

[Noncitizen] Registration Requirement (published February 25, 2025).
- Summary: USCIS published their Alien Registration Requirement webpage on February 25, 2025, announcing and formalizing DHS’s process for noncitizens to register with the government under section 262 of the INA—per Executive Order 14159: “Protecting the American People Against Invasion” (January 20, 2025). DHS also issued an interim final rule (IFR), Registration Requirement for Certain Noncitizens, on March 12, 2025 which went into effect on April 11, 2025.
- Who must register? Per the INA, with limited exceptions, all noncitizens aged 14 or older who were not fingerprinted or registered when applying for a U.S. visa and who will be in the United States for 30 days or longer, must apply for registration and fingerprinting before the expiration of the 30 days. Parents and legal guardians must register their children below the age of 14. When a noncitizen child is registered and reaches age 14, within 30 days of turning 14, they must apply to be re-registered and to be fingerprinted, too. Many noncitizens are considered “already registered” and are not required to register again. For example, those in removal proceedings and those who have submitted certain petitions or applications and completed biometrics for those submissions are considered registered. The USCIS webpage provides information on who has already registered, who must apply for registration, as well as information on how to register.
- Related Actions: Executive Order 14159: “Protecting the American People Against Invasion” directs DHS to ensure noncitizens comply with registration and DHS issued the IFR on the noncitizen registration requirements.
- Related Resources:
  - Congressional Research Service, Alien Registration Requirements (May 19, 2025).
  - Immigrant Legal Resource Center (ILRC), Discussing Registration with Clients (May 14, 2025).
  - University of Southern California, Immigration Update: Mandatory USCIS Foreign National Registration – 30 Days to Register Children (Mar. 14, 2025).
  - AIC, The Trump Administration’s Registration Requirement for Immigrants: A Rapid Analysis by the American Immigration Council (Feb. 26, 2025).
  - National Immigration Law Center, FAQ: Non-citizen Registration Requirement in Trump Day 1 Executive Order (Feb. 25, 2025).
  - AILA has practice alerts and resources published on the administration’s registration requirements for noncitizens. You can log into your account and check them out.

USCIS Memorandum: Updated Procedures for Determination of Initial Jurisdiction over Asylum Applications Filed by Unaccompanied [Immigrant] Children and Implementation of the J.O.P. Settlement Agreement (signed January 30, 2025, effective February 24, 2025)

USCIS Memorandum: Updated Procedures for Determination of Initial Jurisdiction over Asylum Applications Filed by Unaccompanied [Immigrant] Children and Implementation of the J.O.P. Settlement Agreement (signed January 30, 2025, effective February 24, 2025).
- Summary: On February 24, 2025, USCIS’s new memo implementing the J.O.P. settlement agreement took effect. This memo is applicable to class members and those previously determined to be unaccompanied children. For the most part, the new memo supersedes the Kim Memo (2013), and this new memo will be effective for at least three years. Significantly, the USCIS memo directs USCIS to take initial jurisdiction over asylum applications for those with prior unaccompanied child determinations, even if the individual has turned 18 or reunited with a parent or guardian by the time they file their asylum application. Further, the memo allows USCIS to reject jurisdiction if the asylum applicant is in removal proceedings and was placed into adult ICE detention before filing for asylum.
- Related Actions: See the settlement agreement in J.O.P. v. U.S. Dept. of Homeland Security et al., Civil Action 8:19-cv-01944 (D. Md.).
- Related Resources:
  - NIPNLG, J.O.P. v. DHS webpage (last updated April 23, 2025).
  - NIPNLG, J.O.P. v. DHS Settlement Agreement: Five Key Takeaways (Dec. 18, 2024).

USCIS Alert: SAVE Guidance on New Verification of Release Card for [Immigrant] Children (January 28, 2025)

USCIS Alert: SAVE Guidance on New Verification of Release Card for [Immigrant] Children (January 28, 2025).
- Summary: ORR provides all children with a Verification of Release (VOR) form upon release from ORR care. In December 2024, ORR announced that beginning on December 5, 2024, all children released from ORR care to a sponsor in the United States are also mailed a VOR card, which is a plastic, wallet-sized card version of the VOR form. In late January 2025, USCIS issued an alert on SAVE Guidance on New Verification of Release Card for [Immigrant] Children. The announcement states that both the card and form contain the child’s first name, last name, date of birth, and A#, and this may be sufficient data elements to create a SAVE case. However, USCIS further clarified that the card and form are still not evidence of immigration status. Therefore, if additional documentation is required for the SAVE case, alternative documents should be submitted.

USCIS Alert: USCIS waives COVID-19 vaccination requirement for Adjustment of Status applicants (January 22, 2025)

USCIS Alert: USCIS waives COVID-19 vaccination requirement for Adjustment of Status applicants (January 22, 2025).
- Summary: USCIS issued an alert waiving the requirement that applicants for adjustment of status (AOS) to that of a lawful permanent resident demonstrate proof that they received the COVID-19 vaccine.
- How may this affect unaccompanied children? While the Centers for Disease Control and Prevention (CDC) still recommends the COVID-19 vaccine for everyone ages six months and up, it is no longer a requirement to adjust status.

U.S. Immigration and Customs Enforcement (ICE)

ICE Interim Guidance: Interim Guidance Regarding Detention Authority for Applicants for Admission (July 8, 2025)

ICE Interim Guidance: Interim Guidance Regarding Detention Authority for Applicants for Admission (July 8, 2025).
- Summary: This internal memorandum sent to ICE employees provides interim guidance directing officers to treat certain noncitizens—anyone who has not been admitted—as applicants for admission under INA § 235(b), subjecting them to mandatory detention without access to bond hearings before an immigration judge unless ICE affirmatively paroles them or reclassifies their custody under INA § 236. This represents a sharp shift from prior practice, where many of these individuals were processed under § 236 and could seek bond. By reasserting § 235(b) custody, the memo newly renders many individuals ineligible for bond, significantly limiting their avenues for release. Officers are instructed to apply the correct statutory authority, consult supervisors in unclear cases, and retrain staff to ensure compliance. The policy is expected to increase detention numbers and may reduce due process protections for asylum seekers, parolees, and others who previously had access to custody review.
- Related Resource: National Immigration Law Center, FAQ Rapid Response Update on Bond Eligibility for Undocumented Immigrants (July 17, 2025).

ICE Directive 11064.4: Detention and Removal of Alien Parents and Legal Guardians of Minor Children (July 2, 2025)

ICE Directive 11064.4: Detention and Removal of Alien Parents and Legal Guardians of Minor Children (July 2, 2025).
- Summary: This directive sets out guidance on the detention and removal of noncitizen parents and legal guardians of minor children in the United States. It requires ICE to identify individuals who are primary caregivers or have a direct interest in family court or child welfare proceedings and to consider these circumstances when making custody and enforcement decisions. The directive emphasizes minimizing disruption to parental rights by facilitating court participation, arranging child visitation (including in-person and virtual options), and allowing time to make care arrangements before removal. It discourages transferring detained parents away from where court proceedings are located. ICE must document actions taken in support of these obligations and designate local and national points of contact for oversight. Compared to the prior version (Directive 11064.3), this directive narrows who qualifies for protections and removes certain proactive requirements related to family unity.

ICE Memorandum: Civil Immigration Enforcement Actions In or Near Courthouses (May 27, 2025, superseding guidance issued in January 21, 2025)

ICE Memorandum: Civil Immigration Enforcement Actions In or Near Courthouses (May 27, 2025, superseding guidance issued in January 21, 2025).
- Summary: This guidance provides that ICE agents or officers may conduct civil immigration enforcement operations in or near courthouses if they have credible information that the targeted noncitizen will be at present at that specific location. Per the memorandum, those subject to enforcement actions are those subject to immigration violations, including those considered to be national security threats, individuals with criminal convictions, alleged gang members, those previously ordered removed but who have not departed, and those who re-entered following removal. However, the memorandum further provides that family and friends accompanying the targeted noncitizen may also be subject to immigration enforcement depending on the circumstances.
- Related Articles:
  - Ariana Figueroa, Advocates for immigrants sue to stop courthouse ICE arrests, NPR (July 17, 2025).
  - Ximena Bustillo, ICE's novel strategy allows for more arrests from inside immigration courts, NPR (June 12, 2025).
  - Chase Woodruff, Colorado advocates decry ICE courthouse arrest of immigrant family, ColoradoNewsOnline (May 30, 2025).

ICE Memorandum: Unaccompanied Alien Children Joint Initiative Field Implementation (based on news reports) (February 21, 2025)

ICE Memorandum: Unaccompanied Alien Children Joint Initiative Field Implementation (based on news reports) (February 21, 2025).
- Summary: Multiple news platforms reported on ICE’s internal memo titled “Unaccompanied Alien Children Joint Initiative Field Implementation,” directing ICE agents to track down unaccompanied immigrant children in the United States. Through advocacy efforts of NIPNLG, ICE’s memo was revealed through FOIA. The memo details a four-phase approach to find unaccompanied children and eventually conduct enforcement actions involving certain unaccompanied children. The memo also details how ICE has categorized unaccompanied children into three priority groups: “flight risk,” “public safety,” or “border security.” It instructs ICE to prioritize locating and deporting children deemed “flight risks,” particularly those with active removal orders, those who missed their hearing dates, and those released to non-relative sponsors. Soon after the memo was leaked through news coverage, unaccompanied children residing with their sponsors in the United States started having unplanned visits from DHS agents, including agents from Homeland Security Investigations (HSI), the Federal Bureau of Investigation (FBI), and ICE ERO (Enforcement and Removal Operations). These federal agents claimed to conduct “welfare checks” on unaccompanied children to ensure their safety and placement in the United States, but immigration advocates raised concerns about the intentions behind the visits, including possible enforcement action against undocumented sponsors.
- Related Articles:
  - David Gotfredson, HSI agents conduct 'welfare checks' on unaccompanied minors in San Diego, CBS8 (Apr. 14, 2025).
  - Marisa Taylor, Ted Hesson, and Kristina Cooke, Trump officials launch ICE effort to deport unaccompanied migrant children, Reuters (Feb. 23, 2025).
  - Luke Barr and Laura Romero, Trump administration directing ICE to track down unaccompanied minors: Source, ABC News (Feb. 23, 2025).
  - Peter Wade, ICE’s Next Deportation Target is Unaccompanied Migrant Children, Rolling Stone (Feb. 23, 2025).

ICE 287(g) Program: Delegation of Immigration Authority Section 287(g) Immigration and Nationality Act

ICE 287(g) Program: Delegation of Immigration Authority Section 287(g) Immigration and Nationality Act
- Summary: ICE’s 287(g) Program allows ICE Enforcement and Removal Operations (ERO) to partner with state and local law enforcement agencies to identify individuals for removal and further engage in removal operations of noncitizens from the United States. There are three models detailed including the Jail Enforcement Model, the Task Force Model, and the Warrant Service Officer program. Information regarding participating agencies and pending agencies can be found on ICE’s webpage.
- Related Action: This relates to the Executive Order 14159: "Protecting the American People Against Invasion."

ICE Policy Memorandum: Issuance of Policy Memorandum 5004.3: Stays of Removal and Private Immigration Bills (January 31, 2025)

ICE Policy Memorandum: Issuance of Policy Memorandum 5004.3: Stays of Removal and Private Immigration Bills (January 31, 2025).
- Summary: Caleb Vitello, Acting Director of ICE at that time, authored this memorandum and sent it to all ICE employees for ICE employees to understand ICE’s new policy on issuances of stays of removal and the private immigration bill process. This policy includes that ICE will consider—at its discretion and on an individual basis—whether to issue a stay of removal for someone associated with a private immigration bill only if ICE receives a written request asking for ICE to stay removal from the Chair of the full Committee or Subcommittee of jurisdiction. Additionally, ICE will only grant a stay of removal associated with the private immigration bill process just once and will not grant subsequent requests, and the duration of the stay will last six months (though the ICE director can provide a one-time extension).

ICE Interim Policy Guidance: Issuance of Policy Memorandum 11005.4: Interim Guidance on Civil Immigration Enforcement Actions Involving Current or Potential Beneficiaries of Victim-Based Immigration Benefits (January 30, 2025)

ICE Interim Policy Guidance: Issuance of Policy Memorandum 11005.4: Interim Guidance on Civil Immigration Enforcement Actions Involving Current or Potential Beneficiaries of Victim-Based Immigration Benefits (January 30, 2025).
- Summary: Caleb Vitello, Acting Director of ICE at that time, authored this policy guidance memorandum about ICE’s enforcement actions and certain procedures related to immigrant survivors of crime. The interim policy guidance includes, for example, that ICE officers are not required “to affirmatively seek to identify indicia or evidence suggesting [a noncitizen] is a victim of a crime or consider such evidence as a positive discretionary factor in determining whether to take civil enforcement action.” Additionally, this policy guidance advises ICE officers and agents to consult with OPLA when ICE engages with individuals who have already gained status through a survivor-based form of relief. This policy memo rescinds and supersedes prior guidance, ICE Directive 11005.3: Using a Victim-Centered Approach with Noncitizen Crime Victims (Dec. 2021) and ICE Policy Statement 10076.1: Prosecutorial Discretion: Certain Victims, Witnesses, and Plaintiffs (June 2011).
- Related Action: The interim policy states that it is in accordance with Executive Order 14159: "Protecting the American People Against Invasion."
- Related Resource: AILA, Alliance for Immigrant Survivors, and ASISTA, Practice Alert: New ICE Guidance on Current or Potential Victim-Based Benefits (Feb. 5, 2025).

U.S. Customs and Border Protection (CBP)

CBP Announcement: CBP Ends CBP One Scheduling System and Cancels Upcoming Appointments (January 20, 2025)

CBP Announcement: CBP Ends CBP One Scheduling System and Cancels Upcoming Appointments (January 20, 2025).
- Summary: CBP One is no longer available to asylum-seekers at the U.S. border. The Biden Administration implemented the use of CBP One, a mobile phone application through which asylum-seekers could sign up for an appointment with U.S. immigration officials. Until the time of their appointment, they would have to wait in Mexico. The Trump administration suspended this application, and on the night of January 20, asylum-seekers with scheduled appointments received notifications on their phones that their appointments had been cancelled.
- How may this affect unaccompanied children? Youth may have had family members waiting for an appointment with the CBP One application, and the news of cancellation of appointments may be distressing. Additionally, while the majority of unaccompanied children did not enter the United States using CBP One, some unaccompanied children who traveled with a nonparent adult did and may have been processed into the United States with CBP One.
- Litigation: Check out Las Americas Immigrant Advocacy Center v. DHS, 1:24-cv-01702 (D.D.C.) to keep up with ongoing litigation related to the end of CBP One.
- Related Policy or Action: The end of CBP One stems from Executive Order 14165: “Securing Our Borders,” as section 7(a) directs DHS to stop using CBP One for parole or to facilitate entry to the United States.
- Related Article: Gustavo Solis, Matthew Bowler, Migrants stranded when thousands of appointments to enter the US are canceled as Trump takes office, Associated Press (Jan. 21, 2025).

Congressional Actions

Here, we list Congress’s bills, laws, and other related actions.

Bill Signed: House Reconciliation Bill (H.R. 1, July 4, 2025)

Bill Signed: House Reconciliation Bill (H.R. 1, July 4, 2025).
- Summary: President Trump signed R. 1 into law after the bill had been passed through Congress’s reconciliation process. The bill includes immigration and border-related spending provisions, including many fees on applications for immigration benefits; an additional $170.7 billion to DHS and the DOD for enforcement activity and border security; funds for expanding and enhancing DHS facilities, trainings, technology, and vehicles; additional funds for hiring more ICE agents; a large lump sum for ICE enforcement and deportation operations.
- How may this affect unaccompanied children? This bill can impact unaccompanied children in many ways. We point out a few significant potential impacts. The bill allows for indefinite detention of children and families, which is in violation of the Flores Settlement Agreement. The fee changes will impact unaccompanied children with new fees for asylum and special immigrant juvenile status (SIJS) applications. Additionally, the bill includes $300 million to ORR to conduct background checks and home studies of sponsors and to conduct physical examinations of unaccompanied children while in ORR custody to look for gang-related tattoos or markings.
- Related Resources:
  - National Immigration Project, Comparison Chart of the Immigration-Related Fee Changes Brought by H.R.1 The So-Called One Big Beautiful Bill Act (July 22, 2025).
  - KIND, The “One Big Beautiful Bill Act’s” Impacts on Unaccompanied Children: Analysis and Recommendations (July 2025).
  - AIC, Immigration Challenges and Concerns in Implementing the ‘One Big Beautiful Bill’ (July 15, 2025).
  - AIC, What’s in the Big Beautiful Bill? Immigration and Border Security Unpacked (July 14, 2025).
  - National Immigration Law Center, The Anti-Immigrant Policies in Trump’s Final ‘Big Beautiful Bill,’ Explained (July 8, 2025).

Law Passed: President Trump Signed the “Laken Riley Act” S.5 (Pub. L. 119-1) into Law (January 29, 2025)

Law Passed: President Trump Signed the “Laken Riley Act” S.5 (Pub. L. 119-1) into Law (January 29, 2025).

- Summary: President Trump signed into law S. 5, the “Laken Riley Act,” which requires the Secretary of Homeland Security to mandatorily detain noncitizens who have been charged with theft in the United States. Of significance, this law does not exempt minors. Specifically, the Laken Riley Act amends INA § 236(c), 8 U.S.C. § 1226(c) by adding an additional category at INA § 236(c)(1)(E), 8 U.S.C. § 1226(c)(1)(E), to require the DHS to detain any [noncitizen] who:
  - (i) is inadmissible under paragraph (6)(A), (6)(C), or (7) of section 212(a); and is
  - (ii) charged with, is arrested for, is convicted of, admits having committed, or admits committing acts which constitute the essential elements of any burglary, theft, larceny, shoplifting, or assault of a law enforcement officer offense, or any crime that results in death or serious bodily injury to another person.
- Related Articles and Resources:
  - ILRC, The Laken Riley Act & Juvenile Delinquency (Feb. 7, 2025).
  - The National Immigration Project (NIPNLG), Practice Advisory: The Laken Riley Act’s Mandatory Detention Provisions (Feb. 5, 2025).
  - Roque Planas, Immigration Bill Hands White House the Leverage on Detention, The Huffington Post (Feb. 3, 2025).
  - NILA, Six Amendments to the Immigration and Nationality Act Made by the Laken Riley Act (Jan. 29, 2025).
  - NIPNLG, Community Explainer: Laken Riley Act (Jan. 27, 2025).

Executive Orders and Actions

These are President Trump’s actual policies, orders, proclamations, and memoranda.

Presidential Proclamation 10935: “Project Homecoming” (May 9, 2025)

Presidential Proclamation 10935: “Project Homecoming” (May 9, 2025).
- Summary: Through this proclamation, President Trump announced the launch of Project Homecoming, a national initiative to encourage voluntary departure of undocumented immigrants by offering a one-time "exit bonus" and covering the full cost of their travel out of the United States, including air tickets and logistical support. Participants will be assisted through the CBP One app, “CBP Home” processing hubs, and provided with streamlined check-out procedures and airport escorts. The proclamation frames this initiative as a taxpayer-saving alternative to mass enforcement and detention, citing an estimated $150 billion annual cost of illegal immigration. It also warns that those who do not voluntarily depart will face enhanced enforcement (such as the hiring of an additional 20,000 deportation officers) and will be barred from future legal immigration benefits. USCIS also provided information on their website regarding using CBP Home for self-deportations.

Executive Order (EO) 14247: “Protecting American Communities from Criminal [Noncitizens]” (April 28, 2025)

Executive Order (EO) 14247: “Protecting American Communities from Criminal [Noncitizens]” (April 28, 2025).
- Summary: This EO directs the AG and DHS to publish a list of sanctuary cities for determination of cutting federal funding to those jurisdictions and whether to bring suit against them for their “defiance of Federal immigration law enforcement and any potential violations of Federal criminal law.”
- Related Resource: Congressional Research Service, ‘Sanctuary’ Jurisdictions: Legal Overview (June 6, 2025).

Executive Order 14248: “Preserving and Protecting the Integrity of American Elections” (March 25, 2025)

Executive Order 14248: “Preserving and Protecting the Integrity of American Elections” (March 25, 2025).
- Summary: This EO purports to “safeguard American elections in compliance with federal laws” by, among many things, requiring proof of citizenship in voting. Key provisions of the EO include the requirements that the Election Assistance Commission (EAC) require proof of citizenship for the mail-in voter registration form and that the DOS and DHS allow election officials to verify citizenship status through federal databases.
- (W.D. Wa.). These cases challenge the constitutionality of this EO and seek to prevent implementation. Keep up with litigation to EO 14248 on Just Security’s Trump Administration Litigation Tracker.
- Related Articles:
  - Ali Swenson and Christina A. Cassidy, Judge limits a small part of a court order blocking Trump's election overhaul as lawsuits continue, AP News via MSN (July 19, 2025).
  - Michael R. Blood , Kate Brumback, Julie Carr Smyth, Ali Swenson, and Robert Yoon, Trump’s executive order on elections is far-reaching. But will it actually stick?, AP News (Mar. 26, 2025).
  - Ali Swenson and Christina A. Cassidy, Trump signs order seeking to overhaul US elections, including requiring proof of citizenship, AP News (Mar. 25, 2025).

Presidential Memorandum: “Preventing Abuses of the Legal System and the Federal Court” (March 22, 2025)

Presidential Memorandum: “Preventing Abuses of the Legal System and the Federal Court” (March 22, 2025).
- Summary: This executive order directs the Attorney General to seek sanctions against attorneys and law firms who engage in frivolous, unreasonable, and vexatious litigation against the administration or in matters before executive departments and agencies of the United States. President Trump directs the Attorney General to take all appropriate action to refer for disciplinary action any attorney whose conduct in Federal court or before any component of the Federal Government appears to violate professional conduct rules, including rules governing meritorious claims and contentions, and particularly in cases that implicate national security, homeland security, public safety, or election integrity. Further directs the Attorney General, in consultation with any relevant senior executive official, to review conduct by attorneys or their law firms in litigation against the Federal Government over the last eight years.
- Related Articles and Resources:
  - Mike Scarcella, Andrew Goudsward, and Sara Merken, Trump targets lawyers in immigration cases, lawsuits against administration, Reuters (March 24, 2025).
  - David Rohde, Trump targets lawyers who he says file 'frivolous' lawsuits against his administration, NBC News (March 23, 2025).
  - Ali Bianco, Trump hangs sword of Damocles over the American legal system, Politico (March 22, 2025).
  - Devlin Barrett, With New Decree, Trump Seeks to Cow the Legal Profession, The New York Times (March 22, 2025).

Presidential Proclamation: Invocation of the Alien Enemies Act Regarding the Invasion of The United States by Tren De Aragua” (March 15, 2025)

Presidential Proclamation: Invocation of the Alien Enemies Act Regarding the Invasion of The United States by Tren De Aragua” (March 15, 2025).
- Summary: With this proclamation, President Trump invokes the Alien Enemies Act against Tren de Aragua, a Venezuelan gang and orders that all Venezuelan nationals, 14 years of age or older, who are physically present in the United States, who are neither citizens nor lawful permanent residents, and who the U.S. government determines to be members of Tren de Aragua are subject to immediate apprehension, detention, and removal. President Trump orders both the Attorney General and DHS Secretary to carry out this order using all available resources. The Alien Enemies Act—one of the four Alien and Sedition Acts of 1798—is a wartime law, last invoked during the United States’ involvement in World War II, and notably attributed to the U.S. internment of more than 110,000 individuals of Japanese, German, and Italian descent. The purpose of the Act is to allow the president of the United States to detain, relocate, or remove noncitizens from the United States if they are from a country with which the United States is at war.
- Litigation: Several cases were filed in response to this presidential proclamation and are at different stages of litigation. For example, one key case that reached the Supreme Court’s docket is J.G.G. v. Trump, 1:25-cv-00766 (D.D.C. 2025). Keep up with litigation on this executive order and view court documents and updates on Just Security’s Trump Administration Litigation Tracker.
- Related Policy or Action: The invocation of the Alien Enemies Act stems from Executive Order 14157: "Designating Cartels and Other Organizations As Foreign Terrorist Organizations and Specially Designated Global Terrorists." This Executive Order fulfills one of Trump’s promises expressed during the campaign trail for his re-election, as President Trump proclaimed in 2023 that he would invoke this federal law for deportation purposes.
- Related Articles and Resources:
  - Devan Cole and Molly Reinmann, Attorneys for wrongly deported Venezuelan asylum seeker will seek criminal contempt proceedings after prisoner swap, CNN (July 22, 2025).
  - ‘I’m free now’: Venezuelans held in El Salvador reunite with families, REUTERS (July 22, 2025).
  - CLINIC, Part II: What is Happening with the Alien Enemies Act, Kilmar Abrego Garcia, and the Salvadoran Prison Known as CECOT? (June 26, 2025).
  - ASISTA, The Fight to Protect Survivors from the Alien Enemies Act Continues (May 29, 2025).
  - Devan Cole, Priscilla Alvarez, and Katelyn Polantz, Trump-appointed judge says president’s use of Alien Enemies Act is unlawful in first-of-its-kind ruling, CNN (May 2, 2025).
  - Rachel Treisman, 4 things to know about the Alien Enemies Act and Trump's efforts to use it, National Public Radio (Mar. 18, 2025).
  - David Noriega and Sarah Ford, The truth about Tren de Aragua, the gang at the center of Trump's immigration crackdown, NBC News (Mar. 18, 2025).
  - Maria Sacchetti, Marianne LeVine, and Tobi Raji, After judge blocks Alien Enemies Act, White House claims nearly 300 already deported, The Washington Post (Mar. 15, 2025).
  - Ximena Bustillo, Federal judge blocks Trump's plan to target 'alien enemies' for deportation, National Public Radio (Mar. 15, 2015).
  - Vaughn Hillyard, Jake Traylor and Dan Gallo, Trump vows to invoke a wartime law to deport suspected foreign gang members and drug dealers, NBC News (Sept. 20, 2023).

Executive Order 14224: "Designating English as the Official Language of the United States," 90 FR 11363 (March 1, 2025)

Executive Order 14224: "Designating English as the Official Language of the United States," 90 FR 11363 (March 1, 2025).
- Summary: President Trump signed Executive Order 14224, designating English as “the official language of the United States.” Further, this executive order rescinds Executive Order 13166 of August 11, 2000, “Improving Access to Services for Persons with Limited English Proficiency.” Moreover, per this executive order, agency leaders are “not required to amend, remove, or otherwise stop production of documents, products, or other services prepared or offered in languages other than English.”

Executive Order 14157: “Designating Cartels And Other Organizations As Foreign Terrorist Organizations And Specially Designated Global Terrorists” (January 20, 2025)

Executive Order 14157: “Designating Cartels And Other Organizations As Foreign Terrorist Organizations And Specially Designated Global Terrorists” (January 20, 2025).
- Summary: This executive order designates major transnational criminal organizations—primarily Mexican drug cartels like Sinaloa, Jalisco New Generation, Gulf, Northeast, La Nueva Familia Michoacána, United Cartels, as well as MS‑13 and Venezuela's Tren de Aragua—as Foreign Terrorist Organizations (FTOs) under the Immigration and Nationality Act and Specially Designated Global Terrorists (SDGTs) under IEEPA and Executive Order 13224. The order directs the Secretary of State (in consultation with Treasury, DOJ, DHS, and Intelligence) to finalize such designations within 14 days and empowers the Attorney General and DHS to prepare for potential use of the Alien Enemies Act. The measure aims to leverage tools such as asset freezes, criminal prosecutions, visa bans, intelligence cooperation, and possible military support to combat cartel violence and disrupt their operations both domestically and internationally.

Executive Order 14160: "Protecting the Meaning and Value of American Citizenship" (January 20, 2025)

Executive Order 14160: "Protecting the Meaning and Value of American Citizenship" (January 20, 2025).
- Summary: President Trump signed Executive Order 14160 attempting to end birthright citizenship, a form of citizenship automatically bestowed upon birth and protected in the Constitution of the United States through the Fourteenth Amendment, stating: “"all persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside." For noncitizens, this is significant, as children born in the United States to noncitizen parents are U.S. citizens, despite their parents’ immigration status.
- Litigation: The Supreme Court ruled to limit the use of nationwide injunctions in one of the key cases challenging President Trump’s executive order on birthright citizenship. However, a new nationwide injunction still blocks the order. U.S. District Judge Laplante issued a preliminary injunction and certified a nationwide class of United States-born children in Barbara et al. v. Trump et al. on July 10, 2025, and the government did not appeal during a 7-day stay period. Find more information from the ACLU on the case here.
- Related Articles and Resources:
  - Jan Wolfe, US Judge weighs putting new block on Trump’s birthright citizenship order, REUTERS (July 18, 2025).
  - Kelsey Dallas, Where does Trump’s birthright citizenship order currently stand?, SCOTUSblog (July 18, 2025).
  - Congressional Research Service, Trump v. CASA, Inc. and Nationwide Injunctions During the Second Trump Administration (July 16, 2025).
  - AIC, In Birthright Citizenship Decision, the Supreme Court Expanded Trump’s Power (July 1, 2025).
  - AIC, Birthright Citizenship in the United States (Mar. 14, 2025).
  - Laila Khan and Raul Pinto, Breaking Down Trump’s Attempt to End Birthright Citizenship, Immigration Impact (Feb. 7, 2025).

Executive Order 14159: "Protecting the American People Against Invasion" (January 20, 2025)

Executive Order 14159: "Protecting the American People Against Invasion" (January 20, 2025).
- Summary: This executive order lays the foundation for many of the administration’s individual policies regarding undocumented immigrants—as President Trump guides DHS and other agencies to take immigration authority and engage in broad actions against all removable noncitizens present in the United States. This executive order seeks to undo many (if not all) of the Biden Administration’s policies regarding undocumented immigrants, and it also includes policies that impact migration trends to the United States.
- Notable sections and provisions:
  - Section 4 empowers DHS agencies ICE, CBP, and USCIS to take all appropriate action and set civil immigration enforcement priorities in such a way “that protect the public safety and national security interests of the American people, including by ensuring the successful enforcement of final orders of removal.” Additionally, this section also provides that the DHS should ensure that the main mission of ICE’s investigative branch Homeland Security Investigations (HSI) be the enforcement of INA provisions and other immigration laws related to unlawful entry and presence in the United States.
  - Section 5 provides that the Attorney General should take all action to prioritize prosecuting criminal offenses “related to the unauthorized entry or continued unauthorized presence” of noncitizens in the United States.
  - Section 7 includes a provision for the DHS, DOJ, and DOS to ensure the registration of noncitizens; to raise awareness on the “legal obligation” of noncitizens who are not already registered to comply with the U.S. Code’s registration requirements; and to provide that failure for a noncitizen to register will be a criminal and civil immigration enforcement priority.
  - Section 8 directs DHS and the Secretary of Treasury to assess and collect civil fines and penalties from unlawfully present noncitizens and others who facilitated or assisted the presence of undocumented individuals in the United States.
  - Section 9 tasks DHS to maximize use of expedited removal authorities to the maximum extent possible authorized by law.
  - Section 10 tasks the DHS Secretary to ensure detention of immigrants apprehended for violating immigration law while they await the outcome of their immigration proceedings or removal to their country of origin. Additionally, this section tasks DHS to use all available resources or establish contracts to increase detention space to detain removable immigrants.
  - Section 11 directs the DHS Secretary to empower state and local law enforcement officers and agencies—to the maximum extent allowed by the law—to enforce immigration laws in conjunction with federal agents.
  - Section 16 tasks the DOS, DHS, and DOJ to rescind all policies of the prior administration which contributed to the “increased or continued presence of” undocumented immigrants in the United States. This includes limiting grants of humanitarian parole and reconsidering the scope and designation of Temporary Protected Status (TPS).
  - Section 18(b) requires the HHS Secretary, Attorney General, and DHS Secretary to “take all appropriate action” to stop the “smuggling and trafficking of” immigrant children into the United States, including through the “sharing of any information necessary” to fulfill that goal.
  - Section 19 compels review of federal contracts, grants, or other agreements to nonprofits that provide services to noncitizens and to freeze funding pending review.
  - Section 20 lists how undocumented immigrants shall not have access to public benefits.

Executive Order 14165: "Securing Our Borders" (January 20, 2025)

Executive Order 14165: "Securing Our Borders" (January 20, 2025).
- Summary: This executive order discusses the Trump administration’s plan to secure and take control of the U.S. borders, with emphasis on the southern border and unlawful border crossings. The Trump administration will continue implementing physical barriers and deploying more personnel to the border. Additionally, this executive order covers “detaining, to the maximum extent authorized by law, [noncitizens] apprehended on suspicion of violating Federal or State law, until such time as they are removed from the United States; removing promptly all [noncitizens who enter or remain in violation of Federal law; pursuing criminal charges against illegal [noncitizens] who violate the immigration laws, and against those who facilitate their unlawful presence in the United States; cooperating fully with State and local law enforcement officials in enacting Federal-State partnerships to enforce Federal immigration priorities,” among other concerns.
- Notable sections and provisions:
  - Section 2(a) calls for the building of a wall and other barriers.
  - Sections 2(c)-(d) and Section 5 include information about plans for detention and removal for those who enter without inspection.
  - Section 6 directs DHS, DOS, and DOJ to resume the prior Trump Administration’s Migrant Protection Protocols.
  - Section 7 calls for the elimination of humanitarian parole programs, such as the CNHV Program. Further, section 7 directs CBP to terminate CBP One.
  - Section 9(b) provides that DHS can use any technology and procedure available to “determine the validity of any claimed familial relationship between [noncitizens] encountered or apprehended” by DHS.

Executive Order 14168: “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” (January 20, 2025)

Executive Order 14168: “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” (January 20, 2025).
- Summary: The purpose of this executive order is for the Trump Administration to remove inclusive language of other identities and only promote two biological sexes.
- Notable sections and provisions:
  - Section 3(d) tasks DOS and DHS to require that government-issued identification documents, such as passports and driver’s licenses, reflect "immutable biological" sex.
  - Section 4(a) states that DOJ and DHS are to make sure that biological males are not held in women's prisons or detention centers.

Executive Order 14148: "Initial Rescissions of Harmful Executive Orders And Actions" (January 20, 2025)

Executive Order 14148: "Initial Rescissions of Harmful Executive Orders And Actions" (January 20, 2025).
- Summary: This executive order rescinds several of the Biden Administration’s executive orders related to immigration, including:
  - Executive Order 13986 of January 20, 2021 (“Ensuring a Lawful and Accurate Enumeration and Apportionment Pursuant to the Decennial Census”) required census counts to include all residents, regardless of immigration status.
  - Executive Order 14011 of February 2, 2021 (“Establishment of Interagency Task Force on the Reunification of Families”) to reunite children separated from their families at the United States-Mexico border as a result of the Zero-Tolerance Policy.
  - Executive Order 13993 of January 20, 2021 (“Revision of Civil Immigration Enforcement Policies and Priorities”) which covered setting priorities to best serve the national interest and also adhering to due process of law.

Presidential Proclamation 10886: "Declaring a National Emergency at the Southern Border of the United States," 90 FR 8327 (January 20, 2025)

Presidential Proclamation 10886: "Declaring a National Emergency at the Southern Border of the United States," 90 FR 8327 (January 20, 2025).
- Summary: With this proclamation, President Trump declared a national emergency at the southern border, such that to invoke section 12302 of U.S. Code Title 10 and the use of Armed Forces at the southern border.
- Notable sections and provisions:
  - Section 1 calls for military personnel and resources to secure operational control of the southern border.
  - Section 2 calls for additional physical barriers to be put in place along the southern border.
  - Section 4 directs the DOD and DHS to prioritize impeding unlawful entry at the southern border and protecting the safety of DHS personnel and military members.

Presidential Proclamation 10886: "Declaring a National Emergency at the Southern Border of the United States," 90 FR 8327 (January 20, 2025)

Presidential Proclamation 10886: "Declaring a National Emergency at the Southern Border of the United States," 90 FR 8327 (January 20, 2025).
- Summary: With this proclamation, President Trump declared a national emergency at the southern border, such that to invoke section 12302 of U.S. Code Title 10 and the use of Armed Forces at the southern border.
- Notable sections and provisions:
  - Section 1 calls for military personnel and resources to secure operational control of the southern border.
  - Section 2 calls for additional physical barriers to be put in place along the southern border.
  - Section 4 directs the DOD and DHS to prioritize impeding unlawful entry at the southern border and protecting the safety of DHS personnel and military members.

Executive Order 14161: “Protecting the United States from Foreign Terrorists and Other National Security and Public Safety Threats" (January 20, 2025)

Executive Order 14161: “Protecting the United States from Foreign Terrorists and Other National Security and Public Safety Threats" (January 20, 2025).
- Summary: This order tasks federal agencies to improve and increase the screening policies for individuals entering the United States, in the interests of national security and promoting public safety. Those coming from countries identified as national security risks will be subject to enhanced screening and vetting processes to be granted entry to the United States. The executive order directs identifying which countries for which “vetting and screening information is so deficient as to warrant a partial or full suspension on the admission of nationals from those countries.” The United States will also identify how many nationals from those countries have entered or have been admitted into the United States on or since January 20, 2021.
- Notable sections and provisions:
  - Sections 2(a) and 3(a) require maximum vetting of all noncitizens seeking admission or entry to the United States.
  - Sections 2(b) and 2(c) direct agencies to identify countries from which to suspend admissions and prioritize the removal of individuals from those countries.
- Related Resources:
  - NAFSA: Association of International Educators, Executive Order: Protecting The United States From Foreign Terrorists And Other National Security And Public Safety Threats (Feb. 11, 2025).
  - Faiza Patel, Trump’s Executive Order on Foreign Terrorists: Implications for the Rights of Non-Citizens, The Brennan Center for Justice (Feb. 6, 2025).

Issues that May Arise in Certain Unaccompanied Children’s Cases

Here, we list select broader immigration law changes that may affect certain unaccompanied children.

Temporary Protected Status (TPS)

Temporary Protected Status (TPS)
- Summary: The DHS Secretary may designate a foreign country for TPS due to temporary conditions in the country preventing the country's nationals from returning safely, or in certain circumstances, where the country is unable to handle the return of its nationals adequately. USCIS may grant TPS to eligible nationals of certain countries (or parts of countries), who are already in the United States. Since the administration change, DHS has terminated TPS designations for certain countries and indicated further terminations for others. See the list below of countries designated with TPS and click the links to learn more about their TPS status and whether it is still current. Afghanistan was included on the list until recently, but TPS no longer in effect as of July 22, 2025.
- Countries designated for TPS:

Third Country Removals

Third Country Removals
- Summary: Since the administration change, the Trump administration has sought to expand the government’s ability to execute third country removals. A third country removal is the removal of a noncitizen to “any country with a government that will accept the [individual]. 8 U.S.C. § 1231(b)(1)(C)(iv) and 1231 (b)(2)(E)(vii). Congress had previously limited the use of these removals because of the burden to the noncitizen; however, third country removals are permissible when the government has tried all statutorily-listed alternatives and determines that such alternatives are “impracticable, inadvisable, or impossible.” 8 U.S.C. § 1231(b)(1)(C)(iv), (2)(E)(vii). The Trump administration notoriously began carrying out third country removals of certain Venezuelans and others of different nationalities to El Salvador, prompting litigation and concerns of the Trump administration seeking agreements with other countries to carry out such removals (for example, Libya and South Sudan). In a 6-3 decision from June 2025, the Supreme Court allowed the Trump administration to continue deporting individuals to countries of which the individuals have no association.
- Litigation: You can read more about the ongoing, related litigation in this Practice Alert: Third Country Deportations and D.V.D. v. DHS created by NWIRP, NILA, and Human Rights First in June 2025.
- Related Article: Ali Abbas Ahmadi, US Supreme Court allows Trump to resume deportations to third countries, BBC News (June 23, 2025).

Travel Ban

Travel Ban
- Summary: In June 2025, the Trump administration issued a travel ban affecting 19 countries, preventing travel and immigration of individuals from those countries to the United States. The travel ban designates selected countries in three categories, full ban, partial ban, and watchlist countries. The full ban suspends all visa categories for individuals from banned those nations; the partial ban applies restrictions to foreign nationals eligible for certain visa categories; and some countries are placed on a “watchlist” for further determination of partial or full ban of foreign nationals in those countries. The Trump administration selected these countries because of purported visa overstays and supposed issues with information-sharing practices involving national security. The ban is applicable to individuals outside of the United States who have not already been issued an immigrant visa.
- Related Action: Presidential Proclamation “Restricting the Entry of Foreign Nationals to Protect the United States from Foreign Terrorists and Other National Security and Public Safety Threats” (June 4, 2025).
- Related Resource: AIC, Analysis of Trump’s New Travel Ban (June 6, 2025).

End of CHNV Parole Program

End of CHNV Parole Program
- Summary: DHS is terminating parole granted to individuals from Cuba, Haiti, Nicaragua, and Venezuela and their immediate family members (those who arrived via the “CHNV parole programs”) that DHS announced in 2022 and 2023. The CHNV program will officially end on April 24, 2025, terminating parole for individuals who entered the United States under the CHNV program. Nearly 532,000 individuals will lose their lawful status to be in the United States on that date. See DHS FR Doc. 2025-05128 (Mar. 21, 2025) for the official notice. After the Supreme Court upheld the cancellation of the program, DHS issued notices of termination of the CHNV program and encouraged parolees to self-deport.
- Litigation: A class action lawsuit, Svitlana Doe v. Noem, was filed challenging Secretary Noem’s decision to terminate multiple humanitarian parole programs, including CHNV, Uniting for Ukraine, and others. Plaintiffs—parole beneficiaries, sponsors, and advocacy organizations—argue the mass termination violated the Administrative Procedure Act and due process by failing to conduct individualized case reviews. The plaintiffs seek to block the cancellations and reinstate protections for affected individuals. In April 2025, a federal court issued a preliminary injunction halting the terminations, but the Supreme Court later stayed that ruling, allowing DHS to proceed while litigation continues. Keep up with this important case on Justice Action Center’s dedicated webpage.
- Related Articles and Resources:
  - CLINIC, Updates on CHNV Parole Terminations and Federal Litigation (June 30, 2025).
  - Nina Totenberg, Supreme Court allows Trump administration to end humanitarian status for some migrants, NPR (May 30, 2025).
  - Andy J. Semotiuk, Trump Immigration Policy Ending Protection For 1.8 Million Immigrants, Forbes (Mar. 7, 2025).

For more information on the recent immigration-related executive orders and policy changes, see the following resources to help track changes:

If you have any feedback or suggestions to accommodate different learning styles while also keeping this post organized and easy for practitioners to read and digest, please reach out to us at cila@abacila.org.

A Note on Self-Care: At CILA, we value self-care and having an individualized approach and journey to taking care of your health. During times like these, when the populations we serve are under attack or threat by institutions instead meant to provide protection, the need for self-care is more paramount than ever for advocates. Self-care is not just a buzzword; it is an ethical obligation, and it can be the very thing that prevents compassion and resistance fatigue and creates sustainability so that you can continue championing for immigrant youth. CILA encourages you to check out our resources, “Social Work Corner – Finding Strength in Community: Why Community Care is Essential to Self-Care” (Feb. 2025) and “Self-Care for Advocates Working with Unaccompanied Immigrant Youth” (Oct. 2024) to learn more about self-care and how it can complement and reinvigorate your advocacy during challenging times.

Additionally, as always and especially now, our sincerest thanks for your advocacy and pursuit of justice of immigrant children. “When you see something that is not right, not fair, not just, you have to speak up. You have to say something; you have to do something.” - John Lewis

¹CILA’s review of the different immigration executive orders and agency actions is non-exhaustive. We are focusing our review on actions that are most likely to impact unaccompanied children. There are several resources available to view a more complete list of changes, such as the American Immigration Lawyer Association’s (AILA) “Tracking Notable Executive Branch Action during the Second Trump Administration” and the Immigration Policy Tracking Project’s “Tracking Trump Administration Immigration Policies.” Additional tracking resources are also included at the end of this blog post. It is always important to conduct independent research for the most up to date information. Also, be aware that immigration law and policy is an area that changes frequently.

Acronyms and Abbreviations present in this blog post:

Health and Human Services (HHS) and Office of Refugee Resettlement (ORR) Updates

HHS General Updates

ORR Updates

Department of Justice (DOJ) and Executive Office of Immigration Review (EOIR) Updates

DOJ General Updates

Select DOJ Litigation Updates

EOIR General Updates

EOIR Memoranda

Department of Homeland Security (DHS) Updates, Policies, and Actions

General DHS Updates

U.S. Citizenship and Immigration Services (USCIS)

U.S. Immigration and Customs Enforcement (ICE)

U.S. Customs and Border Protection (CBP)

Congressional Actions

Executive Orders and Actions

Issues that May Arise in Certain Unaccompanied Children’s Cases

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© 2023 American Bar Association | CILA Children's Immigration Law Academy

Acronyms and Abbreviations present in this blog post:

Health and Human Services (HHS) and Office of Refugee Resettlement (ORR) Updates

HHS General Updates

ORR Updates

Department of Justice (DOJ) and Executive Office of Immigration Review (EOIR) Updates

DOJ General Updates

Select DOJ Litigation Updates

EOIR General Updates

EOIR Memoranda

Department of Homeland Security (DHS) Updates, Policies, and Actions

General DHS Updates

U.S. Citizenship and Immigration Services (USCIS)

U.S. Immigration and Customs Enforcement (ICE)

U.S. Customs and Border Protection (CBP)

Congressional Actions

Executive Orders and Actions

Issues that May Arise in Certain Unaccompanied Children’s Cases

Every child deserves representation.Get involved.

Please help & donate today.

About us

Our mission

Contact us

Phone: 346-444-2569

Email: cila@abacila.org

About

Pro Bono

Resources

Training

© 2023 American Bar Association | CILA Children's Immigration Law Academy

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Every child deserves representation.
Get involved.