We are excited to share a new resource authored by CILA and our partners at the End SIJS Backlog Coalition and the National Immigration Project, “Template Motion: Defending SIJS Clients in Removal Proceedings.” This resource provides an adaptable template for practitioners representing SIJS youth awaiting visa availability that contains arguments against the IJ’s entry of a removal order and in order to preserve issues for appeal.
Youth with approved SIJS petitions must wait years before they move to the final step in the process of filing an application for SIJS-based adjustment of status. Given the Trump administration’s super-charged immigration enforcement efforts, a growing number of youth with SIJS who are waiting in the visa backlog face removal proceedings in which the Department of Homeland Security (DHS) seeks their removal. While in removal proceedings, these youth are at risk of receiving a removal order from the immigration judge (IJ).
The framework for this template motion was developed in part from the practice advisory issued by CILA, the End SIJS Backlog Coalition, National Immigration Project, ILRC, and Safe Passage Project, “Quick Guide: Defending SIJS Clients in Removal Proceedings.”
CILA is grateful for our partnership with the End SIJS Backlog Coalition and NIPNLG, as well as the support of other practitioners who provided their expertise and time to review the resource.
The resource is available here. You will need a free CILA account to access it. Sign up for an account here. Contact CILA at cila@abacila.org if you need additional assistance accessing this resource.

