Acting EOIR Director issues PM 25-04 rescinding PM 21-16 and attacking BIA management

Original Date Announced
January 27, 2025
On January 27, 2025, the Acting Director of EOIR issued Policy Memorandum (PM) 25-04, which rescinds and cancels PM 21-16 (which had rescinded and cancelled PM 20-01, Case Processing at the Board of Immigration Appeals). While the memo rescinds the Biden era memo, it does not revive the prior Trump-era memo and does not set forth any new procedures or requirements. Footnote 9 does stress, however, that "EOIR has no policy restricting or prohibiting the use of summary dismissals of appeals, nor does it have a policy restricting or prohibiting the use of affirmances without opinion."
PM 25-04 asserts the prior Trump memo was in response to the Board of Immigration Appeals' case management system becoming "dysfunctional" in 2019. It claims the Biden memo was "pretextual dissembling" that "undermines EOIR’s integrity and insults both EOIR employees and its stakeholders." It also claims that, with a few brief exceptions, the Board has suffered from poor leadership and poor management "since at least the mid-1990s."
EOIR PM 25-04
Effective Date
January 27, 2025

None

Status: Final/Actual

Trump Administration Action: Agency Directive

Subject Matter: Hearings and Adjudications

Agencies Affected: EOIR

Associated or Derivative Policies

March 17, 2021
EOIR Acting Director issued Policy Memorandum (PM) 21-16 rescinding and canceling PM 20-01, Case Processing at the Board of Immigration Appeals.
2021.03.17 PM 21-16

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