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2.0

EOIR Acting Director provides guidance on adjudication of constitutional challenges

  1. Original Date Announced

    September 5, 2025

    EOIR Acting Director Sirce Owen issued Policy Memorandum (PM) 25-45, “Consideration of Constitutional Arguments in Agency Adjudications,” to provide guidance to adjudicators confronted with constitutional issues.

    The PM states that EOIR adjudicators may generally consider arguments arising out of constitutional law and should faithfully apply established relevant precedent. It notes that EOIR has historically held that it cannot adjudicate challenges related to the constitutionality of statutes, though it can address constitutional challenges to the application of statutes. However, the PM states that this distinction between constitutional challenges to a statute itself and challenges to the application of a statute is questionable after recent Supreme Court precedent.

    The PM further directs EOIR adjudicators to maintain familiarity with established jurisprudence on constitutional law issues likely to arise in proceedings before them, as well as situations in which Supreme Court decisions may have superseded EOIR precedent.

    Trump 2.0 [ID #2014]

    2025.09.05 EOIR PM 25-45 - Consideration of Constitutional Arguments in Agency Adjudications
  2. Effective Date

    September 5, 2025

Current Status

None

Original Trump Policy Status

Status: Final/Actual
Trump Administration Action: Agency Directive
Subject Matter: Hearings and Adjudications
Agencies Affected: EOIR

To provide information, corrections, or feedback, please email IPTP.feedback@gmail.com

To provide information, corrections, or feedback, please email IPTP.feedback@gmail.com