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2.0

EOIR Acting Director rescinds guidance on DHS "Prosecutorial Discretion"

  1. Original Date Announced

    January 29, 2025

    EOIR's Acting Director issued PM 25-09, rebuking and rescinding PM 21-25. The earlier memo, issued subsequent to DHS' issuance of related memoranda, provided guidance to judges and the BIA on DHS enforcement priorities and the use of prosecutorial discretion.

    PM 25-09 criticizes PM 21-25 as having "impermissibly injected EOIR . . . into the core prosecutorial functions of DHS,” and characterizes the prior memo as “pressuring DHS to adopt a particular position” and “eroding” the judges' independence. PM 25-09, citing the cancellation of the related DHS memoranda, finds no basis for PM 21-25 and rescinds it.

    Notably, PM 25-09 makes no reference to an intervening memorandum, DM 23-04, which had already rescinded PM 21-25. In light of the position taken in PM 25-09, it is unlikely the intervening memo remains in force but that is unclear.

    Trump 2.0 [ID #1470]

    2025.01.29 EOIR PM 25-09 Cancellation of Policy Memorandum 21-25
  2. Effective Date

    January 29, 2025
  3. Subsequent Trump and Court Action

    February 3, 2025

    2025.02.03 - PM 25-16: Cancellation of Director's Memorandum 23-04

    EOIR's Acting Director (clearly realizing that PM 25-09 rescinded the wrong memo on DHS enforcement priorities and prosecutorial discretion) issued PM 25-16, rebuking and rescinding DM 23-04.

    Rehashing the earlier condemnation of the Biden era guidance on this subject, PM 25-16 criticizes DM 23-04 as having "compromised the decisional independence of EOIR adjudicators, improperly crossed the line separating EOIR and DHS’s distinct functions, and turned EOIR into a results-oriented subcomponent of DHS, rather than a truly impartial adjudicatory body."

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  4. Subsequent Trump and Court Action

    August 18, 2025

    2025.08.18 Reported: The Federal Government Has Moved to Reopen Thousands of Paused Immigration Cases Nationwide - Gothamist

    The Gothamist reports that the federal government has filed nearly 49,000 motions to recalendar immigration cases that had been administratively closed. The figure is 1.5 times greater than the number of such motions under the first Trump administration, and nearly six times the number under the Biden administration.

    View Document

Current Status

None

Original Trump Policy Status

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

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