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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    Notably, PM 25-09 makes no reference to an intervening memorandum, DM 23-04, which had already rescinded PM 21-25.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(s)

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      EOIR's Acting Director (clearly realizing that PM 25-09 rescinded the wrong memo on DHS enforcement priorities and prosecutorial discretion) issued PM 25-16, rebuking and rescinding DM 23-04.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

      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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