Original Date Announced

ICE sent an email directive to Enforcement and Removal Operations (ERO) officers directing them to consider for expedited removal when they report to an ERO office all noncitizens previously released by CBP who have not affirmatively applied for asylum with USCIS. This includes (1) paroled "arriving aliens"; (2) "aliens" issued a Notice to Report (NTR); and (3) "aliens" processed for Parole + ATD or Parole with Conditions (PWC).

For "arriving aliens," the directive states that "[t]here is no time limit on the ability to process such aliens for ER."

For NTR, Parole + ATD, and PWC cases, the directive states that they are subject to ER if they are inadmissible under either INA 212(a)(6)(C) or (a)(7) and either the initial CBP encounter was within 14 days and 100 air miles of the border or the noncitizen has not been continuously physically present in the US for two years prior to the inadmissibility finding by ERO.

Individuals not processed for ER should be placed in removal proceedings in immigration court.

If a noncitizen in in active parole status, the NTA or ER charging document will serve to terminate their parole.

This email directive seems to expose millions of individuals who came to the country legally on parole programs (e.g., CHNV, U4U, Afghan parole, family reunification parole, CAM) to expedited removal. It additionally seems to reinterpret the temporal limits on expanded ER to allow people to be subjected to ER even if they have lived in the country continuously for well past two years.

Trump 2.0 [ID# 1587]

Subsequent Trump and Court Action

2025.06.11 Amended Complaint - CHIRLA v. Noem

The Coalition for Humane Immigrant Rights, UndocuBlack Network, and CASA filed a lawsuit on March 24, 2025 challenging three Trump administration written directives targeting people paroled into the country at ports of entry for expedited removal, including the ICE directive that is the subject of this action. On June 11, 2025, the plaintiffs filed an amended complaint, which is the version included here. The amended complaint alleges that the Trump administration’s actions are contrary to law and the agency's regulations and violate the Administrative Procedure Act and Constitution. Coalition for Humane Immigrant Rights v. Noem, No. 1:25-cv-00872 (D.D.C.).

**Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

Subsequent Trump and Court Action

2025.05.21 Reported: ICE arrests at WA immigration court spark fear of fast-track removal - Seattle Times

Multiple reports across the country—including in Miami, Seattle, and Chicago—indicate that U.S. Immigration and Customs Enforcement (ICE) has begun dismissing removal proceedings against respondents who have been in the country for less than two years, in order to place those individuals in expedited removal proceedings.

Subsequent Trump and Court Action

2025.06.11 Motion for Stay - CHIRLA v. Noem

Plaintiffs moved to immediately postpone and stay "the effective dates of implementation and enforcement of the January 23 Huffman Memorandum, February 18 ICE Directive, and March 25 Parole Termination Notice for Cubans, Haitians, Nicaraguans, and Venezuelans (CHNV) insofar as they subject individuals who have previously been granted parole at ports of entry to expedited removal." Coalition for Humane Immigrant Rights v. Noem, No. 1:25-cv-00872 (D.D.C.).

**see litigation note above**