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ORR changes document submission requirements for sponsors of unaccompanied children

  1. Original Date Announced

    The Office of Refugee Resettlement revised section 2.2.4 of Unaccompanied Children Bureau Policy Guide (now titled the "Unaccompanied Alien Children Bureau Policy Guide) to change the list of acceptable documents to prove sponsor identity for sponsors of unaccompanied children. The revised policy guidance limits the forms of identification that are accepted, partially restricting the ability of noncitizens to prove identity. The revised list no longer includes, for instance:

    • Foreign passports that lack a temporary I-551 stamp or temporary I-551 printed notation on a machine-readable immigrant visa or a Form I-94 or Form I-94A with Arrival-Departure Record, and containing an endorsement to work
    • Foreign national ID card
    • Mexican consular identification card
    • Foreign driver's license containing a photograph (with the exception of those issued by a Canadian government entity)
    • Mexican border crossing card that contains a photograph with a valid I-94
    • Marriage certificate

    Trump 2.0 [ID #1770]

    2025.03.07 ORR Unaccompanied Alien Children Bureau Policy Guide 2.2.4 Proof of Sponsor Identity
  2. Effective Date

    March 7, 2025
  3. Subsequent Trump and Court Action(s)

    • April 15, 2025

      2025.04.15 ORR Unaccompanied Alien Children Bureau Policy Guide 2.2.4 Proof of Income

      ORR adds proof of income requirements to the section of the Unaccompanied Alien Children Bureau Policy Guide regarding sponsor applications. Proof of income is now a prerequisite for sponsorship, and ORR will only accept a "[p]revious year’s tax return if in the United States during prior year," a "[c]opy of paystubs for at least the past 60 days continuously; or “[a]n original letter from the sponsor’s employer verifying their employment and salary information, signed within the past 60 days” which an ORR representative must confirm with a supervisor or Human Resources contact.

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    • May 8, 2025

      2025.05.08 Class Action Complaint - Angelica S. v. HHS

      Five children in immigration custody and the Immigrant Defenders Law Center filed a class action lawsuit for injunctive and declarative relief challenging the March 7 and April 15, 2025, changes to ORR's sponsor application requirements (as well as the March 24 IFR partially rescinding the Foundational Rule). Plaintiffs represent a putative class of all "unaccompanied children who are or will be in the custody of HHS and who have not been released to a sponsor because of ORR’s new documentation requirements," and challenge the Policy Guide changes as violating the TVPRA requirement to promptly place children “in the least restrictive setting that is in the best interest of the child" by "unnecessarily denying and delaying release."

      *Litigation entries are limited to initial complaints and major substantive rulings. For pleadings and additional information, use name and docket number to search Civil Rights Clearinghouse and CourtListener or visit Just Security Litigation Tracker

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