Original Date Announced

ORR modified section 2.2.4 of the Unaccompanied Alien Children Bureau Policy Guide, changing guidance related to documents submitted as part of sponsors' applications. Specifically, the changes:

• Narrowed the acceptable forms of sponsor ID, removing many previously accepted documents, including birth certificates, foreign national ID cards, foreign driver’s licenses, consular IDs, and certain border-crossing documents.
• Reduced the acceptable types of address documentation and shortened the timeframe from which the documents may be dated in some cases from 60 days to 30 days.
• Strengthened language providing that ORR could deny release when fraudulent documents were submitted, regardless of sponsor category, with case-by-case exceptions supported by clear justification.

Trump 2.0 [ID #2371]

Subsequent Trump and Court Action

2025.04.15 Unaccompanied Alien Children Bureau Policy Guide Update - Income Verification

ORR made additional changes to section 2.2.4, noting that proof of sponsor income was a mandatory part of the application and providing a list of three acceptable documents to verify sponsors' income. Prior to that change, the policy manual made no mention of an income verification requirement for sponsors.

Subsequent Trump and Court Action

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 changes to ORR's sponsor requirements, including the March 2025 and April 2025 changes to section 2.2.4 of the Policy Guide. The complaint alleges that ORR's policy changes exceed its statutory authority and violate the APA. 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." Angelica S. v. HHS, No. 25-cv-1405 (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

2025.06.09 Order and Opinion Granting Class Certification and Preliminary Injunction - Angelica v. HHS

District Judge Dabney L. Friedrich granted plaintiffs' motions for class certification and granted in part plaintiffs' motion for a preliminary injunction. The court provisionally certified a class of unaccompanied children who were in the custody of HHS on or before April 22, 2025, who have or had a potential sponsor whose "family reunification application has been denied, closed, withdrawn, delayed, or cannot be completed because the sponsor is missing documents newly required on or after March 7, 2025." The court then granted a preliminary injunction enjoining the government from enforcing new sponsorship requirements on the basis that HHS acted arbitrarily and capriciously in failing to explain its new policy and failing to account for plaintiffs' reliance interests in the prior policy. Angelica S. v. HHS, No. 25-cv-1405 (D.D.C.).

*see litigation note above*

Subsequent Trump and Court Action

2026.06.26 ORR - Unaccompanied Children Program Foundational Rule; Sponsor Assessment Update To Include Proof of Identity, Background Check, Placement, and Income Verification Standards

ORR issued a notice of proposed rulemaking to establish additional requirements for evaluating potential sponsors before releasing unaccompanied children from federal custody, including proof of identity, proof of income, and background checks for sponsors and all adult household members. The NPRM's requirements for sponsors' income and identity verification largely codify the earlier changes to Section 2.2.4 of the policy manual described above that were preliminarily enjoined.

The rule would also authorize ORR to examine unaccompanied minors in its custody for visible gang- or criminal-organization-related tattoos, markings, or brandings as part of assessments of whether a child may pose a danger to themselves or others or be vulnerable to trafficking. ORR describes the gang-related markings screening as a "requirement[]" of Pub. L. No. 119-21, the One Big Beautiful Bill Act (OBBBA), H.R. 1. This component of the rule is discussed further in this entry.

ORR claims that the proposals are intended to address fraud, exploitation, trafficking, and other risks identified in the release process. Comments are due on August 25, 2026.

Subsequent Trump and Court Action

2026.07.23 Unaccompanied Alien Children Bureau Policy Guide Section 2.2.4 Update - Income Verification

ORR made additional changes to section 2.2.4, increasing the number and type of documents that could be used to prove sponsors' income. Under the April 15, 2025, version of the program guide described above, ORR considered only three forms of documentation regarding proof of income.