Original Date Announced

The Trump administration has repeatedly obstructed, and in several instances refused to comply, with court orders requiring the administration to facilitate the return of individuals that courts have held were wrongfully deported. In the case of Kilmar Abrego Garcia, the Supreme Court ruled in April 2025 that a lower court properly ordered the administration to "facilitate" his release from custody in El Salvador and return to the United States. The federal government initially refused to do so, and subsequently returned him to the United States for the purposes of indicting him on charges of alleged human smuggling. In several cases since then, the administration has either outright refused court orders to facilitate the return of individuals wrongfully deported or pointed to often self-imposed obstacles to delay implementation of such court orders, in several instances rendering the relief moot.

Trump 2.0 [ID #2240]

Subsequent Trump and Court Action

2025.06.07 Reported: Kilmar Abrego Garcia returned to the US, charged with transporting people in the country illegally - AP News

The Associated Press reported that Abrego Garcia was returned to the U.S. to face criminal charges related to what the Trump administration said was a large human smuggling operation that brought immigrants into the country illegally. Abrego Garcia's attorneys call the case "baseless."

**For further updates on Kilmar Abrego Garcia's case, see here.**

Subsequent Trump and Court Action

2025.07.01 Reported: US Tells Court It Can’t Locate Man Wrongly Sent to El Salvador - Bloomberg

The Trump administration informed the Second Circuit that it cannot locate Melgar-Salmeron, who was wrongly deported to El Salvador on May 7, 2025. A DOJ attorney stated that Melgar-Salmeron’s whereabouts and custodial status are currently unknown, though efforts to locate him are ongoing through diplomatic channels. Melgar-Salmeron v. Bondi, No. 23-7792 (2d Cir.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.09.08 Order - Melgar-Salmeron v. Bondi

The Second Circuit ordered the government to meet and confer with Melgar-Salmeron's counsel to "discuss further steps that can be take to facilitate communications between Petitioner and his counsel" and to file a declaration "indicating what additional steps have been taken to facilitate communications between Petitioner and his counsel." The court also ordered the government to "seek documentation corroborating" its allegations that Melgar-Salmeron was in custody in El Salvador awaiting trial for criminal charges as a reason not to facilitate communication and his return to the United States. Melgar-Salmeron v. Bondi, 23-7792 (2d Cir.)

**Link to case here. See litigation note above.**

Subsequent Trump and Court Action

2025.11.20 Memorandum Opinion - J.O.P. v. Dep't of Homeland Security

U.S. District Court Judge Stephanie Gallagher denied the government's motion to vacate the court's order to "facilitate" a class member's ("Cristian's") return to the U.S. pending adjudication of his asylum application. Cristian is a noncitizen removed to CECOT in El Salvador under the Alien Enemies Act. He was subsequently transferred to Venezuela in a prisoner swap. The court found that the equities weighed against granting the government relief, finding Cristian's "current whereabouts are unknown," and that while "[i]t is possible, at this point, that Cristian has decided to forego a return to the United States . . . . [i]t is equally possible that Cristian has been a victim of the anticipated violence that caused him to seek asylum . . . in the first place."

Judge Gallagher also denied Plaintiffs' motion to find probable cause of criminal contempt for failing to facilitate Cristian's return, finding that "[w]hile this Court shares Class Counsel's frustration with what appears to be lack of good faith government efforts at compliance with this Court's order," named Defendants did not include the State Department that could directly effectuate Cristian's return. Judge Gallagher also declined to impose contempt for Defendants' "often woefully deficient" status reports that were "willful[ly]" late. J.O.P. v. U.S. Department of Homeland Security, 8:19-cv-01944 (D. Md.)

**Link to case here. See litigation note above. For further updates on this litigation, see this entry.**

Subsequent Trump and Court Action

2026.02.12 Memorandum Opinion and Order - J.G.G. v. Trump

Judge Boasberg issued an order requiring the government to "facilitate the return" of Venezuelan nationals who were deported to El Salvador (CECOT) under the Alien Enemies Act and were subsequently repatriated to Venezuela, regardless of whether they are now in Venezuela or a third country. Judge Boasberg noted that "[t]he Court offered the Government the opportunity to propose steps that would facilitate hearings for the class members on their habeas corpus claims," but "[a]pparently not interested in participating in this process, the Government's responses essentially told the Court to pound sand."

Specifically, the order requires the government to provide a "boarding letter" allowing for commercial air travel, along with payment covering the cost of the air travel, to any of the Plaintiffs in the certified class who request to travel back into the United States, and to parole any Plaintiff who appears at a Port of Entry into U.S. custody. Finally, the order states that Plaintiffs must be given the opportunity to file supplemental habeas petitions from abroad. J.G.G v. Trump, No. 1:25-cv-00766 (D.D.C.).

**Link to case here. See litigation note above. For full details regarding this litigation and the Trump administration's invocation of the Alien Enemies Act, see this entry.**

Subsequent Trump and Court Action

2026.02.13 Order on Civil Contempt - Lopez Belloza v. Hyde

Judge Richards Stearns ordered the government to facilitate the return of Any Lucia Lopez Belloza, a 20-year-old Babson College student deported to Honduras in November 2025. Judge Stearns, "to avoid finding Respondents in civil contempt," had previously "suggested that the Secretary of State . . . consider providing Any with an expedited student visa to pursue her studies at Babson College while the validity of her removal order was litigated in the proper fora." Noting that "the Secretary of State has, regrettably, declined the invitation, requiring further intervention from this court," Judge Stearns found the government in contempt and ordered the government to facilitate Lopez Belloza's return within 14 days. Lopez Belloza v. Hyde, 1:25-cv-13499 (D. Mass.).

**Link to case here. See litigation note above.**

Subsequent Trump and Court Action

2026.03.06 Minute Order - Lopez Belloza v. Hyde

In a minute order available on the court docket, Judge Richard Stearns dismissed Any Lucia Lopez Belloza's case challenging her removal from the United States, holding that when she declined return to the United States out of fear that the government would re-detain and deport her, "[t]he sad truth is that when Any declined the flight she also waived this court's only remaining basis for jurisdiction. Any civil contempt dissolved when the government complied with the facilitation order." Lopez Belloza v. Hyde, 1:25-cv-13499 (D. Mass.).

**Link to case here. See litigation note above.**

Subsequent Trump and Court Action

2025.06.24 Order to return Petitioner - Melgar-Salmeron v. Bondi

The Second Circuit ordered the government to facilitate the return of Jordin Alexander Melgar-Salmeron, who was removed to El Salvador on May 7, 2025, thirty minutes after the court granted him a stay of removal. The Second Circuit directed the government to return Melgar-Salmeron as soon as possible to "ensure that his case is handled as it would have been had he not been improperly sent to El Salvador," citing the Supreme Court's decision in Noem v. Abrego Garcia. Melgar-Salmeron v. Bondi, No. 23-7792 (2d Cir.).

**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. For subsequent developments regarding the invocation of the Alien Enemies Act and Judge Boasberg's contempt proceeding, see this entry.**