Immigration Task Force: Litigation Roundup
Client Alert | May 30, 2025
Gibson Dunn’s Immigration Task Force is available to help clients understand what these and other expected policy changes will mean for them and how to comply with new requirements.
In response to the federal government’s new rules and guidance impacting the immigration system, several legal challenges have been filed against the Trump Administration. This update outlines the background and status of certain notable lawsuits: (1) challenges to the invocation of the Alien Enemies Act to remove Venezuelan nationals allegedly connected to the gang Tren de Aragua; (2) a challenge to the removal of Kilmar Armando Abrego Garcia, a Salvadoran national who was lawfully present in the United States; (3) a challenge to the termination of the Temporary Protected Status designation for Venezuelans; (4) challenges to the termination of birthright citizenship; (5) a challenge to the termination of categorial parole programs, including for Cubans, Haitians, Nicaraguans, and Venezuelans; (6) a challenge to the Department of Homeland Security rule requiring registration of certain noncitizens; (7) challenges to the revocation of certain student visas; and (8) challenges to the termination of funding for congressionally appropriated programs benefiting immigrants.
- Challenges to Removal of Venezuelan Nationals Under the Alien Enemies Act
Underlying Executive Order
On March 14, 2025, President Trump issued an Executive Order invoking the Alien Enemies Act of 1798 (AEA) to require the “immediate apprehension, detention, and removal” of Venezuelan nationals age 14 and older who are members of the Venezuelan gang, Tren de Aragua.[1] The Executive Order, titled “Invocation of the Alien Enemies Act Regarding the Invasion of the United States by Tren De Aragua,” states that Tren de Aragua has invaded the United States, “perpetrated irregular warfare,” and used drug trafficking as a weapon against U.S. citizens.[2]
The AEA, enacted in 1798, authorizes the President to “apprehend[], restrain[], secure[], and remove[]” any “alien enemies” only during a declared war or invasion against the United States.[3] The AEA requires that noncitizens are provided a right of voluntary departure and must be given “reasonable time” to depart “according to the dictates of humanity and national hospitality.”[4] The AEA has been invoked only three times since its enactment, during the War of 1812, World War I and World War II.[5] During World War II, the AEA was infamously invoked in the creation of the internment camps for noncitizens from Japan, Germany, Italy, Hungary, Romania and Bulgaria.[6] Until now, the AEA has not been invoked outside of a declared war.[7]
The government began removing Venezuelan nationals promptly following the publication of the Executive Order, resulting in various legal challenges. The first lawsuit, J.G.G v. Trump, successfully obtained a nationwide injunction protecting removal for any individual subject to the Executive Order. As detailed below, however, the Supreme Court overruled that decision on procedural grounds, and plaintiffs seeking to prevent their removal under the Executive Order have since been obligated to file habeas corpus proceedings in the jurisdictions in which they are detained.[8] As of today’s date, there are at least nine separate habeas petitions pending in various federal districts.
The Initial Case: J.G.G. v. Trump
On March 15, 2025, the American Civil Liberties Union (ACLU), Democracy Forward, and the ACLU of the District of Columbia filed suit in the District of Columbia District Court seeking a temporary restraining order (TRO) against the Executive Order’s enforcement.[9] The suit was brought on behalf of five detainees who had been informed the day before that they were going to be deported, as well as a potential class consisting of “all noncitizens in U.S. custody subject to the[Executive Order].” On the day the suit was filed, at 5:00 p.m., Judge James Boasberg held a hearing to consider the plaintiffs’ motions for class certification and a TRO. When asked whether there were any imminent removals planned, the government represented that they did not know and would “investigate.”[10] When plaintiffs’ counsel interjected that two removal flights were scheduled to depart during the time of the hearing, Judge Boasberg adjourned the hearing at 5:22 p.m. to allow the government to confirm whether any flights were scheduled to depart.[11] The hearing resumed at 6:00 p.m., but the government continued to represent that they had no information to share.[12] Around 6:45 p.m., Judge Boasberg verbally entered a nationwide TRO order to prevent the removal of the any members of the putative class for 14 days, concluding that (1) the AEA does not provide a basis for removal under the Executive Order, (2) “a brief delay in [the plaintiffs’] removal does not cause the government harm,” and (3) the plaintiffs face irreparable harm since they will be deported to “prisons in other countries or even back to Venezuela where they face persecution or worse.”[13] During the hearing, Judge Boasberg also ordered the government to “immediately” comply with the TRO and demanded that the government halt all planes or return planes that had already taken off.[14] At 7:25 p.m., Judge Boasberg published a written order memorializing the TRO.[15]
It was later confirmed that three removal flights departed from Harlingen, Texas during that hearing, around 5:25 p.m., 5:45 p.m., and 7:36 p.m.[16] All three planes were still in the air when the TRO was published, and all three planes arrived in El Salvador the following day. Later that day, Secretary of State Marco Rubio shared a video originally posted by El Salvador’s President Nayib Bukele recording the passengers being led off the plane in handcuffs and taken into a prison.[17] On March 17, 2025, the White House reported that 137 people had been removed from the United States under the AEA, although that figure may now be higher.[18]
The government appealed the district court’s decision, and sought a stay of the TRO.[19] The United States Court of Appeals for the District of Columbia Circuit denied the government’s request,[20] and the government appealed that decision to the U.S. Supreme Court.[21] On April 7, 2025, the Supreme Court published an unsigned order vacating the TRO for improper venue but holding that the government cannot deport individuals without the “notice and opportunity” to challenge their removal in federal court.[22] Specifically, the Court noted that “the Fifth Amendment entitles [noncitizens] to due process of law in the context of removal proceedings,” and that detainees must receive notice that they are subject to removal “within a reasonable time and in such a manner as will allow them to actually seek habeas relief” before the removal.[23] While the Court did not discuss the validity of the Executive Order, it noted that challenges to removal under the AEA must be brought in habeas corpus proceedings in the jurisdiction where the individual is confined.[24] As the plaintiffs in J.G.G. were detained in New York and Texas, the Court found that they had improperly filed in Washington, D.C.[25]
Contempt of Court – J.G.G. v. Trump:
On March 17, 2025, Judge Boasberg held a hearing to investigate whether the Trump Administration was in contempt of the TRO.[26] During the hearing, the government refused to answer any questions, invoking “national security concerns” and arguing that the hearing was an “incursion[] on Executive Branch authority.”[27] Judge Boasberg directed the Department of Justice to certify that no noncitizens were removed after the written order (published at 7:25 p.m. on March 15, 2025), to confirm the exact time the Executive Order was signed, made public, and went into effect, and to provide an estimate of the number of individuals subject to the Executive Order that remain in custody. Weeks of what Judge Boasberg called “increasing obstructionism” followed as the government refused to substantively respond to the information requests.[28] On April 16, 2025, Judge Boasberg determined that the government’s actions “demonstrate a willful disregard” for the TRO, concluding that probable cause existed to find the government in criminal contempt.[29] Even though by that time the Supreme Court had vacated the TRO for a venue defect, Judge Boasberg concluded that “even a legally defective order must be complied with until reversed through the appeals process.”[30]
Habeas Corpus Proceedings: Spotlighting A.A.R.P. and W.M.M. v. Trump:
Following the Supreme Court’s ruling on jurisdiction and venue, several plaintiffs filed habeas petitions in nine federal districts: the Southern District of New York,[31] the District of Rhode Island,[32] the Middle District of Georgia,[33] the Southern District of Texas,[34] the District of Nevada,[35] the Western District of Pennsylvania,[36] the District of Colorado,[37] the District of Columbia,[38] and the Northern District of Texas.[39] One of these cases garnered national attention and eventually resulted in a U.S. Supreme Court decision. On April 16, the ACLU filed a habeas petition on behalf of two named plaintiffs, A.A.R.P. and W.M.M., in the Northern District of Texas, requesting a TRO and class certification for “all noncitizens in custody in the Northern District of Texas who were, are, or will be subject to the [Executive Order].”[40] The district court denied the TRO, stating that the individuals are “not facing such an imminent threat” of removal. That same day, the plaintiffs learned that the detention facility had distributed removal notices to the detainees with warnings that removals were “imminent and will happen tonight or tomorrow.”[41] On April 18, 2025, the plaintiffs filed emergency motions in the district court and Fifth Circuit Court of Appeals, and upon hearing no response, applied to the Supreme Court for an emergency injunction.[42]
Early the following morning, at 12:55 a.m. on April 19, 2025, the Supreme Court issued an unsigned, one-page order temporarily blocking the removal of the class of detainees until further order on the pending injunction motion.[43] Justice Alito (joined by Justice Thomas) published a dissent hours later, calling the Court’s order “unprecedented and legally questionable relief.”[44] The dissent took issue with the timing of the appeal, arguing that without a ruling from the lower courts, and without the opportunity for the government to have been heard, the order was inappropriate.
On May 16, 2025, the Supreme Court granted an injunction pending appeal for the two named plaintiffs and putative class members who “fac[e] an imminent threat of severe, irreparable harm.”[45] The Court first determined that it had jurisdiction—even though the district court had not yet ruled on the plaintiffs’ request for an injunction—because the court’s inaction in the face of evidence that individuals were imminently being removed “had the effect of refusing an injunction.”[46] On the merits, the Court restated its conclusions in J.G.G v. Trump that providing “notice roughly 24 hours before removal, devoid of information about how to exercise due process rights to contest that removal” was not “reasonable” and did not provide “sufficient time and information to reasonably be able to contact counsel, file a petition, and pursue appropriate relief.”[47] The Court did not discuss the underlying legality of the invocation of the AEA, nor did it determine what process would be reasonable to satisfy due process rights; it remanded both questions to the Fifth Circuit, where the matter remains pending.[48]
The Supreme Court’s injunction in A.A.R.P. only binds class members within the Fifth Circuit.[49] As prescribed by the Supreme Court’s May 16 opinion, each lower court is to determine what constitutes “reasonable” and “sufficient” notice ahead of removal.[50] Of the nine cases pending before the federal district courts, eight have granted temporary or preliminary injunctions against the Executive Order as of as of today’s date.[51] With several separate cases pending across nine districts, the legal protections and rights for Venezuelan nationals suspected of being Tren de Aragua members may vary drastically from state to state. The universal result of these pending cases is that the government is required to provide more notice to Venezuelan nationals before removal, but there may be no consistent approach across each district.
- Challenge to Removal of Kilmar Armando Abrego Garcia
Kilmar Armando Abrego Garcia is a citizen of El Salvador who had been living in the United States since 2011.[52] In 2019, after the Department of Homeland Security (DHS) initiated removal proceedings against him, an immigration judge granted Mr. Abrego Garcia withholding of removal status, which forbade DHS from removing him to El Salvador due to the threats he faced there from a local gang.[53] On March 12, 2025, however, DHS arrested Mr. Abrego Garcia and, within days, sent him (along with several Venezuelan nationals suspected of being Tren de Aragua members, discussed above) to a maximum security prison in El Salvador known as CECOT, based on his purported membership in the MS-13 gang.[54] Although the government has said in court documents that Mr. Abrego Garcia’s removal was an “administrative error,” it has claimed that Mr. Abrego Garcia’s return to the United States would pose a threat to the public.[55]
On March 24, 2025, Mr. Abrego Garcia, his wife, and his son filed a lawsuit in the United States District Court for the District of Maryland, challenging his removal and seeking an order requiring the government to take steps to return him to the United States. On April 4, 2025, Judge Paula Xinis issued an order finding that Mr. Abrego Garcia had been unlawfully removed to El Salvador in violation of the INA without any legal process and requiring the government to “facilitate and effectuate” his return to the United States.[56] The government asked the United States Court of Appeals for the Fourth Circuit to stay the district court’s decision pending appeal, and the Fourth Circuit denied the government’s motion, writing: “The United States Government has no legal authority to snatch a person who is lawfully present in the United States off the street and remove him from the country without due process.”[57] The government then applied to the United States Supreme Court for a stay, as well as vacatur of the district court’s injunction. After granting a short administrative stay,[58] on April 10, 2025, the Supreme Court voted 9-0 to leave in place the portion of the district court order requiring that the government “facilitate [Mr.] Abrego Garcia’s release from custody in El Salvador and to ensure that his case is handled as it would have been had he not been improperly sent to El Salvador.”[59] The Court ruled, however, that the district court should clarify the portion of its order requiring the government to “effectuate” Mr. Abrego Garcia’s return, as the intended scope of the term was “unclear, and may exceed the [district court’s] authority.”[60] The Court instructed the district court to “clarify its directive, with due regard for the deference owed to the Executive Branch in the conduct of foreign affairs,” while “the Government should be prepared to share what it can concerning the steps it has taken and the prospect of further steps.”[61]
On remand, the district court amended its order, directing the government to “take all available steps to facilitate the return of Mr. Abrego Garcia to the United States as soon as possible,” as well as file a declaration detailing “(1) the current physical location and custodial status of [Mr.] Abrego Garcia; (2) what steps, if any, Defendants have taken to facilitate [Mr.] Abrego Garcia’s immediate return to the United States; and (3) what additional steps Defendants will take, and when, to facilitate his return.”[62] The government asked the Fourth Circuit for another stay pending appeal, which the Fourth Circuit denied as “both extraordinary and premature.”[63] Writing for a unanimous panel, Judge J. Harvey Wilkinson explained:
It is difficult in some cases to get to the very heart of the matter. But in this case, it is not hard at all. The government is asserting a right to stash away residents of this country in foreign prisons without the semblance of due process that is the foundation of our constitutional order. Further, it claims in essence that because it has rid itself of custody that there is nothing that can be done. This should be shocking not only to judges, but to the intuitive sense of liberty that Americans far removed from courthouses still hold dear. . . . The Executive possesses enormous powers to prosecute and to deport, but with powers come restraints. If today the Executive claims the right to deport without due process and in disregard of court orders, what assurance will there be tomorrow that it will not deport American citizens and then disclaim responsibility to bring them home? And what assurance shall there be that the Executive will not train its broad discretionary powers upon its political enemies? The threat, even if not the actuality, would always be present, and the Executive’s obligation to “take Care that the Laws be faithfully executed” would lose its meaning.[64]
Judge Wilkinson rejected the government’s assertion that it only had to work on domestic bars to Mr. Abrego Garcia’s release, pointing to the “Supreme Court’s command that the government facilitate Abrego Garcia’s release from custody in El Salvador.”[65] “Facilitation,” Judge Wilkinson explained, “does not permit the admittedly erroneous deportation of an individual to the one country’s prisons that the withholding order forbids and, further, to do so in disregard of a court order that the government not so subtly spurns.”[66]
Discovery in the case is currently ongoing as the district court continues to attempt to assess what steps the government has taken and will take to comply with the court’s order. On April 22, 2025, the district court criticized the government for failing to satisfy its discovery obligations under the court’s expedited discovery plan.[67] The district court described the government’s objections to various discovery requests as “reflect[ing] a willful and bad faith refusal to comply with discovery obligations.”[68] On May 16, 2025, the district court again criticized the government for failing to comply with the court’s discovery orders.[69] These reprimands have been coupled with indications from the district court that it would entertain sanctions motions from Mr. Abrego Garcia’s lawyers,[70] as well as possibly holding the government in contempt.[71] Though neither sanctions nor contempt have yet been pursued, the district court continues to push the government to meet the expedited discovery deadlines in place. Mr. Abrego Garcia remains in El Salvador.
- Challenge to Termination of Temporary Protected Status for Venezuelans
Approximately 350,000 Venezuelans are currently present in the country under the 2023 Temporary Protected Status (TPS) designation for the country.[72] On January 17, 2025, just days before leaving office, President Biden extended the TPS designation through September 2026, allowing those individuals the ability to continue to legally live and work in the country until then. On January 28, 2025, approximately one week into the Trump Administration, DHS advised that they were “reviewing” the TPS designation; on February 5, 2025, they advised that the designation would end on April 7, 2025. This marked the first time in the thirty-five-year history of the TPS statute that an agency has vacated a country’s designation.
On February 19, 2025, the National TPS Alliance and several individual TPS holders filed suit against DHS, challenging the vacatur of the extension of TPS for Venezuela and the subsequent termination of the original extension, alleging violation of the Administrative Procedure Act (APA) and the Fifth Amendment’s Equal Protection Clause.[73] On March 31, 2025, Northern District of California Judge Edward M. Chen granted the plaintiffs’ motion to “postpone the effective date” of the decision to end TPS for Venezuela while the case proceeded through final judgment.[74] The government appealed that decision to the Court of Appeals for the Ninth Circuit, which, on April 18, 2025, denied the emergency motion to stay the district court’s order.[75] The government then requested emergency relief from the U.S. Supreme Court.
On May 19, 2025, the Supreme Court granted the requested emergency stay of the district court’s order to postpone the effective date of the TPS termination for Venezuela. In doing so, protection for those individuals pending the outcome of the underlying litigation has been terminated. The two-paragraph unsigned order has spurred confusion, however, about when and how the loss of lawful status and work authorization will occur, and the order may require further interpretation via lower courts. Further proceedings are ongoing in the district court.
- Challenges to Termination of Birthright Citizenship
On the first day of his second term, President Trump issued Executive Order 14160, “Protecting the Meaning and Value of American Citizenship,” declaring that an individual born in the United States is not a citizen if, at the time of their birth, (1) their mother is “unlawfully present” or (2) their mother’s presence is “lawful but temporary,” if in either circumstances their father is not a U.S. citizen or lawful permanent resident.[76] That Executive Order barred federal, state, and local governments from issuing documents purporting to recognize United States Citizenship for an individual in one of those categories, arguing they are not “subject to the jurisdiction” of the United States.[77] The Executive Order has been challenged in numerous jurisdictions on the ground that it violates the Fourteenth Amendment’s guarantee of citizenship to anyone born in the United States.
The Fourteenth Amendment, passed during the Reconstruction era following the end of the Civil War, grants citizenship to “[a]ll persons born or naturalized in the United States, and subject to the jurisdiction thereof.” In United States v. Wong Kim Ark, 169 U.S. 649, 693 (1898), the U.S. Supreme Court explained that the Amendment “affirms the ancient and fundamental rule of citizenship by birth within the territory, in the allegiance and under the protection of the country, including all children here born of resident aliens,” with limited exceptions for children of foreign ministers or of hostile occupiers.[78] The Fourteenth Amendment’s citizenship guarantee, the Court explained, “includes the children born within the territory of the United States of all other persons, of whatever race or color, domiciled within the United States.”[79] Since Wong Kim Ark, the Court has repeatedly reaffirmed this view of birthright citizenship. In U.S. ex rel. Hintopoulos v. Shaughnessy, 353 U.S. 72, 73 (1957), the Court recognized that a child born to two individuals present in the U.S. illegally was “an American citizen.” In I.N.S. v. Errico, 385 U.S. 214, 215 (1966), the Court explained that a child born to two individuals who acquired lawful immigration status by fraud still “acquired United States citizenship by birth.” And in I.N.S. v. Rios-Pineda, 471 U.S. 444, 446 (1985), the Court again recognized that a child born to two parents living in the U.S. illegally nonetheless “was a citizen of this country.”
Thus far, three district court judges have barred the federal government from enforcing the Executive Order: Judges John Coughenour of the Western District of Washington,[80] Deborah Boardman of the District of Maryland,[81] and Leo Sorokin of the District of Massachusetts[82] all ruled that the Executive Order violates the Fourteenth Amendment’s guarantee of birthright citizenship. The Ninth Circuit Court of Appeals,[83] Fourth Circuit Court of Appeals,[84] and First Circuit Court of Appeals,[85] respectively, have denied the government’s requests for stays of these district court orders.
On March 13, 2025, the government applied to the U.S. Supreme Court for a stay of the district courts’ injunctions. The orders framed the issue not as one of the Executive Branch’s authority to define citizenship within the boundaries of the Fourteenth Amendment, but instead as one of the district courts’ power to issue nationwide injunctions.[86] In the government’s view, the proper procedure would have been for the plaintiffs in each case to seek class certification and class-wide remedies. Absent the Court reforming nationwide injunction practice, the government argued, the Executive Branch “cannot properly perform its functions.” On April 17, 2025, the Court deferred a decision on the stay application pending oral argument,[87] which occurred on May 15, 2025.[88] The Court has not yet ruled on the stay application, meaning that the Executive Order is still currently on pause.
- Challenge to Terminations of the Certain Humanitarian Parole Program
On January 20, 2025, President Trump issued an executive order, titled Securing Our Borders, that directed the Secretary of Homeland Security to “[t]erminate all categorical parole programs that are contrary to the policies of the United States established in [President Trump’s] Executive Orders,” including a Biden-era humanitarian parole program for Cubans, Haitians, Nicaraguans, and Venezuelans known as the CHNV program.[89] In accordance with the Executive Order, on March 25, 2025, DHS published a Federal Register Notice announcing the immediate termination of the CHNV program.[90] The Notice also announced the termination of all paroles under the program effective April 24, 2025 (unless the DHS Secretary makes an individual determination to the contrary), and further directed that parolees without a lawful basis to remain in the United States following the termination of the CHNV program must depart the United States before their parole termination date.
On February 28, 2025, parole beneficiaries and a members alliance filed a putative class action in the District of Massachusetts challenging the end of the CHNV program and other humanitarian parole programs, including Central American Minors Parole, Family Reunification Parole, Military Parole-in-Place, Uniting for Ukraine, and Operation Allies Welcome.[91] The plaintiffs alleged violations of the APA and Due Process violations associated with the parole program revocations, as well as DHS’s later representations that it had suspended processing of applications for other immigration benefit requests filed by certain parolees.
On April 15, 2025, Judge Indira Talwani issued an order staying the Notice insofar as it purported to revoke, without case-by-case review, previously granted parole and work authorizations issued to CHNV parolees prior to the originally stated parole end date.[92] The order further stayed all individualized notices sent to CHNV parolees via their USCIS online account notifying them that their parole was being revoked without case-by-case review. Among other things, Judge Talwani concluded that the plaintiffs were likely to succeed on their claim that the categorical termination of existing grants of parole was arbitrary and capricious. Judge Talwani further concluded that, absent preliminary relief, the plaintiffs would “be forced to choose between two injurious options: continue following the law and leave the country on their own, or await removal proceedings. . . . The first option will expose Plaintiffs to dangers in their native countries and will cause Plaintiffs to forfeit their APA claims. The second option will put Plaintiffs at risk of arrest and detention and, because Plaintiffs will be in the United States without legal status, undermine Plaintiffs’ chances of receiving other forms of immigration relief in the future—potentially permanently.”
The government appealed to the First Circuit Court of Appeals and asked for a stay pending appeal.[93] On May 5, 2025, the First Circuit Court of Appeals denied the government’s emergency motion for a stay.[94] On May 8, 2025, the government asked the U.S. Supreme Court to stay Judge Talwani’s order, and on May 30, 2025, the U.S. Supreme Court granted the stay in a one-paragraph order, with a lengthy dissent from Justice Jackson (joined by Justice Sotomayor).[95] Therefore, as of today’s date, the injunction pausing the mass revocation of CHNV parole has been reversed, and many CHNV parolees’ status has been terminated effective immediately.
Two days before the Supreme Court stayed the April 15 order on CHNV parole, on May 28, 2025, the district court issued its order on other forms of parole, staying the suspension of adjudication of re-parole applications and other immigration benefits for individuals lawfully present under categorical parole programs.[96] This order was not directly impacted by the May 30 Supreme Court order, so for the time being, it remains in effect.
- Challenge to Registration Requirements for Certain Noncitizens
On March 12, 2025, DHS announced an interim final rule, effective April 11, 2025, that—for the first time in decades—purports to enforce the registration requirements of the Immigration and Nationality Act (INA) against certain noncitizens. These requirements include submitting a newly available registration form online and undergoing biometrics screening.[97] Noncitizens who follow such registration requirements will be issued a certificate or receipt card that they must carry with them at all times.[98]
On March 31, 2025, four organizations—Coalition for Humane Immigrant Rights (a California-based nonprofit that provides services to immigrant communities), United Farmworkers of America (an organization that focuses on improving the lives of agricultural workers), CASA, Inc. (a nonprofit that works to improve the quality of life in working-class diverse and immigrant communities), and Make the Road New York (a nonprofit that works to improve the lives of low-income New Yorkers)—filed suit in the United States District Court for the District of Columbia and moved for a stay of the effective date of the rule (or, in the alternative, for a preliminary injunction) and to enjoin the government from implementing or enforcing the rule for the pendency of the litigation.[99] Among other things, the plaintiffs argued that the rule violated the APA for failing to follow its notice and comment procedures and for being arbitrary and capricious.[100]
On April 10, 2025, Judge Trevor N. McFadden denied the plaintiffs’ motion on the basis that they had “failed to show that they have a substantial likelihood of standing.”[101] Judge McFadden concluded that the plaintiff organizations’ harms were “too speculative,” and they failed to show that the rule would “erode their core missions.” As a result, on April 11, 2025, the rule went into effect, meaning that certain noncitizens, namely those who have not applied for a visa, submitted one of several specific forms for immigration relief, or been issued one of several types of identity, visa, entry, or lawful status documents,[102] are required to register.[103] Noncitizens who are required to register but willfully fail to do so (or to provide proof of registration when requested by law enforcement) could face civil and criminal penalties including a fine of up to $5,000 or imprisonment for up to six months, or both.[104] On April 24, 2025, the plaintiffs appealed the district court’s decision to the District of Columbia Circuit Court[105] and moved the District Court for an injunction pending appeal.[106] Both the appeal and the motion are currently pending, meaning the registration requirement remains in effect as of today.
- Challenges to Revocation of Certain Student Visas
Foreign Student Visas and the Student Exchange Visitor System (SEVIS)
Foreign students can study in the United States by applying for one of three types of visas. An F-1 visa is the most used, allowing students to attend an academic institution like a university; an M-1 visa allows students to join a vocational program; and a J-1 visa allows students to enter into an “exchange” program with a cultural component. Immigration and Customs Enforcement (ICE), as well as other agencies, use the Student and Exchange Visitor Program (SEVP) to monitor student status and compliance with their visas via the Student Exchange Visitor Information System (SEVIS).
The State Department may revoke visas for a number of reasons, ranging from violations of their status, criminal offenses, failure to register change of address, falsification of documents, engagement in any activity related to espionage, endangerment of public safety or national security, participation in an activity related to the opposition to or overthrow of the U.S. Government, or where their presence has potential adverse foreign policy consequences for the U.S. Government.[107] The State Department has clarified that a visa may be revoked even without a formal criminal charge, and all that is required is “derogatory information directly from another U.S. Government agency, including a member of the intelligence or law enforcement community.”[108] If a student violates a term of their student visa, they are ineligible to return to the United States for five years after the date of their violation.[109]
Beginning in March 2025, thousands of international students and recent graduates were advised that their SEVIS records had been terminated, that their underlying visas had been revoked, or both. DHS officials have stated that this was done as part of a “Student Criminal Alien Initiative” targeting students who had had any form of interaction with some form of law enforcement, whether or not it resulted in a criminal conviction that qualified for visa revocation under the law (or any criminal conviction at all).[110]
Doe v. Trump[111]
Following the Student Criminal Alien Initiative, at least 65 lawsuits were filed on behalf of at least 300 students whose SEVIS records and/or visas were terminated. One such group of consolidated cases, titled Doe v. Trump under the lead case, was filed by a group of student-plaintiffs in the Northern District of California on April 7, 2025, alleging that their SEVIS records and/or student visas were terminated in violation of the APA and requesting a TRO.[112] On April 25, 2025, the court held a hearing on the TRO requests and granted (or extended) them in each of the consolidated cases. On May 14, 2025, the court held a hearing on motions for preliminary injunctions, during which counsel for ICE advised that they would be restoring SEVIS records retroactively and contacting every individual impacted by mass terminations.
On May 22, 2025, Judge Jeffrey S. White issued a nationwide preliminary injunction prohibiting the arrest, incarceration, or “impositi[on of] any adverse legal effect” on individuals similarly situated to the plaintiffs pending the final resolution of the matter.[113] In his order, Judge White noted that the plaintiffs were likely to succeed on their APA claim that the “decision to terminate their SEVIS records was arbitrary and capricious because the decision was not based on a rational connection between the facts found and the choice made,” and that the “overwhelming majority of courts considering these cases have determined the plaintiffs are likely to succeed on the merits of the same claims presented here.”[114] Currently, therefore, international students whose SEVIS records were terminated or visas revoked via the mass Student Criminal Alien Initiative should have those terminations reversed and visas reinstated, permitting their continued lawful presence in the country for the pendency of their studies.
- Challenges to Executive Actions Withholding Funding for Immigration-Related Services
The Trump Administration has suspended or entirely terminated funding for various grants and programming, including programs that assist noncitizens navigating the immigration legal system. Gibson Dunn is counsel in three of these cases, summarized below.
Amica Center for Immigrant Rights, et al. v. U.S. Department of Justice[115]
For more than two decades, Congress has appropriated funding for the Department of Justice specifically to spend on providing basic legal orientation programs (including a flagship Legal Orientation Program, or “LOP”) to educate noncitizens about legal rights and responsibilities in immigration detention facilities and immigration courts. These programs are often the only source of reliable legal information for many noncitizens, and the lawyers that run these programs are often the only non-government lawyers regularly inside immigration detention facilities. In January 2025, the Trump Administration issued a “stop work order” for these programs. On January 31, 2025, represented by Gibson Dunn, non-profit legal service providers that run these programs with government funding filed suit in the U.S. District Court for the District of Columbia to prevent the government from eliminating the programs. The suit brings claims under the APA and constitutional claims. Just days after the legal service providers filed their complaint, the government rescinded its stop work order. But on April 16, 2025, the government again stopped all funding for the legal orientation programs. The legal service providers moved for summary judgment, and Judge Randolph Moss ordered the government to supplement the administrative record in response to the government’s contention that it was going to “federalize” the programs. The programs are not currently being funded while the case is ongoing.
United States Conference of Catholic Bishops v. U.S. Department of State[116]
The United States has provided resettlement assistance for newly admitted refugees since 1980 under the Refugee Act and a series of appropriations bills. But on January 24, 2025, citing two Executive Orders, the State Department ended its relationships with private resettlement agencies and suspended resettlement assistance for refugees already in the country. The United States Conference of Catholic Bishops (USCCB) is one of the affected resettlement partners, and has long been providing services to refugees in the United States. The initial-resettlement services mandated by the Refugee Act for refugees in their first 90 days include food, housing, job training, English education, and other services aimed at successful integration into the United States and material support during the transition. At the time of the suspension, USCCB had nearly 7,000 refugees in their initial-resettlement period in its care, all assigned to the Conference by the federal government. On February 26, and after USCCB (represented by Gibson Dunn) filed suit, the State Department terminated its cooperative agreements with the USCCB, stating that the agreements “no longer effectuate[] agency priorities.” USCCB and its partner organizations were forced to rely on their own resources to serve the refugees in their care, lay off staff, and cut back on services provided. In its lawsuit in the U.S. District Court for the District of Columbia, USCCB brings claims under the Constitution, the Refugee Act, the Impoundment Control Act, the APA, and State Department regulations. USCCB is asking the Court to set aside the suspension and termination of its relationship with the United States and enter an injunction requiring the United States to provide the assistance mandated by Congress for newly admitted refugees.
Community Legal Services in East Palo Alto, et al. v. U.S. Department of Health & Human Services[117]
For more than a decade, the Department of Health & Human Services (HHS) has paid legal service providers to provide legal representation to unaccompanied children—children who arrive in the United States without a parent or legal guardian, and who may be as young as just a few months old. HHS provided this funding to comply with a command from Congress in the William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, which orders HHS to fund legal representation for unaccompanied children to the extent it has funding available to do so. In March 2025, HHS cut all funding for this representation. Represented by Gibson Dunn, non-profit legal service providers quickly filed suit and sought a TRO. Judge Araceli Martinez-Olguin of the U.S. District Court for the Northern District of California issued a TRO commanding the government to continue funding legal representations for unaccompanied children. The government appealed the TRO and the Ninth Circuit dismissed the appeal. Judge Martinez-Olguin then issued a preliminary injunction, commanding the government to continue funding the legal representations through the resolution of the case. The government has appealed that order, and the appeal is pending in the Ninth Circuit. The Ninth Circuit has rejected the government’s request to stay the preliminary injunction pending the appeal, meaning that the preliminary injunction requiring HHS’s compliance with Congress’s mandate to fund representation for unaccompanied children remains in effect.
[1] “Invocation of the Alien Enemies Act Regarding the Invasion of The United States by Tren De Aragua,” The White House (Mar. 15, 2025), https://www.whitehouse.gov/presidential-actions/2025/03/invocation-of-the-alien-enemies-act-regarding-the-invasion-of-the-united-states-by-tren-de-aragua/. While the Executive Order was issued and signed on March 14, 2025, it was not published online until March 15, 2025.
[2] Id.
[3] 50 U.S.C. § 21.
[4] Id. §§ 21, 22.
[5] Jennifer Elsea, Cong. Rsch. Serv., LSB 11269, The Alien Enemy Act: History and Potential Use to Remove Members of International Criminal Cartels 3 (Apr. 2, 2025).
[6] Id. See also Amended Class Action Petition for Writ of Habeas Corpus and Complaint, J.G.G. v. Trump, No. 1:25CV00766, 2025 WL 1270187 (D.D.C. Apr. 24, 2025).
[7] Elsea, supra note 5.
[8] Trump v. J.G.G., 145 S.Ct. 1003 (2025).
[9] Complaint and Petition for Writ of Habeas Corpus, J.G.G. v. Trump, 2025 WL 836447 (D.D.C. Mar. 15, 2025).
[10] Transcript of Proceedings before Chief Judge James E. Boasberg at 11, J.G.G. v. Trump, No. 1:25CV00766, (D.D.C. Mar. 15, 2025).
[11] Id. at 15.
[12] Id.
[13] Id. at 41–43.
[14] Id. at 43.
[15] Minute Order on Motion for Temporary Restraining Order, J.G.G. v. Trump, No. 1:25CV00766, 2025 WL 825116 (D.D.C. Mar. 15, 2025); see also Transcript of Proceedings before Chief Judge James E. Boasberg, J.G.G. v. Trump, No. 1:25CV00766, 2025 WL 829734 (D.D.C. Mar. 15, 2025).
[16]Luke Broadwater, et al., A Judge Ordered Deportation Planes to Turn Around. The White House Didn’t Listen, NYTimes (Apr. 8, 2025), available at https://www.nytimes.com/2025/03/17/us/politics/timeline-trump-deportation-flights-el-salvador.html.
[17] Id.
[18] US/El Salvador: Venezuelan Deportees Forcibly Disappeared, Human Rights Watch (Apr. 11, 2025), available at https://www.hrw.org/news/2025/04/11/us/el-salvador-venezuelan-deportees-forcibly-disappeared.
[19] Application to Vacate the Orders Issued by the United States District Court for the District of Columbia and Request for an Immediate Administrative Stay, J.G.G. v. Trump, No. 25-5067, 2025 WL 914682 (D.C. Cir. Mar. 26, 2025).
[20] Id.
[21] Application to Vacate the Orders Issued by the United States District Court for the District of Columbia and Request for an Immediate Administrative Stay, Trump v. J.G.G., No. 24A, 2025 WL 962719 (March 2025)
[22] Trump v. J.G.G., 145 S.Ct. 1003 (Apr. 7, 2025).
[23] Id. at 1006.
[24] Id.
[25] Id.
[26] Transcript of Proceedings before Chief Judge James E. Boasberg, J.G.G. v. Trump, No. 1:25CV00766, 2025 WL 829734 (D.D.C. Mar. 17, 2025).
[27] Id.
[28] Memorandum Opinion regarding Probable Cause Order, J.G.G. v. Trump, No. 1:25CV00766, 2025 WL 1119481 (D.D.C. Apr. 16, 2025).
[29] Id. at *7.
[30] Id.
[31] G.F.F. v. Trump, No. 25 Civ. 2886 (AKH), 2025 WL 1166911 (S.D.N.Y. Apr. 11, 2025).
[32] G.M.G. v. Trump, 1:25-CV-00195 (D.R.I. May 5, 2025).
[33] Y.A.P.A. v. Trump, 4:25-CV-00144 (M.D. Ga. Apr. 30, 2025).
[34] J.A.V. v. Trump, No. 1:25-CV-072, 2025 WL 1064009 (S.D. Tex. Apr. 9, 2025).
[35] Viloria Aviles v. Trump, 2:25CV00611 (D. Nev. Apr. 3, 2025).
[36] A.S.R. v. Trump, No. 3:25-cv-00113-SLH, 2025 WL 1122485 (W.D. Pa. Apr. 15, 2025).
[37] D.B.U. v. Trump, No. 1:25-cv-01163-CNS, 2025 WL 1106556 (D. Colo. Apr. 14, 2025).
[38] J.G.G. v. Trump, No. 1:25CV00766, 2025 WL 1352316 (D.D.C. Apr. 24, 2025).
[39] A.A.R.P. v. Trump, No. 1:25-cv-00059, 2025 WL 1148140 (N.D. Tex Apr. 27, 2025).
[40] Complaint – Class Action: Class Petition for Writ of Habeas Corpus and Complaint for Declaratory and Injunctive Relief, A.A.R.P. v. Trump, No. 1:25-cv-00059, E.C.F. No. 1 (N.D. Tex Apr. 16, 2025).
[41] Petitioners-Plaintiffs’ Renewed Emergency Application for Temporary Restraining Order, A.A.R.P. v. Trump, No. 1:25-cv-00059, E.C.F. No. 30 (N.D. Tex. Apr. 18, 2025).
[42] Emergency Application for an Emergency Injunction or Writ of Mandamus, Stay of Removal, and Request for an Immediate Administrative Injunction, A.A.R.P. v. Trump, No. 24A1007, 2025 WL 1171734 (S. Ct. Apr. 19, 2025).
[43] A.A.R.P. v. Trump, No. 24A1007, 145 S. Ct. 1034 (Mem) (S. Ct. Apr. 19, 2025).
[44] Id. at 1036 (Alito, J., dissenting).
[45] A.A.R.P. v. Trump, Nos. 24A1007, 24-1177, 2025 WL 1417281, at *2 (S. Ct. May 16, 2025).
[46] Id. at *3.
[47] Id. at *2.
[48] Id. at *4.
[49] Id.
[50] Id. at *2.
[51] One case is still pending in the District of Columbia District Court. See J.G.G. v. Trump, No. 1:25CV00766, 2025 WL 1349496 (D.D.C. May 8, 2025).
[52] See Abrego Garcia v. Noem, 2025 WL 1014261, at *2 (D. Md. Apr. 6, 2025).
[53] See id.
[54] Id. at *3.
[55] Application to Vacate the Injunction Issued by the United States District Court for the District of Maryland and Request for an Immediate Administrative Stay, Noem v. Abrego Garcia, No. 24A949, 2025 WL 1038907 (U.S. April 1, 2025).
[56] Abrego Garcia v. Noem, 2025 WL 1024654, at *1 (D. Md. Apr. 4, 2025), amended, 2025 WL 1085601 (D. Md. Apr. 10, 2025).
[57] See Abrego Garcia v. Noem, 2025 WL 1021113 (4th Cir. Apr. 7, 2025).
[58] Noem v. Abrego Garcia, 2025 WL 1022673 (U.S. Apr. 7, 2025), vacated, 2025 WL 1077101 (U.S. Apr. 10, 2025).
[59] Noem v. Abrego Garcia, 145 S.Ct. 1017, 1018 (2025) (internal quotation marks omitted).
[60] Id.
[61] Id.
[62] Abrego Garcia v. Noem, 2025 WL 1085601, at *1 (D. Md. Apr. 10, 2025).
[63] Abrego Garcia v. Noem, 2025 WL 1135112, at *1 (4th Cir. Apr. 17, 2025).
[64] Id. at *1-2.
[65] Id.
[66] Id. at 2.
[67] Devan Cole, ‘That ends now’: Judge overseeing Abrego Garcia case knocks Trump administration for repeated stonewalling, CNN (Apr. 22, 2025); available at https://www.cnn.com/2025/04/22/politics/abrego-garcia-judge-xinis-justice-that-ends-now.
[68] Abrego Garcia v. Noem, 2025 WL 1166402, at *1 (D. Md. Apr. 22, 2025).
[69] See Alan Feuer and Aishvarya Kavi, U.S. Takes Defiant Stance in Court, Saying Abrego Garcia Deportation Was Lawful, N.Y. Times (May 16, 2025); available at https://www.nytimes.com/2025/05/16/us/politics/doj-trump-deportation-abrego-garcia.html.
[70] Gary Grumbach and Dareh Gregorian, Judge in Abrego Garcia case indicates she’s weighing contempt proceedings against Trump administration, NBC News (Apr. 15, 2025), available at https://www.nbcnews.com/politics/immigration/judge-abrego-garcia-case-indicates-weighing-contempt-proceedings-trump-rcna201359.
[71]Sareen Habeshian, Judge in deportation case threatens Trump admin with contempt of court, Axios (Apr. 16, 2025), available at https://www.axios.com/2025/04/15/kilmar-abrego-garcia-deported-case-return.
[72] TPS is a program established by Congress to protect individuals who cannot safely return to their home country due to war, natural disaster, or another emergency. For further discussion of TPS, including the 2021 and 2023 designations for Venezuela, see Gibson Dunn’s Immigration Task Force Client Alert: Updates to Humanitarian Parole and Temporary Protected Status, dated February 24, 2025, available at https://www.gibsondunn.com/updates-to-humanitarian-parole-and-temporary-protected-status/.
[73] Complaint, National TPS Alliance v. Noem, 3:25-cv-01766, ECF No. 1 (N.D. Cal. Mar. 31, 2025).
[74] National TPS Alliance v. Noem, 3:25-cv-01766, ECF No. 93 (N.D. Cal. Mar. 31, 2025).
[75] National TPS Alliance, et al. v. Noem, et al., 25-2120, ECF No. 21 (9th Cir. Apr. 18, 2025).
[76] Exec. Order No. 14160, “Protecting the Meaning and Value of American Citizenship” (Jan. 20, 2025).
[77] Id. § 2(a); see also Gibson Dunn’s Immigration Task Force Client Alert, Jan. 27, 2025, available at https://www.gibsondunn.com/gibson-dunn-launches-immigration-task-force/.
[78] 168 U.S. 649, 693 (1898).
[79] Id.
[80] Washington v. Trump, 2025 WL 272198 (W.D. Wash. Jan. 23, 2025).
[81] CASA, Inc. v. Trump, 2025 WL 408636 (D. Md. Feb. 5, 2025).
[82] New Jersey v. Trump, 2025 WL 617583 (D. Mass. Feb. 26, 2025).
[83] Washington v. Trump, 2025 WL 553485 (9th Cir. Feb. 19, 2025).
[84] CASA, Inc. v. Trump, 2025 WL 654902 (4th Cir. Feb. 28, 2025).
[85] New Jersey v. Trump, 131 F.4th 27 (1st Cir. 2025).
[86] Application for a Partial Stay of the Injunction, Trump v. CASA, Inc., 2025 WL 817770 (U.S. Mar. 13, 2025).
[87] Trump v. CASA, Inc., 2025 WL 1132004 (U.S. Apr. 17, 2025).
[88] Transcript of Oral Argument, Trump v. CASA, Inc., 2025 WL 1424657 (U.S. May 15, 2025).
[89] Exec. Order No. 14165, 90 F.R. 8467, § 7(b) (Jan. 20, 2025), available at https://www.federalregister.gov/documents/2025/01/30/2025-02015/securing-our-borders.
[90] Department of Homeland Security, Termination of Parole Processes for Cubans, Haitians, Nicaraguans, and Venezuelans, 90 Fed. Reg. 13611 (Mar. 25, 2025), available at https://www.federalregister.gov/documents/2025/03/25/2025-05128/termination-of-parole-processes-for-cubans-haitians-nicaraguans-and-venezuelans (last visited May 30, 2025).
[91] Doe v. Noem, No. 1:25-cv-10495 (D. Mass.).
[92] Memorandum & Order Granting in Part Plaintiffs’ Emergency Motion for a Stay of DHS’sS En Masse Truncation of All Valid Grants of CHNV Parole, Doe v. Noem et al., No. 1:25-cv-10495-IT (D. Mass. Apr. 14, 2025), ECF No. 97.
[93] Doe v. Noem, et al., No. 1:25-cv-1384 (1st Cir. May 5, 2025).
[94] Id.
[95] Noem v. Doe, et al., 2025 WL 1534782 (S. Ct. May 30, 2025).
[96] Memorandum & Order Granting Partial Relief on Plaintiffs’ Motion for Preliminary Injunction and Stay of Administrative Action, Doe v. Noem et al., 2025 WL 1514420 (D. Mass. May 28, 2025).
[97] See Alien Registration Form and Evidence of Registration, 90 Fed. Reg. 11793 (Mar. 12, 2025).
[98] Id.
[99] See Compl., Coal. for Humane Immigrant Rts. v. U.S. Dep’t of Homeland Sec., No. 25 Civ. 943 (D.D.C. Mar. 31, 2025); Br. for Pls., Coal. for Humane Immigrant Rts. v. U.S. Dep’t of Homeland Sec., No. 25 Civ. 943 (D.D.C. Mar. 31, 2025).
[100] See Br. for Pls. at 10–28, Coal. for Humane Immigrant Rts. v. U.S. Dep’t of Homeland Sec., No. 25 Civ. 943 (D.D.C. Mar. 31, 2025).
[101] See Coal. for Humane Immigrant Rts. v. U.S. Dep’t of Homeland Sec., 2025 WL 1078776, at *1 (D.D.C. Apr. 10, 2025). On April 24, 2025, the plaintiffs filed their notice that they intended to appeal the District Court’s denial of their injunction motion. Notice of Appeal, Coal. for Humane Immigrant Rts. v. U.S. Dep’t of Homeland Sec., No. 25 Civ. 943 (D.D.C. Apr. 24, 2025).
[102] See Alien Registration Requirement, U.S. Citizenship and Immigr. Servs, available at https://www.uscis.gov/alienregistration (last visited May 30, 2025).
[103] Many noncitizens are considered to have already registered. See Gibson Dunn’s Immigration Task Force Client Alert: Agency Action Update, Mar. 21, 2025, available at https://www.gibsondunn.com/immigration-task-force-agency-action-update/.
[104] See Alien Registration Requirement, U.S. Citizenship and Immigr. Servs., available at https://www.uscis.gov/alienregistration (last visited May 30, 2025) (“It is the legal obligation of all unregistered aliens (or previously registered aliens who turn 14 years old) who are in the United States for 30 days or longer to comply with these requirements. Failure to comply may result in criminal and civil penalties, up to and including misdemeanor prosecution, the imposition of fines, and incarceration.”); Alien Registration Form and Evidence of Registration, 90 Fed. Reg. 11793, 11794 (Mar. 12, 2025) (“An alien’s willful failure or refusal to apply to register or to be fingerprinted is punishable by a fine of up to $5,000 or imprisonment for up to six months, or both.”).
[105] See Notice of Appeal from Denial of Preliminary Injunction, Coal. for Humane Immigrant Rts. v. U.S. Dep’t of Homeland Sec., No. 25 Civ. 943 (D.D.C. Apr. 24, 2025).
[106] See Pls.’ Mot. for Injunction Pending Appeal and Incorporated Mem. of Law, Coal. for Humane Immigrant Rts. v. U.S. Dep’t of Homeland Sec., No. 25 Civ. 943 (D.D.C. Apr. 24, 2025).
[107] 8 U.S.C. § 1127 (2025).
[108] Foreign Affs. Manual, U.S. Dep’t of State 9 FAM 403.11-5(B) (2024), available at https://fam.state.gov/fam/09FAM/09FAM040311.html#M403_11_5_B.
[109] 8 U.S.C. § 1182 (a)(6)(G) (2025).
[110] See, e.g., Vyas v. Noem, No. 3:25-cv-0261-RCC, 2025 WL 1351537, at *4 (S.D. W. Va. May 8, 2025).
[111] No. 4:25-cv-03140 (N.D. Cal.).
[112] Doe v. Trump was filed on behalf of a single student-plaintiff; the case was consolidated with various other cases brought on behalf of additional student-plaintiffs pending in the same district including S.Y. v. Noem, Chen v. Noem, Kim v. Noem, W.B. v. Noem, and Bai v. Noem.
[113] Ord. Granting Mots. Preliminary Injunction, No. 4:25-cv-03244-JSW, Doc. 50 at 20 (N.D. Cal. May 22, 2025).
[114] Id. at 19.
[115] No. 1:25-CV-00298 (D.D.C.).
[116] No. 1:25-cv-00465 (D.D.C.).
[117] No. 3:25-CV-02847 (N.D. Cal.).
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