Template Opposition to DHS Motion to Dismiss to Pursue Expedited Removal

On January 21, 2025, the Trump administration expanded the scope of expedited removal to its statutory maximum, to include certain noncitizens not admitted or paroled who cannot prove they have been continuously present in the United States for at least two years. DHS, Designating Aliens for Expedited Removal, 90 Fed. Reg. 8139 (Jan. 24, 2025). Several days later, DHS issued a memo directing DHS attorneys to consider moving to terminate ongoing removal proceedings in order to pursue expedited re

National Immigration Project Template motion Feb 28, 2025 Direct PDF available

Why it matters

Useful as a drafting starting point for Removal Defense work in Immigration Judge; adapt the facts, authority, and venue-specific requirements before use.

Topics

Removal defense Detention / bond

Workflows

Immigration court deadline Motions, stays, and pretermission Bond, detention, and habeas BIA, PFR, and federal court Sample filings and templates

Forums

Immigration court BIA

Jurisdictions

National