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Make the Road New York v. Noem

No. 1:25-cv-04455 District · Active Active
Court
D.D.C.
dcd
Judge
Jia M. Cobb 46
Filed
Dec 19, 2025
Judge (CL)
Jia M. Cobb 46
Filed (CL)
Dec 19, 2025
CL Status
active

Case Overview

Make the Road New York sued the Trump administration over its guidance to DHS immigration officers to expand expedited removal.


The Application

History

Make the Road New York contends the guidance impermissibly broadens expedited removal beyond Congress's statutory authorization and denies procedural due process to affected immigrants. The government argues the guidance is consistent with existing law and lawful prosecutorial discretion.

The Conclusion

The case is pending before Judge Jia M. Cobb in D.C. District Court with no final ruling on the merits. The court will determine the lawfulness of the expanded expedited removal policy.

Federal Court TMR-92a566db Expedited Removal Policy May 18, 2026

Case Analysis

Overview

The ACLU filed a lawsuit against the Trump administration on behalf of Make the Road, an immigrant advocacy organization. The suit seeks to enjoin DHS's new rule on expedited removal and cites violations of the Fifth Amendment’s due process clause, the Immigration and Nationality Act, and the Administrative Procedure Act.

Overview

Make the Road New York sued the Trump administration over its guidance to DHS immigration officers to expand expedited removal.

Issue

Whether DHS's Expedited Removal Policy violates the Fifth Amendment's Due Process Clause, the Immigration and Nationality Act, and the Administrative Procedure Act by failing to provide adequate procedural safeguards and statutory authority for expanded expedited removal authority.

Rule

The Fifth Amendment Due Process Clause requires procedurally fair processes before deprivation of liberty; the INA prescribes specific statutory procedures and limitations for expedited removal; and the APA mandates notice-and-comment rulemaking for legislative rules.

Analysis

Make the Road challenges the expedited removal policy as unconstitutionally depriving immigrants of due process without adequate opportunity to contest removal, as exceeding DHS's statutory authority under the INA, and as adopted without compliance with APA notice-and-comment procedures.

Conclusion

The case remains active in the D.C. District Court before Judge Jia M. Cobb, with Make the Road seeking declaratory and injunctive relief to prevent enforcement of the expedited removal policy pending resolution of the constitutional, statutory, and administrative claims.

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