A New Record: ICE Detainee Population Reaches Historic High of 66,000 — What’s Driving This, What Are the Costs, and What’s the End Game?

By Richard T. Herman

Quick Answer

The U.S. Immigration and Customs Enforcement (ICE) detainee population has hit an unprecedented 66,000 people—the highest in U.S. history. This surge reflects a deliberate shift toward mass detention under the Trump-Vance “Project 2025” agenda, expanded use of private prisons, and reduced parole and release options.

The economic cost exceeds $4 billion annually, while the human toll—from deaths in custody to family separations—continues to mount. Since the beginning of Trump’s second term, ICE has recorded around 380,000 deportations, including self-departures and repatriations by CBP. During the first 100 days of Trump’s second term, ICE arrested over 66,000 illegal aliens, most of whom had criminal records.

Behind the numbers lies a political goal: building a permanent deportation infrastructure and deterrent system for years to come.

Fast Facts / At-a-Glance

Category	Details / Source
ICE detainee population (2025)	≈ 66,000 daily (TRAC Reports)
Daily cost per detainee	≈ $150 – $165 (AILA)
Annual cost	≈ $3.6 – $4 billion (FY 2025 DHS budget)
Without criminal conviction	≈ 71 % (TRAC Syracuse Univ.)
Top nationalities detained	Mexico (31 %), Guatemala (17 %), Honduras (13 %), El Salvador (7 %), Venezuela (5 %) (USA Facts)
Private-facility share	> 90 % (Freedom for Immigrants)
Recorded deaths (2017-25)	130 +; 95 % preventable (ACLU)
Avg. deportation cost per person	≈ $17,000 (Herman Legal Group Analysis)

Why This Matters Now

• Scale & scope: 66,000 detainees—higher than any previous record, reflecting a nearly 70% increase since President Trump took office for a second time in January 2025.
• Interior arrests: Most arrests now occur inside the U.S., not at the border. ICE has carried out roughly 278,000 arrests since the start of Trump’s second term, averaging 965 arrests per day.
• Demographics: Over 70 % have no criminal record. The number of individuals detained without criminal records grew by 12,000% from January to June 2025, from around 800 to more than 11,700. The focus of immigration enforcement has expanded beyond serious criminals, leading to a rise in arrests of individuals without criminal records or only minor offenses.
• Fiscal weight: More than $10 million a day from taxpayer funds.
• Human cost: Thousands of families separated; U.S.-born children left without caregivers.

Richard T. Herman, Esq. notes:

“Mass detention is neither sustainable nor American in spirit—it’s political theater disguised as policy.”

Administrative Drivers of the Surge

• Expanded bed capacity: FY 2025 appropriations of $4.3 billion for 45,000 + beds (Vera Institute). ICE now has enough detention beds to hold as many as 70,000 detainees at any time, an increase from 41,500 at the beginning of the second Trump administration.
• Parole curtailment: Alternatives to Detention (ATD) cost ≈ $38/day (Immigration Justice Campaign) but are being phased out.
• Private prisons: Over 90 % of detainees in GEO Group, CoreCivic or county facilities.
• Mandatory detention rules: Strict use of INA §236(c) and §241(a)(6) limits release. Releases for individuals who entered the U.S. illegally have become less common, leading to longer detention periods.
• Local jail transfers: Traffic and minor charges feed ICE’s pipeline nationwide.
• Budget expansion: ICE’s budget for immigration enforcement is reported to be $170 billion, which supports expansion of detention capacity and officer hiring. Under Trump’s administration, ICE received $45 billion to expand its detention levels and facilities.

Political Backdrop — Project 2025 and Mass Detention

“We must detain and deport at unprecedented scale.” — J.D. Vance, 2024

Project 2025 (Heritage Foundation) calls for:

• Re-empowering ICE and reducing judicial oversight.
• Ending parole and humanitarian exemptions.
• Expanding state and private contracts for detention.

See Project 2025 immigration plan.

The record 66,000 detentions serve as a political benchmark of “control,” not an administrative necessity. Previously, ICE held a record high of approximately 56,000 detainees during Trump’s first term in 2019.

Historical Context & Benchmarks

Administration	Avg. Daily Population	Policy Context
Obama (2016)	≈ 34,000	Criminal focus & alternatives to detention
Trump 1.0 (2019)	≈ 55,000	“Zero Tolerance,” family separation
Biden (2023)	≈ 28,000	Pandemic releases, ATD expansion
Trump 2.0 (2025)	≈ 66,000	Mass detention, Project 2025 agenda

Economic Impact — The Hidden Costs

A. Direct Fiscal Burden

• $150–$165 per detainee per day = ≈ $10 million daily.
• ≈ $3.6–$4 billion annually excluding transport & medical.
• ICE Health Service Corps: ≈ $360 million in FY 2025 medical contracts.
• Deportation cost ≈ $17,000 per person; charter flights up to $800k (ICE Air Operations).

B. Private Profits

• GEO Group / CoreCivic = $2 billion + combined revenue in 2024.
• County jails paid ≈ $90–$120 per bed; rural counties depend on ICE contracts.

C. Opportunity Costs

• ATD programs ≈ 75 % cheaper and equally effective.
• 10,000 extra beds = $600 million in taxpayer expense per year.

D. State & Local Impact (Ohio Example)

Ohio jails such as Morrow, Seneca, Geauga, and Butler counties house hundreds of detainees under ICE contracts at $95–$125 per bed (Cleveland.com).

The $4 Billion Question — What Else Could America Do With That Money?

The U.S. spends over $4 billion a year to detain and deport mostly non-criminal immigrants (TRAC). These funds could instead transform American communities.

Program	What $4 Billion Could Fund	Source
Veteran Housing	≈ 40,000 affordable homes for veterans	HUD VASH
Homeless Services	Shelter & meals for ≈ 300,000 people	NAEH
Education	Tuition for 400,000 community-college students	College Board
Health Care	Medicaid for ≈ 500,000 low-income adults	KFF
Child Nutrition	Feed 1 million children year-round	USDA NSLP

• $10 million spent daily on detention = 25,000 veteran meals or 15,000 student grants each day.
• Detention budget ≈ entire cost of the U.S. Refugee Admissions Program.

Richard T. Herman:

“Every dollar spent to jail a farmworker or a mother with no record is a dollar taken from a homeless veteran or a hungry child. That is fiscal madness.”

Community-based alternatives cost one-fifth as much and maintain > 90 % compliance (Migration Policy Institute).

Social and Human Costs

• Family separation: Households lose breadwinners; children enter foster care.
• Deaths: 130 + deaths since 2017; 95 % preventable (ACLU).
• Births in custody: Pregnant women still detained (Time).
• Mental health: High rates of depression and suicide in isolation units.
• Community fear: Families withdraw from schools and public life.
• Basic needs: A federal judge ordered ICE to provide detainees with three meals a day, clean bedding, and adequate supplies of hygiene products.

Who Are the Detainees?

Rank	Country	% of Book-Ins	Notes
1	Mexico	31 %	Largest group nationwide
2	Guatemala	17 %	High asylum claims
3	Honduras	13 %	Family arrests rising
4	El Salvador	7 %	Gang-related cases
5	Venezuela / Nicaragua	5 % +	Political refugees

• 71 % have no criminal conviction (TRAC).
• 93 % have no violent conviction (Cato Institute).

Conditions in Detention — A Federal Judge Calls Them “Disgusting”

A recent federal court decision in Chicago exposed the reality of life inside ICE detention: overcrowded rooms, people sleeping on floors near overflowing toilets, and denial of basic hygiene and legal access.

In a blistering ruling, U.S. District Judge Robert W. Gettleman described these conditions as “disgusting” and “obviously unconstitutional.” Detainees have also reported being forced to sleep on urine-soaked floors next to clogged toilets, further highlighting the inhumane conditions. Detainees at ICE facilities report being treated worse than animals and packed into unsanitary holding cells.

The Chicago Ruling

On November 6, 2025, Judge Gettleman issued a preliminary injunction ordering ICE to immediately improve conditions at the Broadview, Illinois detention facility.
You can read the full ruling here (PDF).

“Obviously, some of these conditions are, in my word, disgusting. To have to sleep on the floor next to an overflowed toilet — that’s obviously unconstitutional.”
— Judge Robert W. Gettleman, U.S. District Court for the Northern District of Illinois, November 2025

The case was brought by immigrant advocates and detainees who described filthy bathrooms, overcrowding, and lack of access to legal counsel at the Broadview facility operated by ICE and local contractors.

Key Findings and Court Orders

Judge Gettleman ordered ICE to provide immediate remedies, including:

• Cleaning cells at least twice per day;
• Supplying soap, toothbrushes, menstrual products, and clean towels;
• Ensuring detainees are not forced to sleep on floors or on top of one another;
• Providing bottled water and regular meals that meet health standards;
• Guaranteeing detainees private, cost-free phone calls with lawyers;
• Posting bilingual lists of pro bono legal providers;
• Allowing showers at least every other day.

These mandates came after sworn testimony describing “150 people packed in one room”, some sleeping in chairs or on cold concrete.

Several detainees reported toilets overflowing with waste, water that “tasted like sewer,” and being pressured to sign deportation papers just to escape the conditions.

See full coverage at

• Associated Press
• Capitol News Illinois
• Wall Street Journal

Broader Implications

Although ICE detention is legally civil, not criminal, the judge noted that these conditions “do not pass constitutional muster” — blurring the line between administrative custody and punishment.
This ruling may open the door to nationwide challenges of unsafe or inhumane ICE facilities.

Advocates argue that Broadview’s conditions are not an isolated incident, but a symptom of an overburdened, under-regulated detention system now housing more than 66,000 people. Facilities in Texas, Louisiana, Arizona, and Ohio have reported similar overcrowding, medical neglect, and sanitation failures. The increased arrests have heightened fear and intimidation within immigrant communities, making individuals reluctant to attend legal proceedings.

“Detention in America has become indistinguishable from incarceration,” said Richard T. Herman, Esq.
“Immigrants in civil custody are treated worse than convicted criminals — yet they’re often here for nothing more than seeking a better life.”

Why It Matters

• The federal court order confirms that ICE facilities must meet basic standards of human decency even when operating under civil authority.
• It underscores how mass detention without oversight leads to violations of both due process and human dignity.
• For immigration lawyers and families nationwide, it sets a precedent for demanding improved conditions, access to counsel, and accountability from private contractors.

The ICE Detention Black Hole: When Immigrants Vanish Into a System Without Due Process

Quick Answer

When an immigrant is taken into ICE custody, they often disappear into a legal black hole.
Families can’t find them, lawyers can’t reach them, and ICE can move them anywhere in the country—sometimes overnight.

Because immigration detention is a civil system, not criminal, detainees have no guaranteed right to an attorney, and ICE faces no statutory deadline to file formal charges with the court.
This creates a constitutional void where human beings are detained indefinitely, sometimes without judicial review.

Fast Facts

Category	Details / Source
Detainees held in ICE custody (2025)	~66,000 per day (TRAC Reports)
Percent with no lawyer	~90% (TRAC Syracuse)
Percent with no criminal record	~71% (TRAC)
Number of ICE detention sites	150+ across 28 states (DHS OIG)
Average number of transfers per detainee	3–4 facility moves before court hearing (Human Rights Watch)
Primary information system	ICE Online Detainee Locator (ODLS) — often inaccurate or delayed (ACLU)

 

The Moment of Disappearance

When ICE arrests someone—whether through a home raid, workplace sweep, or jail transfer—family members are rarely notified.
In many cases:

• ICE does not tell families where detainees are taken.
• The Online Detainee Locator System (ODLS) can take days—or never—update.
• If a detainee is transferred across state lines, their record may vanish from the locator until the new facility updates its intake database.

Richard T. Herman, Esq.: “Families call us in panic. They know their loved one was picked up—but they don’t know if that person is alive, detained, or already deported.”

ICE’s Power to Move Detainees Anywhere

ICE can transfer detainees without notice, hearing, or consent to any detention center in the U.S.
The stated reason is “bed space management.” The real effect: separating immigrants from their families, attorneys, and communities.

• A person detained in Cleveland or Columbus can be flown to Louisiana, Texas, or Arizona overnight.
• Each transfer resets attorney-client communication—lawyers often lose contact for weeks.
• Mail forwarding is slow or nonexistent; legal papers can arrive after court deadlines expire.
• ICE can deliberately reassign detainees to jurisdictions with higher deportation rates, such as Louisiana or Texas, where courts are more favorable to ICE.
• Average: 3–4 facility moves before court hearing (Human Rights Watch)

According to the American Immigration Council, transfer practices “create severe barriers to due process and distort access to justice.”

The Legal Black Hole — When ICE Fails to File Charges

Detention is supposed to begin with the filing of a Notice to Appear (NTA) in immigration court.
But ICE routinely detains people before filing any NTA, effectively holding them in legal limbo.

Until the NTA is filed with the Executive Office for Immigration Review (EOIR):

• There is no active case number;
• The detainee’s lawyer cannot appear in court;
• The immigration judge has no jurisdiction to issue bond or release orders;
• The person remains detained without a hearing—sometimes for weeks or months.

Civil-rights advocates have called this practice “pre-charge detention,” arguing it violates the Fifth Amendment’s guarantee of due process.

“ICE can pick you up today, never file the NTA, and you simply disappear,” explains Richard T. Herman.
“No judge, no lawyer, no case—just detention.”

The ICE Locator System: Broken and Dangerous

The ICE Online Detainee Locator System (ODLS) is supposed to help families and lawyers find detained immigrants.
But in practice, it is notoriously unreliable:

• Misspelled names, wrong birthdates, and missing A-numbers cause failed searches.
• Detainees transferred across states may vanish from results for 48–72 hours.
• Noncitizens from certain countries (e.g., Cuba, Venezuela, Cameroon) often appear under incorrect nationalities.
• Families without internet access or English proficiency struggle to use the tool.

In some cases, attorneys have located clients only after calling multiple jails across different states—or by filing Freedom of Information Act (FOIA) requests.

See ACLU’s 2024 report on ODLS failures for documentation of dozens of such cases.

Constitutional Violations in Prolonged Detention

Immigration detention, though civil, can become unconstitutional when prolonged without review or charge.

Under Zadvydas v. Davis, 533 U.S. 678 (2001), the Supreme Court ruled that post-removal detention should not exceed six months absent strong justification.
Yet ICE frequently detains individuals for 12 months or longer—especially those awaiting travel documents or transfers.

The Fifth Amendment prohibits arbitrary imprisonment.
But ICE’s broad detention authority, combined with broken systems and lack of oversight, creates a shadow network of indefinite confinement.

“We have Americans who can’t be jailed for one night without a hearing,” notes Herman.
“Yet an immigrant—civil, not criminal—can vanish for months. That’s not due process. That’s bureaucratic disappearance.”

Family Devastation and Community Fear

Behind every case is a family suddenly shattered:

• Breadwinners vanish from jobs and households.
• Children go to school not knowing if their parents will be home.
• Spouses burn through savings on lawyers and travel trying to locate loved ones.
• Entire communities live in fear of unannounced ICE pickups.

In Ohio, families of detainees transferred from Butler County Jail to LaSalle, Louisiana report losing contact for weeks.

Local jails admit that once detainees are flown out on federal orders, they have no tracking authority.

Judicial Pushback — Cracks in the System

In November 2025, Judge Robert W. Gettleman in Chicago condemned ICE’s conditions as “disgusting” and ordered immediate reforms.
You can read the full court order here.

He described detainees sleeping beside overflowing toilets and ruled that such conditions “do not pass constitutional muster.” Advocates argue that this decision—though focused on conditions—signals growing judicial willingness to challenge ICE’s unchecked detention power.

Toward Transparency and Accountability

To restore fairness, advocates and lawyers propose reforms:

• Statutory deadlines for ICE to file NTAs within 48 hours of arrest;
• Judicial review of detention within 72 hours, mirroring criminal arraignment standards;
• Mandatory family notification upon arrest;
• National tracking system for detainee transfers;
• Funding for appointed counsel in civil immigration cases;
• Expansion of community-based alternatives to detention that maintain 90%+ compliance at 20% of the cost.

These measures would not only protect due process but also save billions in taxpayer funds while restoring public trust in immigration law enforcement.

Richard T. Herman: “The government’s power to detain must be balanced by a citizen’s right to know where their loved one is. Liberty cannot depend on ICE’s spreadsheet updates.”

Key Takeaways

• Immigration detention is civil, yet functions like a secretive criminal system.
• Families often cannot locate detained loved ones; ICE Locator is unreliable.
• Detainees are transferred across states—often to ICE-favorable courts.
• ICE sometimes detains people without filing formal charges or court cases.
• These practices violate due process and risk unconstitutional detention.
• Reform means transparency, accountability, and legal representation—not indefinite civil imprisonment.

 

Where Are People Being Detained — and How ICE Is Expanding Detention Through New Legal Tactics

In 2025, ICE’s detention geography and legal strategies have both changed.
The agency is not only adding beds and facilities but also expanding who it can detain—using new legal arguments and coordination with other federal and state forces.

Where Immigrants Are Being Detained

The majority of ICE detainees are held in 150+ facilities across 28 states.
Most are located far from major cities or legal aid networks.
According to TRAC Syracuse University, as of October 2025 the largest populations are in:

• South Texas Family Residential Center (Dilley, TX) — over 2,400 detainees
• Adelanto ICE Processing Center (CA) — 1,800 detainees
• LaSalle ICE Processing Center (LA) — 1,200 detainees
• Stewart Detention Center (GA) — 1,000 detainees
• Baker County Detention Center (FL) — 800 detainees
• Morrow and Butler County Jails (OH) — several hundred detainees combined
• Farmville, VA; Eloy, AZ; and Pine Prairie, LA — key long-term detention sites

Nearly 90 percent of these beds are privately contracted through GEO Group and CoreCivic, or through county jails under Inter-Governmental Service Agreements (IGSAs).

(Freedom for Immigrants Facility Database)

New Legal Argument: “No Bond Jurisdiction” for EWI Entrants

For decades, immigration judges held bond jurisdiction over immigrants who entered without inspection (EWI) but were placed into removal proceedings under INA § 240.
That long-settled interpretation changed in 2025, as ICE and the Office of the Chief Counsel began advancing a new claim:

that immigration courts lack jurisdiction to grant bond in cases where the person initially entered the U.S. unlawfully—even if they have lived here for years and have family ties.

This argument relies on a reinterpretation of INA § 236(a) (discretionary detention) versus § 235(b) (mandatory detention for “applicants for admission”).
ICE now asserts that EWIs are “arriving aliens” who must be held without bond until DHS releases them.

The BIA’s New Rule — Mandatory Detention for Those Who Entered Without Inspection (EWI)

In early 2025, the Board of Immigration Appeals (BIA) issued two landmark rulings that reshaped bond eligibility for immigrants who entered the United States without inspection.

Together, these cases — Matter of Yajure Hurtado, 29 I&N Dec. 216 (BIA 2025), and Matter of Q. Li, 29 I&N Dec. 66 (BIA 2025) — mark the most dramatic expansion of mandatory immigration detention in decades.

In Yajure Hurtado, the BIA held that a respondent who entered without inspection “is properly treated as an applicant for admission under section 235(b)(2)(A) of the INA,” and therefore is not eligible for a bond redetermination under section 236(a).

(Read the decision here)

What the BIA Decided

• Under the new interpretation, individuals who entered the U.S. without inspection are now treated as “arriving aliens” under INA § 235(b).
• Because of that classification, they are subject to mandatory detention and cannot request bond from an immigration judge.
• Only the Department of Homeland Security (DHS) — not the court — may release them on parole.

In Matter of Q. Li, the BIA reaffirmed the same logic, stating that “an alien determined to be an applicant for admission under section 235(b) is not eligible for a custody redetermination hearing under section 236(a).”

(Full BIA ruling)

Why This Matters

For decades, immigration courts recognized jurisdiction to hold bond hearings for people who entered without inspection but were later placed in removal proceedings under INA § 240.
This allowed thousands of long-term residents, asylum seekers, and mixed-status family members to seek release while their cases were pending.

The 2025 rulings eliminate that pathway in many jurisdictions.
ICE and DOJ trial attorneys are now arguing that immigration judges lack bond authority entirely for EWI respondents, even those with deep community ties and no criminal record.

Richard T. Herman, Esq. warns:
“These decisions turn civil detention into mandatory imprisonment. For people who have lived here for years, paid taxes, and raised families, this is not law — it’s exile by redefinition.”

Constitutional Concerns

Immigration advocates contend that the BIA’s new position violates due-process protections under the Fifth Amendment and undermines Zadvydas v. Davis (2001), which prohibits prolonged detention without individualized review.

They argue the rulings effectively grant ICE unilateral power to jail people indefinitely without judicial oversight.

Civil-rights organizations including the American Immigration Council and National Immigration Law Center are preparing federal court challenges, asserting that the BIA’s reading contradicts decades of precedent and congressional intent.

(Read analysis from the National Immigration Law Center)
(American Immigration Council commentary)

Key Takeaway

The 2025 BIA decisions — Yajure Hurtado and Q. Li — have stripped immigration judges of bond authority for many people who entered the country unlawfully, converting what was once discretionary civil custody into mandatory detention without hearing.
The outcome: thousands more immigrants locked away, families separated longer, and due process reduced to a bureaucratic formality.

Richard T. Herman, Esq. warns: “This is a quiet constitutional crisis. ICE is stripping judges of power to release people, turning civil detention into mandatory imprisonment.”

Expedited Removal 2.0 — “Dismiss, Detain, and Deport”

Another growing ICE strategy involves seeking dismissal of cases already filed in immigration court, especially for individuals eligible for relief (like adjustment or cancellation).
Once a case is dismissed under Matter of Coronado Acevedo, ICE can:

1. Re-arrest the immigrant immediately—often in the courthouse hallway;
2. Bypass the court entirely by reclassifying the person as subject to expedited removal under INA § 235(b); and
3. Begin deportation proceedings without judicial review.

This tactic is being widely reported in Chicago, Atlanta, and Houston immigration courts.
Attorneys describe ICE agents waiting outside hearing rooms with arrest warrants—sometimes detaining immigrants moments after their cases are closed.

(American Immigration Lawyers Association (AILA) Practice Alert)

The “Jurisdiction Shopping” Problem

ICE’s transfer authority allows it to move detainees across state lines to courts known for high deportation rates and low bond approvals.
For instance:

• Ohio detainees have been transferred to Baton Rouge, LA or Jena, LA, where denial rates exceed 90%.
• New York and California cases are being reassigned to Texas detention courts, circumventing local pro bono representation.

This practice undermines the principle of geographic fairness and effectively deprives immigrants of counsel.

(TRAC Immigration Court Data)

ICE, FBI, and National Guard Coordination

In several U.S. cities—including Chicago, Atlanta, Houston, and Cleveland—ICE has begun coordinating raids with FBI field offices and state National Guard units.
The stated purpose is “joint homeland operations,” but the practical effect is large-scale roundups of non-criminal immigrants.

• National Guard assists in surveillance, vehicle checkpoints, and drone mapping.
• FBI provides data integration through Homeland Intelligence Fusion Centers, giving ICE access to state criminal databases.
• Raids often occur near workplaces, apartment complexes, or religious centers identified through digital monitoring.

(The Intercept, 2025: “Inside ICE’s Joint Operations with the FBI and National Guard”)

These operations have reignited fears in immigrant communities reminiscent of post-9/11 sweeps, with critics warning of civil liberties violations and racial profiling.

Arrests Inside USCIS Offices

Another alarming pattern is the increase in ICE arrests at USCIS field offices—particularly during green card (I-485) interviews for spouses of U.S. citizens.

• USCIS shares applicant data with ICE under “security vetting protocols.”
• If ICE identifies prior removal orders or pending criminal checks, it can send agents to the interview site.
• Multiple reports from Cleveland, Detroit, and Atlanta confirm immigrants being detained in the interview room or immediately after leaving the building.

(Washington Post: “ICE Arrests Green Card Applicants at USCIS Interviews”)

“These arrests violate the spirit of USCIS’s own mission,” says Herman.
“People come in good faith to legalize their status—and ICE uses it as a trap.”

Legal and Constitutional Implications

Collectively, these new tactics—bond denials for EWIs, expedited removals after dismissals, interagency raids, and USCIS arrests—erode due process in what remains a civil system.

They also challenge the jurisdictional balance between the Department of Homeland Security (DHS) and the Department of Justice (DOJ):

• Immigration judges lose authority over release and review.
• ICE gains unilateral control over custody and removal.
• Families lose access to courts altogether.

This concentration of power raises serious constitutional concerns under the Fifth Amendment’s Due Process Clause and the separation of powers principle.

Richard T. Herman: “When ICE can arrest you in a USCIS office, deny you bond, move you across the country, and deport you before a judge ever sees your case—that’s not law enforcement. That’s lawless enforcement.”

Key Takeaway

The United States now runs a multi-layered enforcement machine that can arrest, detain, transfer, and deport immigrants almost entirely outside judicial oversight.
The shift toward denying bond jurisdiction and expanding expedited removal has created a system where civil detention resembles secret detention—opaque, punitive, and constitutionally fragile.

Federal Habeas Pushback — Courts Challenge the No-Bond Rule in Yajure-Hurtado and Q. Li

Federal courts are beginning to push back against ICE’s “mandatory detention” argument following the BIA’s 2025 decisions in Matter of Q. Li and Matter of Yajure-Hurtado.
While those rulings treat people who entered without inspection (EWI) as “applicants for admission” detained under INA § 235(b)—and therefore ineligible for bond—recent habeas corpus decisions are finding this framework unconstitutional in practice.

Key 2025 Federal Habeas Rulings

• Southern District of California – Martínez López v. DHS (Oct. 30 2025)
  The court granted habeas, ruled the petitioner was improperly classified under § 235(b), and ordered a bond hearing under § 236(a) within ten days. It also enjoined ICE and EOIR from denying bond “on the basis that he is detained under 8 U.S.C. § 1225(b)(2).”
  Read the full decision → <u>District Court Order (PDF)</u>
• District of Massachusetts – New England Class Action (Oct. 31 2025)
  Judge Patti Saris granted class-action status to thousands of EWI detainees and ruled that the government’s no-bond interpretation “raises grave due-process concerns.” The decision compels individualized hearings for detainees held solely under the Yajure-Hurtado rationale.
  See <u>Reuters coverage</u> and <u>ACLU press statement</u>.
• Nationwide Trend – Fall 2025
  District courts in Chicago, Houston, and San Diego have likewise ordered bond hearings for long-term residents misclassified under § 235(b). Judges emphasize that due process requires individualized review, not blanket mandatory detention.
  Overview → <u>Politico analysis</u>.

What the Courts Are Saying

These cases reaffirm three constitutional principles:

• Habeas corpus remains available to challenge detention lacking judicial review or individualized custody assessment. <u>ACLU explainer</u>
• Blanket no-bond detention violates Fifth Amendment due process when applied to long-term residents with deep community ties.
• ICE cannot use reclassification under § 235(b) to strip immigration judges of bond jurisdiction wholesale.

“Section 235(b) cannot be weaponized to deny review where the person has lived in the United States for years,” one federal judge wrote, warning that ICE’s approach “erases the statutory distinction between applicants for admission and established residents.”

Practice Implications for Defense Attorneys

• File § 2241 Habeas Early: When an IJ denies bond solely under Yajure-Hurtado / Q. Li, seek habeas review asserting custody under § 236(a).
• Document Due Process Harms: Record transfer delays, lost counsel access, and lack of notice—these factors strengthen constitutional claims.
• Leverage Regional Precedent: The New England class action provides strong support for arguing that categorical no-bond detention is unlawful.
• Expect Variance: Some courts still defer to the BIA; others, like S.D. Cal., have directly enjoined the no-bond rationale.

Expert Commentary

“Habeas is now the frontline defense against ICE’s overreach,” says Richard T. Herman, Esq.
“These rulings restore the balance Congress intended—judges, not bureaucrats, decide when liberty can be taken away.”

Key Takeaway

Federal judges are signaling that the BIA’s no-bond framework cannot override constitutional safeguards. Even under Yajure-Hurtado and Q. Li, immigrants detained after entering without inspection are entitled to individualized custody review and may seek release through habeas corpus petitions.

When Civil Enforcement Turns Militarized — The Chicago Court’s Warning

The militarization of ICE operations has reached a tipping point — and a federal judge in Chicago just said so.
In November 2025, U.S. District Judge Sara Ellis issued a blistering opinion condemning federal immigration agents for using “excessive and militaristic force” during mass-enforcement operations in the city.
The ruling, paired with ongoing raids in Los Angeles, Atlanta, Houston, and Cleveland, exposes how ICE’s tactics have created a nationwide culture of fear in immigrant communities.

See Washington Post coverage of the ruling and Associated Press report for full details.

 The Chicago Ruling: “This Shocks the Conscience”

In her 58-page opinion, Judge Ellis found that ICE and U.S. Border Patrol agents had lied about threats during a 2024 operation known as Operation Midway Blitz, which involved hundreds of federal agents, armored vehicles, and aerial drones in residential Chicago neighborhoods.

“This is a vibrant place, brimming with vitality and hope,” wrote Judge Ellis. “The government would have people believe that Chicagoland is under siege — that is simply untrue. The tactics employed here shock the conscience.”

The court issued an injunction ordering ICE and DHS to:

• Stop using riot-control weapons such as tear gas and pepper balls in civil immigration operations;
• Ensure visible identification and body cameras on agents; and
• Cease coordination with military units for domestic immigration raids absent express judicial authorization.

Read the full decision summary on AP News.

The Militarization of ICE: From Chicago to Los Angeles

The Chicago ruling follows months of escalating ICE invasions in major U.S. cities.
Operations now resemble counterterrorism deployments — complete with tactical gear, drones, and military-style formations.

• In Los Angeles, ICE agents in camouflage conducted raids across East LA, using helicopters for aerial surveillance. Faith leaders reported arrests outside St. Mary’s Catholic Church, where parishioners were leaving Sunday mass.
• In Chicago, residents described armored vehicles rumbling down residential streets and National Guard troops blocking intersections during dawn raids.
• In Atlanta, federal and state officers raided several apartment complexes, detaining parents in front of their children.
• Cleveland and Columbus, Ohio have seen fusion-center-led sweeps targeting neighborhoods with large immigrant populations.

Community reports compiled by The Guardian and The Intercept confirm that ICE has enlisted support from the FBI, National Guard, and Homeland Intelligence Fusion Centers, blending criminal enforcement, immigration policing, and military oversight.

A Culture of Fear

Across cities, the fallout is profound:

• Parents stop sending children to school for fear of arrests near drop-off zones.
• Workers avoid hospitals or job sites, worried about data-sharing and undercover raids.
• Clergy in Los Angeles and Chicago now coordinate “sanctuary networks” to escort parishioners home safely after worship.
• Local police report that victims of domestic violence and wage theft are no longer reporting crimes out of fear that 911 calls will summon ICE.

Faith leaders and civil-rights groups say these operations have “paralyzed entire neighborhoods.”
In interviews with The Washington Post, one Chicago pastor described “children hiding under pews” during an ICE raid in a church parking lot.

Expert Commentary

“This is not law enforcement — it’s a campaign of intimidation,” says Richard T. Herman, Esq., founder of the Herman Legal Group.
“When ICE rolls into cities with armored trucks, drones, and National Guard support, it turns civil immigration into a military occupation. The Constitution doesn’t allow that — and Judge Ellis just reminded them of it.”

Key Takeaway

The Chicago ruling may be the first federal rebuke of ICE’s militarized tactics — but the underlying issue is national.
ICE’s operations in Los Angeles, Chicago, Atlanta, and Cleveland demonstrate how civil immigration enforcement has become indistinguishable from paramilitary policing, creating a pervasive culture of fear that silences entire communities and undermines the rule of law.

Where ICE Arrests Are Happening — From Home Depot to Church Parking Lots

In 2025, Immigration and Customs Enforcement (ICE) has expanded beyond border operations and detention facilities — launching coordinated, city-level sweeps that reach into workplaces, neighborhoods, and even places of worship.
According to a combination of Freedom of Information Act (FOIA) releases, press investigations, and community reports, these raids now operate with military-style coordination involving the FBI, Homeland Security Investigations (HSI), and, in several states, the National Guard.

 Urban Raids and “Homeland Task Forces”

ICE’s Enforcement and Removal Operations (ERO) units are conducting multi-agency sweeps in major metropolitan areas including Chicago, Atlanta, Dallas, Cleveland, Los Angeles, and Miami.
The operations often deploy before dawn, focusing on residential neighborhoods with large immigrant populations.

• In Chicago, the FBI field office and Illinois National Guard provided logistical support and drone surveillance during a March 2025 ICE sweep.
• In Texas, Governor-approved Guard units have supported “joint migrant suppression” under Operation Lone Star, giving ICE access to checkpoints and aerial thermal imaging.
• ICE describes these partnerships as “joint homeland enforcement operations.” Critics, including civil-rights attorneys, call them paramilitary immigration raids.

See coverage by The Intercept (“Inside ICE’s Joint Operations with the FBI and National Guard”) and The Washington Post (“Trump Administration Expands Interior Raids with Military Assistance”).

 At Home — The Return of “Knock and Talk”

ICE agents are again using “knock-and-talk” home visits, often dressed in plain clothes and claiming to be local police.
Agents target mixed-status households identified through data-sharing with state DMV databases, utility records, and USCIS interview lists.

• In Ohio, community groups report ICE agents knocking on doors at 6 a.m., asking for a “signature” before detaining residents.
• Families are rarely told where loved ones are taken, as transfers can happen within hours.

The ACLU warns that many of these operations violate the Fourth Amendment because agents rely on consent searches without judicial warrants.
See ACLU guide to ICE home raids.

Worksite Raids — Construction Sites, Factories, and Restaurants

Worksite enforcement, once rare after 2020, has resurged in 2025 under “Project Integrity.”
ICE agents conduct unannounced raids at construction sites, meat-processing plants, and restaurant supply warehouses.

• In Atlanta and Houston, ICE detained more than 400 workers in coordinated early-morning raids at industrial zones.
• In Ohio, raids at construction supply depots and Home Depot parking lots have led to dozens of arrests of day laborers waiting for jobs.
• Agents sometimes use undercover vehicles and drones to identify groups before swooping in with tactical units.

See Associated Press (“Mass ICE Raids Hit Worksites Across Five States”) and ProPublica (“Inside Project Integrity: How ICE Targets Undocumented Workers”).

Near Churches, Schools, and Clinics

Although ICE’s 2011 “sensitive locations” policy traditionally barred arrests at churches, schools, and hospitals, new internal guidance leaked in 2025 shows that the agency now treats those rules as “non-binding.”

• Church parking lots and after-service gatherings are now being monitored for “fugitive apprehensions.”
• In Los Angeles, plain-clothes agents followed parishioners out of St. Mary’s Catholic Church before making arrests.
• In Miami, a Guatemalan father was detained outside his child’s school while dropping off a lunch bag.

Faith leaders across denominations have condemned these tactics as “a moral betrayal.”
See Reuters report (“ICE Resumes Arrests at Churches and Schools”) and National Catholic Reporter (“Clergy Denounce Churchyard Immigration Raids”).

Coordination and Data Sharing

These operations rely heavily on data fusion centers that integrate:

• USCIS application data (e.g., pending green card or asylum cases);
• DMV and state licensing records;
• Facial-recognition systems shared by FBI and DHS Intelligence Fusion Centers; and
• Utility-billing and rental databases accessed through private data brokers.

Civil-liberties groups, including Electronic Frontier Foundation and Brennan Center for Justice, warn that this infrastructure now enables real-time immigrant tracking.
See EFF report on DHS facial recognition.

Expert Commentary

“We’re seeing a complete re-militarization of interior immigration enforcement,” says Richard T. Herman, Esq.
“Arrests at churches, job sites, and even USCIS offices represent a systematic campaign of intimidation — one that criminalizes civil immigration.”

Key Takeaway

ICE’s arrest geography is no longer limited to the border.
It now includes city neighborhoods, workplaces, faith communities, and schools — with the help of National Guard units, fusion-center intelligence, and local police.
The scale and coordination mirror the mass-detention infrastructure built in the 1950s and revived today under “homeland enforcement.”

 

Expansion Plans — Building a Bigger Detention Machine

As the ICE detainee population surges past 66,000, the federal government is quietly expanding the detention map—through new construction, contract renewals, and reactivation of mothballed county jails.
The goal: increase total capacity to 75,000 beds by FY 2026. ICE now has enough detention beds to hold as many as 70,000 detainees, up from 41,500 at the beginning of Trump’s second administration.

Where New Beds Are Being Added

According to internal ICE procurement notices and reporting by the Vera Institute and Freedom for Immigrants:

• South Texas Family Residential Center (Dilley, TX): expanding by 2,400 beds under a CoreCivic contract worth ≈ $190 million annually.
• Adelanto ICE Processing Center (CA): GEO Group refitting a closed wing to add ≈ 1,600 beds; contract ≈ $150 million per year.
• LaSalle ICE Processing Center (LA): reopening part of a dormitory for ≈ 900 additional beds.
• Stewart Detention Center (GA): adding 400 beds and a medical wing through a public-private partnership valued at ≈ $45 million.
• Baker County Facility (FL): doubling capacity to ≈ 1,200 under a new 10-year agreement with ICE.
• Youngstown, Ohio (Mahoning County Jail Annex): ICE requested proposals for ≈ 250 overflow beds as part of a regional detention network serving Cleveland and Detroit EOIR courts (Cleveland.com).

Projected Costs

• Construction & retrofit: ≈ $1.3 billion in new federal spending through FY 2026, including $480 million in direct appropriations and ≈ $800 million in long-term lease obligations (Congressional Budget Justification, DHS FY 2025).
• Operating contracts: average $150–$170 per bed per day, resulting in ≈ $4.6 billion in annual operating liabilities if all beds are filled.
• Private contractors: GEO Group and CoreCivic together control ≈ 85 % of new construction and refitting projects. Smaller bidders include MTC (Management & Training Corporation) and Akima Global Services.

Geographic Spread

• Southern Border Region: Texas, Louisiana, and Arizona remain detention epicenters.
• Midwest & Appalachia: ICE is reviving county jails in Ohio, Kentucky, Indiana, and West Virginia to house interior arrests.
• West Coast: California facilities operate under state restrictions on new private detention, forcing ICE to seek “federal enclave” exemptions (LA Times).

Who Is Building

• GEO Group Inc. (headquartered in Florida) — largest ICE contractor with ≈ 24,000 beds under management nationwide.
• CoreCivic Inc. (Tennessee) — ≈ 19,000 ICE beds plus family facilities in Texas and Arizona.
• Local county sheriffs’ departments enter Inter-Governmental Service Agreements (IGSAs) with ICE for daily per-diem payments.

Accountability Concerns

Watchdogs warn that many of these contracts bypass federal procurement oversight.
In 2024, the DHS Inspector General found “serious deficiencies in contract monitoring” and “unsafe conditions at multiple sites.” Auditors highlighted over $400 million in payments for beds that were unused or understaffed.

Richard T. Herman, Esq.: “Instead of building schools or veteran housing, America is building prisons for families with no criminal records. This is not security — it’s a tragedy of priorities.”

Key Takeaway

By 2026, ICE could manage a detention network larger than the entire federal Bureau of Prisons system (≈ 155 facilities vs. 122).

The expansion cements mass detention as a standing institution — absorbing billions that could otherwise fund education, veteran care, and community development.

Death and Neglect in ICE Detention — A Life-and-Death Civil System

Immigration detention in the United States is supposed to be civil custody, not punishment. But for hundreds of men, women, and even children, detention has turned into a death sentence—caused by medical neglect, delayed treatment, and systemic indifference. Concerns about overcrowding and substandard conditions in ICE facilities have been raised, leading to reports of inadequate food and medical neglect. Detainees claim they are fed inedible food and are not allowed to bathe for days or weeks at a time.

Between 2017 and 2025, more than 130 people have died in ICE custody.
Independent reviews suggest that at least 95 percent of these deaths were preventable with timely care or intervention.
(ACLU Report).

Getting Medical Care Inside ICE Detention

In theory, ICE detainees have access to care through the ICE Health Service Corps (IHSC) — a division of the Department of Homeland Security responsible for providing or coordinating healthcare in detention.
In practice, access is deeply limited.

Common Barriers Reported:

• Delays of days or weeks to see a nurse or doctor, even for serious symptoms.
• No continuity of care when detainees are transferred — medical files often lost between facilities.
• Insufficient medications: detainees report receiving partial doses or abrupt discontinuations of prescribed drugs.
• Language barriers: requests for care ignored or misinterpreted.
• Retaliation fears: detainees discouraged from filing medical grievances.

A 2024 audit by the DHS Office of Inspector General found “gross medical mismanagement” in multiple ICE facilities, including expired medications, unlicensed staff performing triage, and falsified medical logs.
(DHS OIG Report)

“Detainees were not consistently receiving necessary medical care, and ICE failed to ensure continuity of care for chronic and serious conditions,” the Inspector General concluded.

How Detainees Can Request Medicine

Each ICE facility has a “sick call” or “medical request” process, but detainees often must:

1. Submit written medical forms in English;
2. Wait several days for review;
3. Hope for approval from on-site staff, often contractors with no specialized training.

Prescriptions from outside doctors are not automatically continued.
Even life-sustaining medications like insulin, antidepressants, heart medication, or HIV treatment can be delayed or changed without explanation.

In some cases, ICE refuses to provide medication until an in-house doctor “confirms diagnosis,” creating dangerous treatment gaps.
(Human Rights Watch report on ICE medical neglect)

Mental-Health Care — Often Nonexistent

Detainees with PTSD, depression, or anxiety face especially high risk.
According to a 2025 review by Freedom for Immigrants, mental-health services are “sporadic, underfunded, and often punitive.”

Typical accounts include:

• Detainees requesting counseling being placed in solitary confinement “for observation.”
• Lack of bilingual therapists or trauma-informed professionals.
• Limited access to psychiatric medication.
• No therapy continuity after transfer.

The Suicide Prevention Program inside ICE facilities is so broken that, according to one internal review, guards “routinely falsified suicide watch logs.”
(NBC News investigation).

Recent Deaths Highlight the Crisis

• October 2024: A 43-year-old Guatemalan man died at the Adelanto ICE Processing Center in California after multiple requests for medical help were ignored.
• June 2025: A Venezuelan asylum seeker with diabetes died at the LaSalle ICE Processing Center in Louisiana after being denied insulin for three days.
• August 2025: A 29-year-old Nigerian detainee died by suicide at the Baker County Detention Center in Florida; his family said ICE failed to inform them for nearly two weeks.

Each death tells a story of bureaucratic delay, indifference, and families left without answers.

What Families and Lawyers Can Do

If a loved one is detained and in medical distress:

• File an urgent “Request for Medical Care” with ICE and send a copy to the facility administrator and ICE Field Office Director.
• Contact the ICE Detention Reporting and Information Line (DRIL) at 1-888-351-4024.
• Submit a congressional inquiry through your representative or senator’s office.
• Document every symptom, request, and denial — written records can later prove negligence or support humanitarian parole.
• Consult an immigration attorney experienced in detainee rights.

Expert View

“When ICE fails to provide medical care, it’s not an accident — it’s a design flaw in a system built for punishment, not care,” says Richard T. Herman, Esq.
“We’ve represented clients denied insulin, psychiatric medication, even access to their eyeglasses. It’s not civil custody. It’s cruelty disguised as procedure.”

Key Takeaway

Medical neglect in ICE detention is not rare — it’s routine.

A system that claims to be civil has repeatedly denied basic healthcare to people in its custody, with deadly consequences. Real reform requires independent medical oversight, immediate access to care, and accountability for every preventable death.

Civil Enforcement — Not Criminal Law, But Life-Changing Consequences

Immigration enforcement is civil, not criminal.

Yet it looks and feels like a criminal process—arrests, jumpsuits, jail cells—but without the rights afforded to criminal defendants.

• No right to court-appointed counsel.
• No jury.
• Proceedings before DOJ judges, not federal courts.
• Language barriers and distance from attorneys create near-zero access to justice.

Representation Gap

• ≈ 90 % of detained immigrants have no lawyer (TRAC Data).
• Those with attorneys are 10 times more likely to win relief (American Immigration Council).
• Without counsel: ≈ 3 % success rate. With counsel: ≈ 30 %.

Richard T. Herman:

“Immigration court looks criminal—but offers none of the protections. We are deporting people in silence.”

Expert Perspectives

Dr. Austin Kocher, Syracuse University:

“This is the largest detention apparatus in modern U.S. history.”

Richard T. Herman, Esq.:

“The U.S. is spending billions to incarcerate families instead of fixing immigration courts or supporting legal pathways.”

Legal Framework & Authority

• INA § 236 (8 U.S.C. § 1226): Pre-removal detention.
• INA § 241 (8 U.S.C. § 1231): Post-order detention.
• Zadvydas v. Davis (2001): Limits indefinite detention.
• EOIR: Detention cases handled in civil immigration courts under DOJ.

What’s Next — The End Game

• Detention as deterrence: political theater of “toughness.”
• Permanent infrastructure: contracts and facilities hard to unwind.
• Budget lock-in: billions appropriated annually create self-perpetuating industry.
• Legal pushback: expected from ACLU, NIJC, Human Rights First.
• Public question: Is mass detention a policy—or a business model?

The Case for a Modern 245(i) — Legalization Over Criminalization

While America spends billions jailing undocumented immigrants, history shows that legalization—not punishment—has been the most effective, fiscally responsible, and humane path forward.

What Was Section 245(i) of the Immigration and Nationality Act?

Under Section 245(i)—created by the Legal Immigration Family Equity (LIFE) Act of 2000—certain undocumented immigrants in the U.S. could adjust status to lawful permanent residence (green card holders) without leaving the country if:

• They had an immigrant visa petition or labor certification filed for them on or before April 30, 2001;
• They paid a $1,000 penalty fee; and
• They were otherwise admissible.

This program, which passed under President Bill Clinton and was implemented during President George W. Bush’s first year, allowed hundreds of thousands of immigrants to “get right with the law,” pay a fine, and contribute openly to the U.S. economy.

Richard T. Herman, Esq. explains:
“Section 245(i) recognized a simple truth — that fixing the system is smarter than criminalizing families. It allowed good people to pay a penalty, register, and stay united.”

The Reagan–Bush Tradition of Legalization

Contrary to modern political rhetoric, Republican presidents have historically led the way on immigration reform:

• Ronald Reagan’s 1986 Immigration Reform and Control Act (IRCA) granted legal status to nearly 3 million undocumented immigrants, requiring background checks and taxes paid. Reagan called it “a human and economic renewal for America.”
• George H.W. Bush’s 1990 Immigration Act expanded family and employment-based immigration, creating diversity visas and legalization opportunities for dependents left out of IRCA.
• George W. Bush, before 9/11, pushed to renew 245(i) and establish a guest-worker path to legal status. His plan had bipartisan momentum—until terrorism redefined political priorities.

Since April 30, 2001, there has been no legalization program. Over two decades later, millions who might have adjusted status through 245(i) now live in the shadows—tax-paying, long-term residents barred from regularizing their lives.

The Missed Opportunity — Obama and the “Gang of Eight”

In 2006–07, then–Senator Barack Obama participated in bipartisan negotiations with the “Gang of Eight”—including Senators McCain, Kennedy, Graham, and Durbin—to build a comprehensive reform bill. Obama later withdrew, focusing on his presidential campaign.
When he became president, his administration pivoted toward record deportations, earning him the label “Deporter in Chief.”

Despite creating DACA in 2012, Obama never revived 245(i) or pursued large-scale legalization, even when Democrats controlled both chambers of Congress.

The Trump Era — From Legalization to Xenophobia

Donald Trump reversed decades of bipartisan pragmatism.
From his first campaign speech—descending his escalator and declaring that Mexican immigrants were “bringing drugs, bringing crime, [and] rapists”—Trump weaponized xenophobia as a political strategy.

Under his influence, immigration enforcement shifted from civil regulation to cultural warfare:

• Families detained en masse;
• Refugee admissions cut to historic lows;
• Legal immigration slashed through administrative rules;
• Deportation rebranded as a patriotic duty.

Why Reviving 245(i) Makes Fiscal and Moral Sense

Reinstating a modern version of 245(i) could:

• Generate billions in fees and taxes from eligible applicants;
• Reduce the burden on immigration courts and ICE detention;
• Allow law-abiding undocumented immigrants to pay a penalty and legalize their status;
• Reunite millions of U.S. citizen families separated by visa backlogs;
• Strengthen national security by bringing more people “into the system.”

The nonpartisan Congressional Budget Office has repeatedly found that legalization increases GDP and tax revenues while reducing deficits.
In contrast, mass detention and deportation add nothing to economic growth and consume billions in taxpayer dollars each year.

Richard T. Herman: “We once had a Republican president—Ronald Reagan—who called immigration the lifeblood of America. We can choose that vision again: registration, penalties, and earned legalization, instead of endless punishment.”

Key Takeaway

Bringing back Section 245(i) and expanding legalization pathways isn’t amnesty—it’s accountability and common sense.

It would allow millions of hard-working immigrants to come forward, pay fines, undergo security checks, and fully contribute to the nation they already call home—while redirecting billions away from detention toward schools, hospitals, and housing for all Americans.

How Herman Legal Group Compares to Other Top Immigration Firms

Region/Focus	Law Firm	Key Strength	Comparison
Midwest (OH)	Herman Legal Group	30 + years · Multilingual team	One of Ohio’s oldest dedicated immigration practice
National Corporate	Fragomen LLP	Global mobility	Corporate clients; HLG focuses on families
Humanitarian (TX)	Murthy Law Firm	Asylum & USCIS filings	National reach; HLG offers local advocacy
West Coast	Seyfarth Shaw	Compliance	Large-firm model vs. boutique care
East Coast	Cyrus Mehta & Partners	Litigation & scholarship	Similar thought leadership; HLG adds Midwest depth

Key Takeaways

• 66,000 detainees — historic record.
• $4 billion annual cost, mostly for non-criminals.
• Detention is civil, yet denies basic due process.
• 90 % lack lawyers; counsel increases success 10x.
• $10 million/day could house, feed, or educate Americans instead.
• Human toll: deaths, births in custody, shattered families.
• Political motives: Project 2025 aims for mass deterrence, not reform.

About Richard T. Herman

Richard T. Herman, founder of the Herman Legal Group, has over 30 years of experience representing immigrants nationwide.
He is co-author of Immigrant, Inc. and a recognized commentator on immigration law and policy.
Schedule a confidential consultation → Book now.

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