Introduction

On April 13, 2026, Reuters reported that the Trump administration had dismissed nine additional immigration judges over the preceding two weeks, including two Massachusetts-based judges who had ruled against the federal government’s efforts to deport pro-Palestinian university students.1 The terminations bring the total number of immigration judges removed since January 2025 to one hundred and thirteen, according to the National Association of Immigration Judges (“NAIJ”). This article supplements our prior analysis of the December 1, 2025, New York firings2 and examines the legal, structural, and practical implications of the latest wave of dismissals.

The April 2026 Firings: A Continuation of an Established Pattern

According to NAIJ, six immigration judges were dismissed during the weekend of April 10–12, 2026, and three additional judges were dismissed on Good Friday, April 3, 2026.3 The union characterized the firings as having occurred without due process, cause, or explanation, and as “wrong and unjust.”3 The pattern is by now familiar: probationary judges receiving notice by email, often near the end of their two-year probationary periods, with no articulated rationale and no formal opportunity to respond.

As we have previously documented, the December 1, 2025, removal of seven sitting judges from 26 Federal Plaza in New York City—including Assistant Chief Immigration Judge Amiena A. Khan, and Judges Lori K. Adams, Theodora N. Kouris, Maria Lurye, Lisa Batya Schwartz Ehrens, Alice Segal, and Evalyn P. Douchy—represented one of the most consequential single-day actions of its kind in modern immigration adjudication.2 The April 2026 dismissals do not break that pattern; they extend it geographically and place it firmly within a sequence of identifiable, politically resonant terminations.

Judges Patel and Froes: The Öztürk and Mahdawi Cases

Two of the judges fired in the most recent wave drew particular attention. Judge Roopal Patel, who sat at the Boston Immigration Court, and Judge Nina Froes, who sat at the Chelmsford Immigration Court, were both appointed during the Biden administration in 2024 and were dismissed near the conclusion of their two-year probationary periods.4 Each had recently issued a ruling adverse to the Department of Homeland Security in a high-profile removal case involving an international student associated with pro-Palestinian advocacy.

On January 29, 2026, Judge Patel terminated proceedings against Tufts University doctoral student Rümeysa Öztürk, finding that DHS had not met its burden of proof to sustain the charges.5 Approximately one month later, Judge Froes dismissed deportation proceedings against Mohsen Mahdawi, a Columbia University student and lawful permanent resident.6 Both rulings drew immediate criticism from the administration, and within weeks both judges had been notified of their terminations.7 Whether the dismissals were causally connected to the rulings cannot be confirmed on the present record—no agency rationale has been provided in either case—but the proximity of the rulings to the terminations is striking, and the absence of any contrary explanation is itself a matter of public concern.

The Statutory and Constitutional Framework: A Note on Why This Matters

Immigration judges are not Article III judges. They are attorneys appointed by the Attorney General to serve as administrative adjudicators within the Department of Justice’s Executive Office for Immigration Review.8 Their statutory authority to conduct hearings, take evidence, and issue removal orders is broad,9 but their employment status is that of executive-branch personnel subject to the Attorney General’s removal power—a power that has been read expansively in recent administrative decisions, including a March 2026 Merit Systems Protection Board ruling that significantly weakened the statutory civil-service protections previously thought to constrain at-will dismissals of immigration judges.10 The administration has framed these personnel actions as part of a broader policy agenda; the White House announced on April 10, 2026, that the “era of amnesty” in the immigration courts had ended.11

Whatever one makes of the policy framing, the constitutional implications are not abstract. Procedural due process, as the Supreme Court has long recognized, requires meaningful access to a neutral decisionmaker.12 When a respondent in removal proceedings stands before an adjudicator who has reason to believe that an unfavorable ruling against the government may result in the loss of his or her position, the structural conditions that make a hearing meaningful begin to erode. That erosion is not visible on the record of any individual case; it is a systemic phenomenon that emerges over many cases, and over time, in the aggregate behavior of the bench.

The Replacement Pattern: Temporary Immigration Judges and Military Lawyers

The terminations have not occurred in isolation. As we have previously analyzed, the Department of Justice in August 2025 issued a final rule expanding eligibility for Temporary Immigration Judges (“TIJs”) to include attorneys from across the federal government, and in September 2025 the Secretary of Defense authorized up to 600 military lawyers to be detailed into TIJ positions.13 The result is a dual-track restructuring: experienced humanitarian-oriented adjudicators are being removed, while their replacements—many drawn from enforcement-oriented backgrounds, military legal practice, or short-term temporary details—are being installed at speed.14

CNN, drawing on NAIJ data, reported that at least one hundred and thirty-nine immigration judges had been fired, accepted deferred-resignation offers, or been involuntarily transferred since the start of the second Trump administration.15 The figure now reported by NAIJ—one hundred and thirteen outright terminations—represents a substantial subset of that broader figure and underscores the magnitude of the bench reorganization. Public TRAC data indicates that the judges removed have, on the whole, had grant rates well above the national average,16 a correlation we examined in detail in our prior article on the New York firings.2

Practical Implications for Respondents and Practitioners

For practitioners with active matters in courts that have lost judges—including New York, Boston, Chelmsford, San Francisco, and others—several practical points warrant attention.

First, dockets are being reassigned at unprecedented scale. Cases set before terminated judges are being transferred to remaining judges or to newly installed TIJs, often with little advance notice. Counsel should monitor the EOIR portal closely for changes in judge assignments and be prepared to renew or re-file pending motions, including motions to continue, motions to reopen the evidentiary record, or motions for video appearance, where the change in adjudicator materially affects the procedural posture.

Second, the substantive expectations of newly assigned adjudicators may differ substantially from those of their predecessors. Counsel should not assume that prior practice norms in a particular courtroom—regarding admission of country-conditions evidence, scope of cross-examination, or treatment of expert testimony—will carry over. Submissions should be prepared with an eye toward written documentation that can stand on its own before an unfamiliar adjudicator and, if necessary, on appeal to the Board of Immigration Appeals or to the relevant circuit court.17

Third, the pattern of recent decisions suggests an elevated need for thorough preservation of the record below. Where an adverse ruling appears imminent—particularly in cases involving asylum, withholding, or protection under the Convention Against Torture—counsel should ensure that all evidentiary objections, due process objections, and constitutional arguments are placed clearly on the record. Cases that begin in front of one judge and conclude in front of another raise distinct preservation concerns, and the Board’s standards for plain error and waiver remain unforgiving.17

The Independence of the Adjudicative Function

The American Bar Association and other commentators have for many years argued that immigration adjudication should be removed from the Department of Justice and reconstituted as an Article I court, on the model of the Tax Court or the Court of Federal Claims.18 The April 2026 firings—and the broader sequence of which they are part—lend renewed weight to that argument. When the same executive branch that prosecutes removal cases also possesses the authority to dismiss the judges who decide them, the resulting structural tension is difficult to reconcile with the appearance, and arguably the substance, of impartial adjudication.

Whether or not legislative reform of the kind the ABA has proposed is politically achievable in the near term, the events of the past sixteen months provide an empirical record that future reformers will not be able to ignore. The bench is being reshaped at a pace and with a degree of opacity that has no recent parallel, and the rulings in the Öztürk and Mahdawi cases are likely to be studied for years as concrete examples of the costs that such a reshaping imposes on the integrity of the system.

Conclusion

The April 2026 firings do not represent a new direction so much as an acceleration of an existing one. The administration’s approach to the immigration bench—marked by mass terminations, the absence of public rationale, the expansion of TIJ authority to include military and other federal-government lawyers, and a posture that treats the judges as policy instruments rather than independent adjudicators—has now produced a documented record of one hundred and thirteen removals over sixteen months. For respondents in removal proceedings, for the lawyers who represent them, and for the broader public interest in fair and orderly adjudication of cases involving life, liberty, and family unity, the implications are serious and ongoing. We will continue to track and report on developments at EOIR and in the federal courts as this situation unfolds.

  1. Kanishka Singh, US Fires More Immigration Judges, Including Two Who Blocked Deporting Pro-Palestinian Students, Reuters (Apr. 13, 2026).
  2. See Alexander J. Segal, Eight New York Immigration Judges Fired in Sudden EOIR Purge: A Dangerous New Phase in U.S. Immigration Adjudication, MyAttorneyUSA.com (Jan. 6, 2026).
  3. Press Release, Nat’l Ass’n of Immigr. Judges, Statement on Recent Terminations (Apr. 13, 2026); Singh, supra note 1.
  4. Singh, supra note 1; see also Trump Fires Judges Who Blocked Deportations of Student Activists Rümeysa Öztürk and Mohsen Mahdawi, Democracy Now! (Apr. 13, 2026).
  5. Trump Administration Order, In re Öztürk, Boston Immigr. Ct. (Jan. 29, 2026) (Patel, IJ) (terminating proceedings; finding DHS failed to sustain its burden of proof).
  6. Order Terminating Proceedings, In re Mahdawi, Chelmsford Immigr. Ct. (Feb. 2026) (Froes, IJ); Mohsen Mahdawi is a lawful permanent resident.
  7. Singh, supra note 1; Esmy Jimenez, Administration Fires 2 Immigration Judges Who Ruled Against Deporting Palestinian Rights Advocates, ABC News (Apr. 13, 2026).
  8. See, e.g., Khouri v. Wolf, 481 F. Supp. 3d 24 (D.D.C. 2020) (discussing immigration judges as employees of the Department of Justice subject to DOJ’s personnel authority); 8 C.F.R. § 1003.10.
  9. 8 U.S.C. § 1229a(b)(1) (statutory authority of the immigration judge to administer oaths, receive evidence, and issue orders); see also Matter of E-F-H-L-, 26 I. & N. Dec. 319 (BIA 2014) (right to a full evidentiary hearing on protection claims).
  10. See generally Decision, Doyle v. Dep’t of Justice, MSPB Docket No. (Mar. 2026) (interpreting Article II removal power as limiting statutory civil-service protections for immigration judges); see also Tania Nemer Compl., Nemer v. Bondi, No. 1:25-cv-_ (D.D.C. filed Dec. 2025) (challenging termination on Title VII and First Amendment grounds).
  11. See Press Release, The White House, Era of Amnesty Is Over: President Trump Restores Rule of Law to Immigration Court (Apr. 10, 2026).
  12. See Mathews v. Eldridge, 424 U.S. 319, 333 (1976) (procedural due process requires “the opportunity to be heard at a meaningful time and in a meaningful manner” (cleaned up); Reno v. Flores, 507 U.S. 292, 306 (1993).
  13. 8 C.F.R. § 1003.10(e); see Final Rule, Eligibility Requirements for Temporary Immigration Judges, 90 Fed. Reg. 41,883 (Aug. 28, 2025); Memorandum from Sec’y of Def., Detail of Up to 600 Military Lawyers as Temporary Immigration Judges (Aug. 27, 2025).
  14. See Alexander J. Segal, Up to 600 Military Lawyers to Serve as Temporary IJs, MyAttorneyUSA.com (Sept. 9, 2025).
  15. Inside the Trump Administration’s Unprecedented Purge of Immigration Judges, CNN (Oct. 6, 2025).
  16. Transactional Records Access Clearinghouse (TRAC), Immigration Court Asylum Decisions (Syracuse Univ., updated 2026).
  17. See, e.g., 8 C.F.R. § 1003.1(d)(7) (BIA referral and review authority); Matter of M-A-F-, 26 I. & N. Dec. 651 (BIA 2015).
  18. See ABA Model Code of Judicial Conduct, Canon 1 (independence and impartiality of the judiciary); ABA Comm’n on Immigr., Reforming the Immigration System: Proposals to Promote Independence, Fairness, Efficiency, and Professionalism in the Adjudication of Removal Cases (2010 & Suppl. 2019).