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THIS WEEK IN BRIEF:

• Kilmar Abrego Garcia’s Case and Nayib Bukele’s Washington visit: A high-stakes legal battle continues between the federal courts and the Trump administration over the case of a Salvadoran man who was wrongly deported and sent to a notorious mega-prison in his home country. During an Oval Office visit, the country’s authoritarian-trending president struck a defiant tone alongside President Trump, calling into question the administration’s compliance with a Supreme Court requirement that it “facilitate” the return of Kilmar Abrego Garcia. Sen. Chris Van Hollen (D-Maryland) met Abrego Garcia briefly during a visit to El Salvador.
• The Alien Enemies Act: Evidence continues to show that most of the 238 Venezuelan men sent to the Salvadoran mega-prison on March 15 faced no allegations of criminal activity or gang ties. A judge who had sought to stop their removal is now considering whether to hold Trump administration officials in contempt of court.
• The Roosevelt Reservation and other military developments: The White House has declared that a 20-yard fringe of territory along the border in California, Arizona, and New Mexico is now the equivalent of a “military installation.” This raises important questions about the role of the U.S. military on U.S. soil. As is widely expected, these questions will deepen if the administration invokes the Insurrection Act of 1807.
• March migration data show further declines: With 7,181 Border Patrol apprehensions, March 2025 was one of the quietest months at the U.S.-Mexico border since the 1960s. The main reason is the Trump administration’s shutdown of asylum access at the border. The ratio of uniformed personnel at the border to March migrant apprehensions is now about 4.6 to 1.
• Mass deportation and the coming “reconciliation” funding bill: Congress is edging closer to considering a massive budget bill that would multiply the U.S. government’s ability to deport undocumented migrants on an enormous scale. The Trump administration’s unstated goal appears to be 1 million deportations during its first year, which seems unlikely. Meanwhile, the administration is rapidly undoing documented statuses granted by the Biden administration.

THE FULL UPDATE:

Kilmar Abrego Garcia’s Case and Nayib Bukele’s Washington visit

A scene in the Oval Office

• The authoritarian-trending president of El Salvador, Nayib Bukele, visited the White House on April 14. During an Oval Office visit, reporters asked Bukele whether he would be willing to release and return to the United States Kilmar Abrego Garcia. A 29-year-old Salvadoran apprentice sheet-metal worker protected from removal by an immigration judge’s order, Abrego Garcia is being held in a Salvadoran government “mega-prison” after Immigration and Customs Enforcement (ICE) sent him there in mid-March, after detaining him in Maryland.
• “The question is preposterous. How can I smuggle a terrorist into the United States? I don’t have the power to return him to the United States,” Bukele said. “Of course I’m not going to do it.” “They’d love to have a criminal released into our country… these are sick people,” added President Donald Trump. (A transcript is here.)
• Abrego Garcia had “withholding of removal,” a status specifying that, for his safety, he could not be removed to El Salvador. In court declarations, the government has recognized that Abrego Garcia’s removal from the United States was an error.
• “Latin America experts scoffed at the idea that Mr. Bukele, whose government has ordered mass arrests and seized control of the country’s courts, would suggest he could not return one man—if he wanted to,” the New York Times reported, citing, among others, WOLA Central America Program Director Ana María Méndez Dardón.
• While cameras rolled as the two presidents entered the Oval Office, Trump told Bukele, “The homegrowns are next. You got to build about five more places,” raising the possibility that the administration will try to send U.S. citizens to facilities like the Center for Confinement of Terrorism (CECOT), a notoriously austere and massive facility that Bukele had built as part of a sweeping, abuse-ridden anti-gang crackdown. “Yeah, we’ve got space,” Bukele replied.

Defying the Supreme Court?

• On April 10, the U.S. Supreme Court unanimously ruled that the Trump administration must “facilitate” Abrego García’s return to the United States, where his wife and three children are U.S. citizens. This ruling softened an order from the district judge presiding over Abrego Garcia’s case, Paula Xinis, who had required the administration to return him to the United States by 11:59 pm on April 7.
• The Oval Office episode, many observers have noted, met no reasonable definition of “facilitating.”
• “We won a case 9-0,” White House Deputy Chief of Staff Stephen Miller said during the Oval Office meeting. “And people like CNN are portraying it as a loss, as usual, because they want foreign terrorists in the country who kidnap women and children.”
• At his newsletter, Steve Vladeck of the Georgetown University Law Center wrote that the administration is defying the Supreme Court “in spirit” but not “directly.” The Court’s April 10 ruling “left a little bit of wiggle room—by (1) not mandating Abrego Garcia’s return; (2) not setting any deadline for any next steps; and (3) using malleable language (“facilitate”) to describe the government’s underlying obligation.”
• “To understand what’s going on in these few sentences [of the Supreme Court’s decision], you have to place yourself in the shoes of the most tedious law professor you know,” explained legal journalist Jay Willis. “‘Facilitate’ generally refers to making something easier or more likely, and often connotes good-faith effort. ‘Effectuate,’ on the other hand, usually implies the accomplishment of a specific result.”
• The administration is arguing that its definition of “facilitating” only governs activity on U.S. soil: that it cannot ask Bukele to free Abrego Garcia from El Salvador’s Center for Confinement of Terrorism (CECOT) prison, even though the State Department is paying the Salvadoran government a reported $6 million for a year to hold citizens of El Salvador and Venezuela sent there since March 15.

Sen. Van Hollen visits El Salvador

• Sen. Chris Van Hollen (D-Maryland), who counts Abrego Garcia’s family as constituents, visited El Salvador on April 16 and 17. There, the Bukele government prevented him from visiting the CECOT facility to check on Abrego García’s welfare. (A day before, the Salvadoran government permitted a delegation of Republican members of the House of Representatives to visit, and to post social media photos, from the CECOT.)
• Late on the 17th, Van Hollen and Bukele almost simultaneously posted photos of the Senator meeting with Abrego Garcia, wearing civilian clothes and a baseball cap over his shaved head, in the restaurant of San Salvador’s Sheraton Hotel. As this Update goes to publication, we have little information about what was said or how the meeting happened. Bukele tweeted, however: “Now that he’s been confirmed healthy, he gets the honor of staying in El Salvador’s custody.”

The administration’s narrative

• Trump administration officials continue to insist that Abrego Garcia is a member of MS-13, a violent Salvadoran gang that the Trump administration added to the State Department’s list of foreign terrorist organizations in February.
• The only proof that they have presented was discussion at Abrego Garcia’s immigration proceedings, which relied on an anonymous source and a Prince George’s County Police Department worksheet, filled out in 2019 when, eight years after arriving in the United States at age 16, police arrested him for loitering as he sought day labor in a suburban Washington, DC Home Depot parking lot. It remains Abrego Garcia’s only arrest in 14 years in the United States.
• The administration has presented no other evidence, and we have since learned via the New Republic’s Greg Sargent that the worksheet—which relied heavily on how Abrego Garcia was attired when arrested—was filled out by a police officer who was suspended from the force two weeks later, and later indicted, for “giving confidential information about a case to a sex worker.”
• Aaron Reichlin-Melnick of the American Immigration Council posted a helpful graphical timeline of Abrego Garcia’s arrest and immigration case.
• That has not stopped senior officials from calling Abrego Garcia a “terrorist” and heaping new, unfounded allegations on top of that: that he is involved in human trafficking, drug trafficking, and was arrested with “ rolls of cash.” (Actually, he was arrested while wearing a sweatshirt depicting rolls of cash.)
• “He was not mistakenly sent to El Salvador,” White House Deputy Chief of Staff Miller said of Abrego Garcia on Fox News. “This was the right person sent to the right place.”

Tension in the District Court

• After the Supreme Court’s April 10 decision, Judge Xinis—whose earlier ruling the Court generally upheld— ordered the Trump administration to provide daily updates on “1) the current physical location and custodial status of Abrego Garcia; (2) what steps, if any, Defendants have taken to facilitate Abrego Garcia’s immediate return to the United States; and (3) what additional steps Defendants will take, and when, to facilitate his return.”
• These updates have offered no new or valuable information, routinely arriving late in the day and generally echoing the defiant tone of Bukele’s White House meeting. They did confirm, at least, that Abrego Garcia is alive and in the CECOT.
• “DHS [the Department of Homeland Security] does not have authority to forcibly extract an alien from the domestic custody of a foreign sovereign nation,” the acting general counsel at DHS, Joseph Mazzara, stated in one of those updates, which were consistently brief and were down to two sentences in length, and identical, by April 16 and April 17.
• At an April 15 hearing in her Greenbelt, Maryland court, Judge Xinis ordered the administration to answer questions submitted by Abrego Garcia’s attorney. Xinis will require three knowledgeable government witnesses to participate in sworn depositions over the next two weeks. “It’s going to be two weeks of intense discovery,” Xinis said. “There are no business hours while we do this… Cancel vacations, cancel other appointments.”
• Noting that the administration has “done nothing at all,” a written order following the hearing stated “at a minimum,” it is required “to take the steps available to them toward aiding, assisting, or making easier Abrego Garcia’s release from custody in El Salvador.”
• When the administration sought to appeal this order, the 4th Circuit turned them down with a very strongly worded 3-0 decision. “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,” read the opinion authored by Judge Harvie Wilkinson, a Reagan appointee considered one of the most prominent conservatives on the bench. “This should be shocking not only to judges, but to the intuitive sense of liberty that Americans far removed from courthouses still hold dear.”
• Democratic legislators, including ranking Senate Foreign Relations Committee member Jeanne Shaheen (D-New Hampshire) and eight House members, have sent letters to the administration demanding more information about the agreement it reached with the Salvadoran government.
• ProPublica noted that members of Congress have been getting zero response from ICE when they inquire about other operations that may be harming constituents in their districts.
• Xinis hinted at a possible finding that administration officials are in contempt of court due to non-cooperation.
• The administration fired Erez Reuveni, a veteran Justice Department lawyer who had been candid in earlier hearings with Judge Xinis, recognizing that Abrego Garcia had been deported in error and lamenting that the administration had not provided him with information to answer her questions.

Analyses

• “Abrego Garcia’s case is as big a test case for the rule of law during the Trump administration as anything else we’ve seen,” Georgetown’s Vladeck wrote, in part “because, if the government can wrongfully remove someone like Abrego Garcia to a Salvadoran prison without any consequence, it can do that to any of us—alleged gang member or not; Salvadoran or not; citizen or not.”
• “This administration is rapidly constructing a legal framework that would allow it to abruptly disappear anyone, including natural-born U.S. citizens, to a foreign prison forever, for any reason it chooses, or no reason at all,” wrote Mark Joseph Stern at Slate.
• “This is the beginning of an American policy of state terror, and it has to be identified as such to be stopped,” wrote Yale University professor Timothy Snyder, author of On Tyranny.
• “Donald Trump has turned what was originally an immigration question into the most fundamental of questions about the American constitution,” wrote journalist Garrett Graff.
• “If the Trump administration can defy court orders with impunity, and Congress is unwilling to act, there is no reason for it to respect the constitutional rights of American citizens either,” wrote Adam Serwer at the Atlantic.
• Constitutional scholars consulted by CBS News overwhelmingly concluded that U.S. law, including habeas corpus guarantees and the Eighth Amendment prohibition on cruel and unusual punishment, does not allow the transfer of U.S. citizens to foreign prisons.
• Vladeck told Rolling Stone, “You can’t deport U.S. citizens. There’s no emergency exception, there’s no special wartime authority, there’s no secret clause. You just can’t deport citizens.” Citing two unnamed sources, the publication reported that internal Trump administration “conversations have revolved around attempting to denaturalize American citizens and deport them to other countries, including El Salvador.”
• Officials’ profligate use of the “terrorist” label to describe Abrego Garcia and other migrants is drawing concern. “We have people who love America, like the president, like his cabinet, like the directors of his agencies, who want to protect Americans. And then there is the other side, that is on the side of the cartel members, on the side of the illegal aliens, on the side of the terrorists,” Sebastian Gorka, the White House senior director for counterterrorism, told the right-leaning NewsMax network. “And you have to ask yourself, are they technically aiding and abetting them? Because aiding and abetting criminals and terrorists is a crime in federal statute.”

The Alien Enemies Act

Due process and the March 15 temporary restraining order

• A New York Times feature found that most of the 238 Venezuelan men sent to El Salvador’s CECOT prison on March 15 lacked any evidence linking them to gang activity. This echoes similar, earlier findings of CBS News’s “60 Minutes,” Bloomberg, and the Salvadoran human rights defense NGO Cristosal. Most, particularly the reported 137 detained and deported under the Alien Enemies Act, received no due process: little or no opportunity to defend themselves or challenge accusations of ties to the “Tren de Aragua” criminal group.
• In a 5-4 ruling on April 7, the Supreme Court found that while lower-court challenges continue, the Trump administration could apply the Alien Enemies Act, a 1798 wartime statute, to detain and deport—including to the CECOT—Venezuelan citizens suspected of ties to the Tren de Aragua (TdA). The administration added TdA to the State Department’s list of international terrorist organizations in February.
• However, the Court ruled that those subject to the Alien Enemies Act should be notified and permitted to file writs of habeas corpus, requiring them to be brought before a court to determine if their detention is lawful. This did not happen with the 137 people whisked out of the country in a matter of hours on March 15.
• The March 15 removals to El Salvador took place even though, while planes were in the air, a Washington, DC federal judge had issued a temporary restraining order suspending use of the Alien Enemies Act. That judge, Chief District Court Judge James Boasberg, found on April 16 that “probable cause” exists to hold Trump administration officials in criminal contempt of court for ignoring his order, which the Supreme Court struck down on April 7.
• Boasberg will pursue his contempt investigations, the New York Times explained, unless the administration allows those sent to El Salvador “a chance to challenge their removal.” The judge laid this out in a 46-page opinion on April 16.

Habeas petitions and enforced disappearance

• In Nevada, a federal judge halted use of the Alien Enemies Act against Adrian Arturo Viloria Aviles, a 29-year-old citizen of Venezuela.
• Attorneys are filing habeas petitions in Washington, DC, for some people who are now in the CECOT. The American Immigration Council, National Immigration Project, and the Center for Constitutional Rights filed a petition for Edicson David Quintero Chacón, “a 28-year-old carpenter, fisherman, and father of two young children.”
• As this Update goes to publication, alarms are sounding about Alien Enemies Act removal notifications issued to Venezuelan people detained in the Bluebonnet Detention Facility in Anson, Texas. Courts in this part of Texas have not agreed to suspend Alien Enemies Act removals.
• How the administration has shipped detainees to El Salvador “fits every definition of an enforced disappearance under international law,” Denise Gilman of the University of Texas School of Law immigration clinic told the Huffington Post.
• An April 11 Human Rights Watch statement concurred that what has happened to the Venezuelan men in the CECOT meets the definition of “enforced disappearances and arbitrary detention.”
• A Venezuelan woman living in Chicago, “YD,” told local public radio that she caught a glimpse of her partner Yeison Rodrigo Jaimes-Rincon, the father of her infant child, in the background of a video being recorded by a Rolex-wearing Homeland Security Secretary Kristi Noem.
• The Trump administration has delivered Kilmar Abrego Garcia and about 287 other men from El Salvador and Venezuela to the CECOT prison since March 15. Since then, they have been entirely out of contact with the outside world. “Writs of habeas corpus have been presented to El Salvador’s Supreme Court on behalf of the deportees, to no avail,” the New York Times reported. “Many of the men have American lawyers, who say they have received no information on their clients from the American or the Salvadoran authorities—even whether they are alive.”
• Available information indicates that the Trump administration has sent 288 people to the CECOT so far:
  • 137 Venezuelans under the Alien Enemies Act on March 15.101 other Venezuelans with final removal orders on March 15.(CBS News obtained and published the names of the above 238 people. The names of those below this list are, for the most part, unknown.)23 Salvadorans with final removal orders, also on March 15, including Abrego Garcia and prominent MS-13 leader César Humberto López Larios, alias “Greñas.” 10 Salvadorans and 7 Venezuelans with final removal orders on March 30.
  • 10 Salvadorans and Venezuelans with final removal orders sent from the Guantánamo Bay Naval Station in Cuba on April 12. How many were Salvadoran and how many were Venezuelan is unknown.
• Stephen Miller, the top architect of the Trump administration’s immigration policies, told reporters, “There’s no upper limit to the agreement. We’re going to continue to send foreign terrorist aliens to El Salvador, as well as to many other countries.”
• Politico reported that Erik Prince, the former CEO of the highly controversial private security and mercenary firm Blackwater, has been presenting a plan to designate part of the CECOT as U.S. territory—as often happens with diplomatic or military facilities overseas—and transfer as many as 100,000 U.S. prisoners there. That population would include U.S. citizens. (CNN had reported about a similar Prince proposal, involving sending immigrants with criminal records to El Salvador, a few days earlier.) “It’s unclear how seriously the White House is considering the plan by Prince,” the brother of the first Trump administration’s education secretary, Betsy DeVos. Politico had reported in February that Prince was also pitching a $25 billion plan to handle logistics to deport 12 million migrants within two years.

The Roosevelt Reservation and other military developments

A 20-yard-wide military facility

• An April 11 White House memorandum placed under U.S. military control a 20-yard fringe of territory along much of the border in California, Arizona, and New Mexico. This land, it reads, is now to be considered a “National Defense Area.”
• This narrow stretch of land, known as the “Roosevelt Reservation,” has been federal government property since 1907, during the term of President Theodore Roosevelt. “It was meant to, you know, make sure that right along the U.S.-Mexico border, there weren’t going to be buildings,” Associated Press defense reporter Tara Copp told Arizona Public Media.
• The Department of the Interior transferred “administrative jurisdiction” of “approximately 109,651 acres” of federal land to the Department of the Army for three years.
• The change could mean that people who set foot in, or pass through, this strip of land, mainly migrants, could be charged with the crime of trespassing on a military installation.
• It could also involve soldiers holding migrants inside the fringe of land until Border Patrol or other authorities can apprehend them. The Posse Comitatus Act of 1878 prohibits soldiers from arresting civilians under normal, non-emergency circumstances, so such “holding” of migrants would be a legal gray area.
• Under the “military purpose doctrine,” the Brennan Center’s Elizabeth Goitien explained, troops may carry out arrests despite Posse Comitatus if the arrests happen within the context of a mission whose primary purpose is not law enforcement.
• A legal review is ongoing, the Associated Press reported.
• In 2019, the first Trump administration had placed the Roosevelt Reservation under Defense Department control to help pay for border wall building. The move allowed Trump, employing emergency authorities to transfer funds, to enable the Defense budget to pay for wall-building by categorizing it as construction on a military facility. Unlike the April 11 order, this earlier transfer did not contemplate allowing military personnel to potentially detain or “hold” people in the border fringe zone.
• “In the coming weeks, this administration will add more than 90 miles in the state of Texas,” which is not part of the Roosevelt Reservation, White House Press Secretary Karoline Leavitt said on April 15.
• The president of Mexico, Claudia Sheinbaum, sent a diplomatic note to the United States voicing concern about this new escalation of the U.S. military presence along both countries’ border. “We don’t know if it’s to continue building the wall or what the objective would be. But in any case, what we always ask for is respect and coordination,” Sheinbaum told reporters on April 16.
• “Deploying military assets to the border, during a record time of low crossing numbers, is a misguided and wasteful use of military resources and taxpayer dollars,” said Rep. Gabe Vásquez (D), whose district encompasses New Mexico’s entire border with Mexico and is where the “National Defense Area” plan will first be rolled out.
• The office of Arizona Gov. Katie Hobbs, a Democrat, has not indicated opposition to the military plan, but wants to see more details.

Insurrection Act

• A January 20 White House executive order gave the secretaries of Defense and Homeland Security 90 days to recommend whether to invoke the Insurrection Act of 1807 to provide the active-duty military an even greater role at the U.S.-Mexico border. Those 90 days end on April 20.
• This very old law grants significant discretion to deploy the military domestically when the President determines that “unlawful obstructions, combinations, or assemblages, or rebellion against the authority of the United States make it impracticable to enforce the laws of the United States by the ordinary course of judicial proceedings.” It is an emergency exception to the Posse Comitatus Act. The Insurrection Act has been invoked, usually on a very small scale, just six times in the past sixty years.
• Steve Vladeck of the Georgetown University Law Center published an April 14 overview of the Insurrection Act’s history and associated risks, concluding that “the political checks that historically warded against dubious invocations of the Insurrection Act are not going to stop President Trump from invoking it—perhaps as early as the end of this week.”

Guantánamo

• CBS News published a leaked copy of a March 7 memorandum of understanding between the Departments of Homeland Security and Defense (DOD) to govern migrant detention operations at the Guantánamo Bay Naval Station in Cuba. Reporter Camilo Montoya-Gálvez, who obtained the report, noted that it allows for DHS and DOD to hold non-criminal detainees at the notorious facility “despite a vow to hold ‘the worst’ offenders at the naval base.” They merely need to have final deportation orders and be suspected of a “nexus” with organized crime or gang activity.
• The memo also specifies that migrants detained at the naval base are formally under ICE custody, and that children will not be sent there. (In early February, DHS Secretary Kristi Noem “would not directly answer” questions about whether families would be held there, Reuters had reported.) People are not to be kept at the base for more than 180 days.
• A Defense Department spokesperson told Montoya-Gálvez that, as of April 16, the U.S. government was holding 42 migrants at Guantánamo. Thirty-two were labeled “low risk” and held at the base’s Migrant Operations Center, while 10 considered “high risk” were at Camp VI, the military-run prison built after September 11, 2001 to hold suspected terrorists.
• “I hear there are 41 immigration detainees held at Guantánamo Bay this morning, and the staff has been reduced to 760, including ICE contractors,” New York Times reporter Carol Rosenberg tweeted on April 12. This indicates a significant drawdown. “Most are soldiers and Marines. The Army general from Texas who set up the operation has left, and a colonel is in charge.”

Other military stories

• Two U.S. Marines assigned to the border mission died, and another was seriously injured, in a vehicle accident in Santa Teresa, New Mexico, west of El Paso. They were in a civilian vehicle at the time.
• Off the coast of the border between San Diego and Tijuana, the U.S.S. Stockdale replaced the U.S.S. Spruance as the Trump administration continues to deploy U.S. Navy guided-missile destroyers as part of the border security mission.
• Washington Post defense reporter Dan Lamothe, who first broke the “Roosevelt Range” story in March, published an overview of the rapidly growing U.S. military presence at the border, focusing primarily on Colorado-based brigades operating Stryker armored combat vehicles in Arizona, New Mexico, and far west Texas.

March migration data

Border numbers decline

• Customs and Border Protection (CBP) reported a new reduction in the number of migrants its agents and officers encountered at the U.S.-Mexico border in March 2025, down slightly from February and remaining at levels probably not seen since the 1960s.
• The reason is the Trump administration’s new restrictions that essentially eliminate the right to seek asylum at the border, along with migrants’ and smugglers’ caution about crossing as security-force deployments and a “mass deportation” effort get rolled out. The Trump administration’s asylum restrictions, issued in a January 20 executive order, are the subject of active litigation.
• CBP, which incorporates Border Patrol agents operating between ports of entry (official border crossings) and Field Operations officers operating at the ports of entry, took 11,017 people into custody last month, down from 11,709 in February, 61,447 in January, and 189,359 in March 2024.

Data table

• Seventy-six percent of migrants encountered in February were citizens of Mexico, more than double the 34 percent share that Mexican people represented since October 2019.
• Between the ports of entry in March, CBP’s Border Patrol component apprehended 7,181 people, down from 8,346 in February, 29,105 in January, and 137,473 in March 2024.

Data table

• March’s total, 232 per day, is the fewest monthly Border Patrol apprehensions in the more than 25 years for which monthly data are available.
• Border Patrol agents released three (3) migrants from custody in March, up from a revised zero in February, 2,558 in January, and 78,496 in March 2024.

• Migrants encountered at the ports of entry remained few, as the Trump administration ceased use of the CBP One smartphone app to help asylum seekers make appointments. CBP’s port of entry encounters totaled 3,836 people or 124 per day in March, up from 3,363 or 120 per day in February, 32,343 in January, and 51,886 in March 2024.
• The vast majority of migrants encountered at ports of entry were citizens of Mexico. Only 267 in March and 366 in February were from elsewhere.

Data table

• Eighty-six percent of migrants encountered in January were single adults, 8 percent were family unit members (parents and children), and 6 percent were unaccompanied children. That is vastly different than the proportions between October 2023 and January 2025 (57 percent single adults, 37 percent family unit members, 5 percent unaccompanied children).
• The main reason for the shift from families to single adults is the unavailability of asylum: parents with children were more likely to turn themselves in to seek protection than to attempt to evade Border Patrol.
• Of the nine geographic sectors into which Border Patrol divides the border, El Paso, which includes far west Texas and all of New Mexico, was the number one sector for migrant apprehensions for the second straight month. The El Paso sector’s 1,627 apprehensions were 23 percent of the March total.
• All told, combining Border Patrol agents with active-duty and National Guard military personnel—but not including CBP officers or Texas state police with border enforcement missions—there will soon be 4.6 uniformed personnel at the U.S.-Mexico border for every migrant whom Border Patrol apprehended there in March.

Darién Gap decline

• Panama released data showing a further drop in northbound migration through the Darién Gap, a treacherous 60-plus-mile jungle route through which 1.07 million people passed between 2022 and 2024.
• Just 194 people passed through the Darién route in February, the fewest in any month since September 2020. This is down from 408 in February and 36,841 in March 2024. Panama measured 1,204,298 people migrating through the Darién Gap between 2021 and 2024.
• Of the 194 in March, 33 percent (64 people) were citizens of Venezuela, and 11 percent were from Cameroon and Nepal (22 each).

Data table

• Reporting from the town of Villa Caleta on the Panamanian end of the Darién trail, the Associated Press found that the drop in migrants passing through has meant the abrupt end of a local economic boom.

Inverse migration flows

• On the Colombian side of the Darién Gap, Elizabeth Dickinson of the International Crisis Group told the AP, “The Gulf Clan, the criminal group that profited from the northward migration, now scouts the coast to see if it can make money off migrants going the other way.”
• Colombia’s government reported that between January 1 and March 15, it detected 3,485 migrants “in reverse irregular migration flow,” an average of 47 people per day, mostly arriving on a southbound sea route around the Darién Gap. The Niskanen Center’s Gil Guerra reported 4,513 people crossing into Colombia from Panama in February and March. Both figures are greater than the 2,813 people Colombia detected departing northbound into the Darién Gap.
• About 200 Venezuelan migrants protested outside the Siglo 21 detention center in Tapachula, near Mexico’s southern border with Guatemala, “to ask authorities to help them return to their country because they no longer want to be in Mexico or reach the United States,” reported La Jornada.

Mass deportation and the coming “reconciliation” funding bill

A massive legislative outlay coming

• The pace of ICE detentions and deportations from the U.S. interior has increased relatively modestly since January 20. The Trump administration’s deportation campaign won’t become truly massive until the Republican-majority Congress passes a gigantic funding increase, explained an analysis from Nick Miroff at the Atlantic.
• Using the budget reconciliation process, which allows bills to pass with a simple majority–no Democratic votes needed—this yet-to-be-introduced legislation could provide up to $175 billion in new funding to DHS. “To put those sums in perspective, the entire annual budget of ICE is about $9 billion,” Miroff recalled. It could bring “the kind of social and demographic transformation of the United States that immigration hard-liners have long fantasized about achieving.”
• Congress may begin considering the bill when it comes back from Easter recess, but it is difficult to speculate with clarity about a timetable for passage.
• As noted in WOLA’s April 11 Border Update, the New York Times revealed an ICE request for proposals for contractors to expand its detention capacity, which anticipates spending up to a staggering $45 billion over two years, six times ICE’s current detention budget.
• ProPublica revealed that ICE is awarding Deployed Resources, a company that builds and manages large tent facilities, a contract worth up to $3.8 billion to operate a tent detention camp at Fort Bliss, in El Paso, Texas. ICE’s entire nationwide 2024 detention budget was $3.43 billion.

Technology contracts

• Some contracting seeks to take advantage of data technologies. Citing contracting records, Miroff found that ICE has just added $30 million to a contract with the data-mining company Palantir “to deploy new Targeting and Enforcement Prioritization, Self-Deportation Tracking, and Immigration Lifecycle Process capabilities.” 404 Media reported that the contract addition augments ICE’s Investigative Case Management system, which “connects to other DHS and federal databases, including SEVIA which contains records about people who are inside the country on a student visa; real-time maps associated with ICE’s location tracking tools; and other information from other federal agencies.”
• 404 Media also reported on CBP’s use of AI-enhanced products like “Fivecast ONYX” and “DataMinr” to scour the internet for “people of interest.”
• A New York Times investigation explored how Geo Group, the United States’ largest private prison operator and a major ICE contractor, has become central to the Trump administration’s mass deportation plans through surveillance technology developed in recent years for ICE’s Alternatives to Detention program. “Those products are now aiding President Trump’s deportation efforts by providing the whereabouts of unauthorized immigrants.”

1 million deportations in a year?

• “Four current and former federal officials with direct knowledge of the plans” told the Washington Post that the “1 million” figure often comes up in internal conversations. The administration appears determined to deport 1 million people in its first year, more than double the Obama administration’s record of 434,015 removals in 2013 (removals of people entirely from the U.S. interior peaked at 188,422 in 2011, according to the Migration Policy Institute).
• Miroff obtained ICE data indicating that the agency deported 18,500 people in March. This is down from March 2024 (23,100), when ICE had more recent border-crossers to deport.
• Tracking all this is harder because the Trump administration has halted publication of the DHS Office of Homeland Security Statistics’ monthly “Immigration Enforcement and Legal Processes” report. That time series ends in November 2024.
• A million is apparently the unofficial goal even though the administration will not have the infrastructure or staffing for such an escalation until well after a “reconciliation” bill provides the resources to pay for it.
• To reach this number, “the administration is negotiating with as many as 30 countries” to get them to accept deportations of third countries’ citizens, two officials told the Post.
• About 1.45 million people in the United States have final removal orders, but most of the rest of the undocumented population is likely able to challenge their removal in immigration court.
• “The courts may slow deportations to some extent, but ‘much more’ than a million is certainly achievable when money is no obstacle,” David Bier of the Cato Institute, a critic of Trump immigration policies, told the Washington Examiner.

Removing statuses

• Miroff noted that the Trump administration’s moves to undo Temporary Protected Statuses (TPS) and Biden-era humanitarian paroles could end up revoking the documentation of “about 2.5 million people whose names, addresses, and other personal data are already known to DHS and ICE.”
• DHS sent an email to many—perhaps most or all—of the more than 900,000 people granted parole when they arrived at border ports of entry using the Biden-era CBP One app. The message instructs them that their parole has been canceled and they must leave the United States “immediately.” The New York Times reported that “at least 10 immigration lawyers, most of whom are U.S. citizens, said that they, too, had received the notices urging them to depart the country.”
• A federal judge in Boston blocked the administration from canceling the humanitarian parole that the Biden administration had offered to about 532,000 citizens of Cuba, Haiti, Nicaragua, and Venezuela. The parole was a two-year status that the Biden administration did not intend to renew, but the Trump administration sought to cancel it early, on April 24.
• Immigration judges, who work for the Department of Justice, were issued an April 11 Department memo instructing them “to scour their dockets for asylum cases they can deny without holding a full hearing,” reported Bloomberg.

New Mexico disappearances

• The New Yorker’s Jonathan Blitzer investigated an early March ICE operation in New Mexico, which resulted in the arrest of 48 people whose whereabouts remain alarmingly unknown. No detainees were identified, their locations remain undisclosed, it’s unclear if they have access to counsel, and the agencies have rebuffed inquiries even from Senate offices. The Trump administration’s near-total shutdown of DHS internal oversight bodies, especially the Office of Civil Rights and Civil Liberties and the Office of the Immigration Detention Ombudsman, has made it harder to get basic information.

Other “mass deportation” developments

• White House pressure and criticism “has deflated morale among immigration officers who are working at full tilt but increasingly skeptical they can meet the lofty goals,” three officials told the Post.
• DHS Secretary Kristi Noem’s fondness for posting videos during deportation operations “is rankling ICE officials, who grumble that her desire for publicity interfered with the operations of the agency she is in charge of running,” the Wall Street Journal reported.
• Politico reported that the Department of Government Efficiency (“DOGE”), the government-slashing agency informally headed by billionaire Elon Musk, has embarked on an immigration initiative headed by an old friend of the world’s wealthiest man. “A specialized DOGE immigration task force” has “embedded engineers and staffers across nearly every nook of the Department of Homeland Security” and is seeking to revoke paroles, terminate visas, and perhaps later to alter the asylum adjudication process.

Other News

• The administration plans to build a 17-mile-long “wall” of buoys in the middle of the Rio Grande in south Texas, the Washington Examiner reported. The project would dwarf the 1,000-foot string of buoys that the state of Texas installed in Eagle Pass in 2023. There, Texas argued that the floating barrier did not interfere with the river’s navigability, a key element of a water treaty with Mexico. It could be more of an issue further downstream, where the administration plans to build the longer barrier.
• CBP is seeking bidders for a contract to build 24.7 miles of border wall between Nogales and Naco, Arizona, an area that the Arizona Daily Star calls “a known biodiversity hotspot.”
• A report from ProPublica and the Texas Tribune found a stark disparity between the billions of dollars that government is pouring into policing and immigration enforcement along the U.S.-Mexico border, and the widespread poverty in which many border region residents live. Some communities lack even clean drinking water and access to hospitals.
• The Miami Herald and El Nuevo Herald reported on growing disenchantment with the Trump administration among the south Florida city’s Cuban-American and Venezuelan-American communities. Cuban-American healthcare billionaire Mike Fernández wrote a strongly worded letter “urging Cuban-American Republican leaders in Miami to stand up to President Donald Trump’s immigration offensive and speak out, or ‘make way for others who can.’” Adelys Ferro, executive director of the Venezuelan American Caucus, said of Secretary of State and former Florida senator Marco Rubio, “It’s devastating to see that the same Marco Rubio who championed TPS for Venezuelans—who pushed for protection and stood with our community—is now the one turning his back on us.”
• A New York Times Magazine feature examined how the White House’s penchant for sharing “deportation cartoons” on its social media accounts indicates “an especially dark turn” in its content strategy.
• Doctors Without Borders reported from an encampment in Mexico City on the experience of “extracontinental migrants”—people from Africa, Asia, or Europe—now stranded in Mexico’s capital after the Trump administration shut down access to the U.S. asylum system at the border.
• 44% of respondents to a Meganálisis poll of Venezuelans inside Venezuela said they are considering emigrating, “as everyday life in the country continues to unravel,” the Miami Herald reported. But now, with the U.S. border shut to asylum seekers, respondents are unsure where they can go.