Ms. L. v. U.S. Immigration and Customs Enforcement et al

Filing 210

STATUS REPORT Joint Report by Greg Archambeault, Alex Azar, L. Francis Cissna, Pete Flores, Joseph Greene, Thomas Homan, Francis M. Jackson, Scott Lloyd, Adrian P. Macias, Hector A. Mancha Jr., Kevin K. McAleenan, Kirstjen Nielsen, Office of Refugee Resettlement, Jefferson Beauregard Sessions, III, U.S. Citizenship and Immigration Services, U.S. Customs and Border Protection, U.S. Department of Health and Human Services, U.S. Department of Homeland Security, U.S. Immigration and Customs Enforcement. (Fabian, Sarah) (aef).

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CHAD A. READLER
Acting Assistant Attorney General
SCOTT G. STEWART
Deputy Assistant Attorney General
WILLIAM C. PEACHEY
Director
Office of Immigration Litigation
WILLIAM C. SILVIS
Assistant Director
Office of Immigration Litigation
SARAH B. FABIAN
Senior Litigation Counsel
NICOLE MURLEY
Trial Attorney
Office of Immigration Litigation
U.S. Department of Justice
Box 868, Ben Franklin Station
Washington, DC 20442
Telephone: [phone]
Fax: [phone]

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15 ADAM L. BRAVERMAN
United States Attorney
16 SAMUEL W. BETTWY
17 Assistant U.S. Attorney
California Bar No. 94918
18 Office of the U.S. Attorney
19 880 Front Street, Room 6293
San Diego, CA 92101-8893
20 619-546-7125
21 619-546-7751 (fax)
22 Attorneys for Federal Respondents23 Defendants
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Lee Gelernt*
Judy Rabinovitz*
Anand Balakrishnan*
AMERICAN CIVIL LIBERTIES
UNION FOUNDATION
125 Broad St., 18th Floor
New York, NY 10004
T: [phone]
F: [phone]
[e-mail]
[e-mail]
[e-mail]
Bardis Vakili (SBN 247783)
ACLU FOUNDATION OF
SAN DIEGO & IMPERIAL
COUNTIES
P.O. Box 87131
San Diego, CA 92138-7131
T: [phone]
F: [phone]
[e-mail]
Stephen B. Kang (SBN 292280)
Spencer E. Amdur (SBN 320069)
AMERICAN CIVIL LIBERTIES
UNION FOUNDATION
39 Drumm Street
San Francisco, CA 94111
T: [phone]
F: [phone]
[e-mail]
[e-mail]
Attorneys for PetitionersPlaintiffs
*Admitted Pro Hac Vice

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA

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MS. L, et al.,

Case No. 18cv428 DMS MDD

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Petitioners-Plaintiffs,

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JOINT STATUS REPORT
vs.
U.S. IMMIGRATION AND
CUSTOMS ENFORCEMENT, et
al.,

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Respondents-Defendants.

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The Court ordered the parties to file a joint status report on August 30, 2018,

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14 in anticipation of the telephonic status conference scheduled for August 31, 2018, at
15 1:00 p.m. PST. The parties submit this joint status report in accordance with the
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Court’s instruction.
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DEFENDANTS’ POSITIONS
18 I.
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A. Update on. Reunifications
Defendants report on the current status of reunification with children ages 0

22 through 17 in the table below. The data presented in this section reflects approximate
23 numbers maintained by ORR at least as of August 27, 2018. These numbers are
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dynamic and continue to change as more reunifications or discharges occur. The
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26 table below follows the same format as that of the August 23, 2018 Joint Status
27 Report.
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Phase 1 Phase 2
(Under (5 and Total
5)
above)

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Description

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Total number of possible children of potential class
103
members originally identified
Discharged Children
Children discharged by being reunified with separated
61
parent
Children discharged under other appropriate
circumstances (these include discharges to other
sponsors [such as situations where the child’s separated 20
parent is not eligible for reunification] or children that
turned 18)
Total children discharged
81
Children Remaining in Care with ORR

2,551

2,654

1,876

1,937

200

220

2,076

2,157

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475

497

• Children still in care where further review shows
they were not separated from parents by DHS:

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47

52

1

166

167

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• Parent indicated desire against reunification
(includes a significant number of parents outside
the U.S.):

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• Adult presently outside the U.S.:

6

316

322

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• Adult in other federal, state, or local custody:

2

15

17

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• Adult red flag background check:

9

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35

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• Adult red flag case review – safety & well-being:

1

17

18

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• Adult red flag case review – parentage:

0

3

3

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11
12
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14

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Children remaining in care where the adult associated
with the child is not eligible for reunification or is not
available for discharge at this time:

The Court also requested updated information regarding reunification efforts
involving children in New York State.

Defendants have provided updated,

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24 aggregate information related to those children in their concurrent Joint Status
25 Report in the N.T.C. case.
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B. Reunification of Removed Class Members
Defendants report on the current status of reunification of removed class
members in the table below. The data presented in this section reflects approximate

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5 numbers maintained by ORR as of at least August 27, 2018, with an additional row
6 in Process 4 to reflect children in ORR care who have received orders of voluntary
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departure. These numbers are dynamic and continue to change as the reunification

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9 process moves forward.
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REUNIFICATION REPORTING METRIC
PROCESS
Children in ORR care with
STARTING
parents presently departed from
POPULATION
the U.S.

NO.

REPORTING
PARTY

322

Def’s.

PROCESS 1:
Children with no “red flags” for
Identify & Resolve safety or parentage
Safety/Parentage
Children with “red flags” for
Concerns
safety per background check
Children with “red flags” for
safety per case file review
Children with “red flags” for
parentage

316

Def’s.

4

Def’s.

0

Def’s.

2

Def’s.

322

Def’s.

318

Def’s.

0

Def’s.

322

Def’s.

PROCESS 2:
Establish Contact
with Parents in
Country of Origin

Children with parent contact
information identified
Children with parent contact
information identified and parents
actually contacted
Children with no parent contact
information/parent contact
information in development
Children with parent contact
information provided to ACLU by
Government

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PROCESS 3:
Determine
Parental Intention
for Minor

Children for whom ACLU has
communicated parental intent for
minor

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Pl’s.

PROCESS 4:
Resolve
Children in ORR care with orders
Immigration
Status of Minors to of voluntary departure
Allow
Reunification

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Def’s.

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8

Defendants will report additional information on Processes 4 and 5

9 (Transportation of Minors for Physical Reunification with Parents in Country of
10
Origin) as the reunification efforts continue.
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C. M.M.M. TRO Negotiations
As ordered by the Court, the parties continue to meet and confer on the issues

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set forth in the Court’s August 17 order, ECF No. 196. The parties request that they

16 be permitted a short extension until 3:00pm PST on Tuesday, September 4, to submit
17 a proposed briefing schedule if they cannot reach resolution.
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D. Information Sharing
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Plaintiffs have made numerous recent requests for additional data over the

21 past week. Defendants have prioritized responding to those requests related to the
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ongoing reunification process. For many of Plaintiffs’ requests, Plaintiffs seek data
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24 that they already have received. Therefore, Defendants also are working to provide
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Plaintiffs with more explanation about the data they already have in the hopes that

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this may obviate some of their requests. For the remainder of Plaintiffs’ requests,

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Defendants plan to respond as appropriate, or will meet and confer with Plaintiffs to

2 determine if the parties can reach agreement regarding these requests.
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E. Requests for Relief from M.M.M. TRO

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The government wishes to raise—and propose a solution to—an important,

6 recurring, but readily solvable challenge that it has been facing.
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In recent days, the government has seen an increasing number of children of

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9 Ms. L class members who wish to voluntarily depart the country so that the children
10 may reunify with their parents (who are outside of the United States). These children
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are subject to the M.M.M. TRO, which restrains the government from “removing

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13 from the United States” the children of Ms. L. class members. The TRO does not,
14 however, prohibit the departure of these children from the United States pursuant to
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an order of voluntary departure under 8 U.S.C. § 1229c, as such does not constitute

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17 a removal under the law. Under settled principles of immigration law, removal and
18 voluntary departure are different: the government acts to effectuate removal in
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accordance with a removal order; a voluntary departure simply means that an alien
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21 has been granted the entitlement to leave of their own accord without many of the
22 consequences associated with removal. The TRO currently limits the government’s
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ability to do the former; it does not bar class members or their children from doing
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Dozens of children—represented by individual counsel, on top of their

2 putative representation by M.M.M.—have been granted voluntary departure by
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immigration judges and have sought the government’s aid in departing. The

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5 government has, in turn, worked with counsel for the children to facilitate and pay
6 for travel back to their country of origin. The government has offered that assistance
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in harmony with the Court’s preliminary injunction and its directive to reunify.

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The government’s concern is that such assistance could give rise to an

10 erroneous claim that it is violating the M.M.M. TRO by “removing” a child from the
11

country. Although such a claim would be mistaken (the government would be

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13 assisting a voluntary departure, not effectuating a removal), the government has
14 taken an abundantly cautious approach to protect itself against that sort of a claim.
15

In particular, when an individual counsel for a child has come to the government for

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17 aid in facilitating a voluntary departure, government counsel has asked that counsel
18 contact M.M.M. counsel to obtain M.M.M. counsel’s agreement that the departure
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raises no concerns under the TRO.
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That approach worked moderately well (albeit inefficiently) when only a few
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22 children sought voluntary departure. With the sudden increase of such requests,
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however, it has become inefficient and unworkable because M.M.M. counsel have
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25 been unwilling or unable to provide prompt agreement, and have been unwilling to
26 agree to an efficient approach. On more than one occasion now, counsel for those
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children has been unable to obtain the necessary approvals from M.M.M. counsel for

2 the voluntary departure to go forward as scheduled, and ICE has had to cancel the
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departure against the child’s wishes, and reschedule after approval could be

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5 obtained. Government counsel asked M.M.M. counsel to agree that for these children
6 who take voluntary departure assisted by counsel, such approval is not necessary,
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but counsel for M.M.M. would not agree. As a result, the government finds itself

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9 negotiating between children and their counsel who seek the government’s
10 assistance in reunifying the child with a parent abroad, and counsel for M.M.M., who
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stands in the way of such reunification.

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Given these challenges and concerns, the government now proposes to the

14 Court a simple solution: The Court could simply clarify that where a child seeks
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and is granted voluntary departure by an immigration judge, assisted by counsel,

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17 ICE may facilitate that child’s voluntary departure for the purpose of reunification
18 with his or her parent in the child’s country of origin without obtaining the approval
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of M.M.M. counsel. As explained above, the TRO does not address voluntary
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21 departure. The government has coordinated with M.M.M. counsel out of an
22 abundance of caution. Now that the number of voluntary departure assistance
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requests has escalated, that approach has become untenable.
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Relatedly, in accordance with the reunification plan approved by this Court,
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26 the ACLU/Steering Committee recently submitted to Defendants documentation for
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a number of class members and their children that reflect the parents’ wishes that

2 their child be returned to the country of origin, and which includes confirmation
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from the ACLU/Steering Committee that counsel for the child has also confirmed

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5 that the child wishes to return. As above, while returning a child to the country of
6 origin in accordance with the reunification plan is also not removal under the law,
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the government seeks clarification from this Court that the M.M.M. TRO does not

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9 prevent the government from moving forward to reunify the child with his or her
10 parent abroad in this situation.
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II.

PLAINTIFFS’ POSITIONS
1.

Steering Committee Progress

Over the past week, the Steering Committee has made significant progress in
effectuating reunifications. It continues to reach removed parents and
representatives for their children who remain in the United States. The Steering
Committee has consulted with the Vera Institute of Justice and has identified the
vast majority of lawyers or advocates for each of the children with removed
parents currently in ORR custody 1. And, as further detailed below, the Steering
Committee has identified and confirmed to the Government the wishes of 43
parents with respect to reunification, and expects to deliver confirmed preferences
for many more in the coming week.
The Government reports that the accurate number of children in ORR
custody with removed parents was 343 as of August 23. For those children and
parents, the Steering Committee’s progress to date is as follows:
1

The Steering Committee notes that children in ORR custody appear to be
moving between facilities on occasion, which affects the identity of the designated
27 legal service provider.
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Removed parents identified by the Government (8/7, 8/10

343

and 8/24 lists)
• Parents for whom Committee has no phone number

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5

Steering Committee called phone number for parent (using

324

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Government-provided number or number otherwise

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obtained by Steering Committee)

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Steering Committee spoke to parent (either by phone or in

244

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person)
• Parents called and successfully reached

239

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3
4

10
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• Parents found through outreach by NGOs

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• Parents called and not reached (and not reached 80
through NGO efforts)

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o Phone number inoperable or ineffective

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o Phone calls ongoing

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Parents reached by phone or NGO outreach

244

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Reunified: confirmed reunifications in home country

2

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Ready for reunification: parent’s reunification wish

174

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confirmed to match child’s

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Preliminary indication of parent’s wishes for

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reunification

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Ongoing discussions w parent about reunification

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Preferences already communicated to government

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32

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The Steering Committee also continues to work with the Government to

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1 identify all children in ORR custody with removed parents, utilizing the significant
2 data the Steering Committee has compiled in order to ensure no child or parent is
3 overlooked in this process. On August 24, the Government produced an updated
4 list of children in ORR custody whose parents have been removed. On August 25,
5 the Government produced an updated list of removed parents who signed a Letter
6 of Designation on file with ORR, identifying a sponsor in the United States in
7 whose custody their child(ren) could be placed.
8

On August 26, the Steering Committee provided to the Government a list of

9 concerns that it had regarding discrepancies between the August 24 and 25 lists
10 that the Government provided and prior iterations of those lists. In addition, the
11 Steering Committee raised concerns about: (1) children whom the Steering
12 Committee believes to be in ORR shelters and whose parents the Steering
13 Committee believes to have been removed, but whose names do not appear on
14 prior lists of children in ORR custody produced by the Government; and (2)
15 inoperative parent phone numbers.
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On August 29, the Government responded to the Steering Committee’s

17 August 26 communication, setting forth explanations and additional information in
18 response to the Steering Committee’s questions. The August 29 communication
19 resolved certain of the Steering Committee’s concerns. A few issues remain to be
20 resolved, including:
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• Discrepancies between August 24 List of Children in ORR Custody with

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Removed Parents (“Aug. 24 ORR Custody/Removed Parents List”) and

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Prior Iterations of This List:

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o The Steering Committee reported to the Government that 70

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children who appeared on prior iterations of the Aug. 24 ORR

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Custody/Removed Parents List did not appear on the Aug. 24 ORR

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Custody/Removed Parents List.

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o The Government responds that the 70 children were removed from

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the Aug. 24 ORR Custody/Removed Parents List because either (1)

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they were discharged from ORR care, (2) their parents are no longer

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removed and are in custody in the United States, (3) HHS has since

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determined that the children were not separated from their parents

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by DHS, or (4) the cases are under review to determine if separation

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occurred.

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o Plaintiffs appreciate the Government’s response; however, Plaintiffs

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intend to further meet and confer with the Government regarding the

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circumstances of the children who have recently been discharged

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from ORR care, and to discuss how to proceed with those of these

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children whose parents are members of the Ms. L class.

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The Steering Committee previously reported its progress using the total

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number of 412 children in ORR care, based on the Government’s own data

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from August 7th and 10th.2

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2

As to this larger group of children with parents who were removed —
including the 70 that the Government reports are now no longer in ORR care —
the Steering Committee’s progress is reported below, so that the Court may
compare progress in the past week using the same baseline group. Certain
categories have changed slightly: the Government reported one additional child in
ORR care with a removed parent, which increases the 412 from August 23 to 413;
the “Parents for whom Committee has no phone number” category has changed
from reflecting parents for whom the Government did not provide a number to now
showing parents for whom there is no number provided by the Government and the
Steering Committee has not found a number through its own efforts.

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8/23 JSR

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Removed parents identified by the Government

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8/30 JSR

412

413

(8/7,8/10

25

(8/7,8/10,8/24

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2
3
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lists)
• Parents for whom Committee has no phone 41
number

lists)
33

371

380

Steering Committee spoke to parent (either by

231

279

phone or in person)
• Parents called and successfully reached

225

273

6

6

5

Steering Committee called phone number for

6

parent (using Government-provided number or

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one otherwise determined by Steering

8

Committee)

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10
11
12

• Parents found through outreach by NGOs

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• Parents called and not reached (and not 140
reached through NGO efforts)

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15
16

o Phone number
ineffective

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inoperable

or 38

o Phone calls ongoing

101
43

102

58

8/23 JSR

8/30 JSR

231

279

10

19

15

184

183

36

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25
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Parents reached by phone or NGO outreach
Reunified: confirmed reunifications in home
country
Ready for reunification: parent’s reunification
wish confirmed to match child’s
Preliminary indication of parent’s wishes for
reunification

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• Other Issues:

2

The Steering Committee also reported to the Government regarding children

3 whom the Steering Committee’s constituents report to be in ORR custody but who
4 do not appear on any Government list produced to date; concerns regarding the
5 procedure for investigating or confirming inoperative phone numbers for parents;
6 and other issues related to information exchange between the Steering Committee
7 and the Government. The Steering Committee and the Government have
8 committed to meet and confer on these issues and are hopeful that they will be able
9 to resolve them without the Court’s intervention. If there are any outstanding
10 issues that cannot be resolved, the parties will bring these issues to the Court’s
11 attention.
12

Finally, as discussed in the last status report, the Steering Committee

13 continues to receive indications that some parents may have been coerced or
14 misled by U.S. government actions that deprived the parents of their right to seek
15 asylum. These incidents include parents who were told that they needed to accept
16 removal and not pursue asylum in order to be reunited with their children, and
17 parents who were required to sign documents they did not understand, in languages
18 they do not speak, that had the effect of waiving their right to seek asylum. The
19 Steering Committee continues to investigate these cases.
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21
22
23
24

Ongoing discussions w parent about

23

40

0

45

reunification
Preferences already communicated to
government

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B.

Information Sharing

2

At Defendants’ request, Plaintiffs have begun sending consolidated sets of

3 information requests concerning the Class members’ reunification processes on
4 Mondays and Thursdays of every week. Most importantly, Plaintiffs have asked
5 Defendants to provide, on an ongoing basis, a complete list of Class members that
6 corresponds to the numbers they report in their weekly status reports.
7

Up until this point, Defendants have provided multiple lists of parents and

8 children in various categories, e.g. parents who have allegedly waived their
9 reunification rights; parents who have been reunited in family detention. However,
10 the numbers of Class members on these lists frequently contain significant
11 discrepancies with the numbers in the weekly status reports, which makes it difficult
12 to rely on these lists when advising Class members and their advocates.
13

Defendants compile and synthesize Class member information in order to

14 provide updated statistics to the Court every week. Providing that same information
15 to Plaintiffs would likely alleviate this confusion, since Plaintiffs would simply
16 receive the information and data underlying Defendants’ disclosures to the Court.
17 Plaintiffs have proposed, and ask for the Court to order, that Defendants provide this
18 information every Friday (the day after the filing of the status reports).
19

For the numbers in last week’s JSR, Plaintiffs still await an updated list of (1)

20 1,923 reunifications; (2) 203 other appropriate discharges; (3) several categories for
21 the 528 children still in ORR care, including children that the Government believes
22 were not separated from parents, adults in other custody (federal, state, local), and
23 all three categories of “red flags” that the Government contends prevent
24 reunification.
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1 DATED: August 30, 2018

Respectfully submitted,

2

/s/ Lee Gelernt
Lee Gelernt*
Judy Rabinovitz*
Anand Balakrishnan*
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION
125 Broad St., 18th Floor
New York, NY 10004
T: [phone]
F: [phone]
[e-mail]
[e-mail]
[e-mail]

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Bardis Vakili (SBN 247783)
ACLU FOUNDATION OF SAN DIEGO
& IMPERIAL COUNTIES
P.O. Box 87131
San Diego, CA 92138-7131
T: [phone]
F: [phone]
[e-mail]

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Stephen B. Kang (SBN 292280)
Spencer E. Amdur (SBN 320069)
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION
39 Drumm Street
San Francisco, CA 94111
T: [phone]
F: [phone]
[e-mail]
[e-mail]
Attorneys for Petitioners-Plaintiffs
*Admitted Pro Hac Vice

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CHAD A. READLER
Acting Assistant Attorney General
SCOTT G. STEWART
Deputy Assistant Attorney General
WILLIAM C. PEACHEY
Director
WILLIAM C. SILVIS
Assistant Director

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/s/ Sarah B. Fabian
SARAH B. FABIAN
Senior Litigation Counsel
NICOLE MURLEY
Trial Attorney
Office of Immigration Litigation
Civil Division
U.S. Department of Justice
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
[phone]
[phone] (facsimile)
[e-mail]
ADAM L. BRAVERMAN
United States Attorney
SAMUEL W. BETTWY
Assistant U.S. Attorney
Attorneys for Respondents-Defendants

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