This amended complaint at law lays out, in muscular fashion, the manifold abuses of the Noem / Miller / Tangerine 2.0 regime -- attempted on a US holiday weekend (but impotently so). [It is specifically red-lined, for ease of comparison to the original filing, made on an emergency basis -- after midnight on the Saturday of Labor Day Weekend, 2025.]
. . .Plaintiffs are unaccompanied minors in Refugee Resettlement (“ORR”) custody whom Defendants have sought or are seeking to remove from the United States in clear violation of the unambiguous protections that Congress has provided them as vulnerable children. Defendants have unlawfully claimed the power to expel these children, in violation of the Trafficking Victims Protection Reauthorization Act of 2008, (“TVPRA”), the Immigration and Nationality Act, (“INA”), and the Constitution. Plaintiffs seek to represent a class of unaccompanied children who are or will be placed in ORR custody and who do not have a final order of removal or grant of voluntary departure by an immigration judge.
Recognizing their unique vulnerability, Congress has created a special statutory scheme to ensure that unaccompanied minors receive enhanced protection and care, including whenever the government seeks to remove them from the United States. Summary expulsion plainly violates this statutory scheme. . . .
Now you know. Stand tall. Speak up. Be unafraid. His time of fear mongering is coming to an end. These are your rights. Out.
नमस्ते
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