Immigration Law Essay 139 Harv. L. Rev. 1560

Keys to the Kingdom: Immigration Control and the Accretion of Executive Power


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Introduction

In his campaign for the presidency in 2024, then-candidate Donald Trump focused particular attention on immigration policy.1 Differentiating his proposed approach from that of the Biden Administration,2 Trump promised that if he were elected, he would “close the border” to migrants entering without authorization.3 In the interior of the country, he pledged to oversee “the largest deportation operation in the history of our country.”4

One year in, the Trump Administration claims victory on both counts.5 In describing the southern border, the Trump Administration points to reports of a sharp decline in encounters between Border Patrol agents and unauthorized entrants.6 Removals from the interior also have increased substantially.7 The Administration claims that more than 675,000 individuals were “deport[ed]” and that another 2.2 million individuals departed the United States in the first year of President Trump’s term.8

This Essay analyzes the means that the Trump Administration has used to achieve its ends. Certain elements of the Trump Administration’s immigration policies differ in intensity or focus rather than in kind from the policies of past administrations. Past U.S. presidential administrations have relied on racial profiling in interior immigration enforcement,9 have used the threat of immigration detention to deter migrants from attempting to enter the country and to encourage their departure,10 and have detained immigrants (sometimes for extended periods of time) to avoid their release into the country during the pendency of their administrative proceedings.11 Every President from Ronald Reagan onward has relied upon Immigration and Nationality Act12 (INA) section 212(f)13 to bar certain foreign nationals otherwise qualified to enter the United States from doing so.14 Since the 1990s (and sporadically in the decades before), every presidential administration, regardless of party affiliation, has overseen the deportations of tens of thousands of individuals per year.15 Families have been separated, sometimes forever, under these policies.16

All of these things continue to be true under President Trump. But the continuities in immigration enforcement strategies are vastly outstripped by the differences.17 Even when the Administration is using familiar tools, such as racial profiling,18 immigration detention,19 and entry bans,20 it is doing so in ways that look and feel like substantial breaks with practices of presidential administrations in recent history.21

This Essay explores the novel immigration policy choices this Administration has made in order to effectuate its agenda and explains the broader implications of these choices for U.S. democracy. Part I explores four broad subcategories of change. Section I.A describes the significant expansion of immigration policing and arrests in the interior of the United States, unguided by meaningful enforcement priorities, and undergirded by a heavy reliance on racial profiling and violence. Section I.B discusses the Administration’s expansive use of coercive immigration detention, including as against longtime and lawful U.S. residents. Section I.C tackles the Administration’s exertion of substantial political control over immigration adjudication, combined with significant gamesmanship in federal judicial proceedings. Section I.D illuminates the Administration’s discriminatory reconfiguration (and outright elimination) of lawful immigration pathways.

Part II evaluates the broader context and meaning of these policy shifts. Section II.A explains how these changes in immigration policy are part of a larger break with the nation’s formal post–Civil Rights era rejection of racially discriminatory laws. Section II.B discusses how these changes are part of a broader reconfiguration of executive authority through the erosion of separation of powers principles. Section II.C demonstrates that recent developments in immigration policy are a part of the Trump Administration’s broader rejection of a rule-based system of international law. This Essay concludes with some reflections on how developments in immigration policy during the first year of the second Trump Administration constitute both a microcosm and a staging ground for broader antidemocratic shifts in the Trump Administration’s governance strategy.

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Footnotes
  1. ^ Priscilla Alvarez & Phil Mattingly, Mass Detention and Returning Migrants to Mexico: Donald Trump’s Plans on Immigration Are Coming into Focus, CNN (Nov. 16, 2024, at 13:30 ET), https://www.cnn.com/2024/11/16/politics/donald-trump-immigration-plans [https://perma.cc/9TUM-Z539] (“President-elect Donald Trump made immigration a central element of his 2024 presidential campaign . . . .”).

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  2. ^ President Joseph R. Biden’s policies included “narrow[ing] the categories of unauthorized immigrants targeted for arrest” and removal from the interior of the country; stopping construction on the border wall; suspending the first Trump Administration’s policy requiring asylum seekers at the southern border to remain in Mexico until their U.S. asylum hearing date; and exempting unaccompanied minor children from the Title 42 entry ban enacted by President Trump during the COVID-19 pandemic (a ban that was otherwise continued by President Biden through May 2023). Christopher Flavelle, How Biden Ignored Warnings and Lost Americans’ Faith in Immigration, N.Y. Times (Dec. 7, 2025), https://www.nytimes.com/2025/12/07/us/politics/biden-immigration-trump.html [https://perma.cc/ENJ6-LHBM]. For a historically and demographically grounded analysis of Biden-era immigration policies, see Muzaffar Chishti et al., Biden’s Mixed Immigration Legacy: Border Challenges Overshadowed Modernization Advances, Migration Pol’y Inst. (Dec. 10, 2024), https://www.migrationpolicy.org/article/biden-immigration-legacy [https://perma.cc/NC2F-7EDL].

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  3. ^ Promises Made, Promises Kept — One Year Later, White House (Nov. 5, 2025) [hereinafter Promises Made, Promises Kept] (quoting President Trump), https://www.whitehouse.gov/articles/2025/11/promises-made-promises-kept-one-year-later [https://perma.cc/C585-8927] (“We will close the border. We will stop the invasion of illegals into our country.”).

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  4. ^ Id. (quoting President Trump).

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  5. ^ Id.

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  6. ^ Id. (citing Jeff Abbott et al., For the First Time in Decades, The US-Mexico Border Is Silent. Here’s Why, azcentral (June 9, 2025, at 05:01 MT), https://www.azcentral.com/story/news/politics/immigration/2025/06/09/us-mexico-border-immigrants/83824441007 [https://perma.cc/6ZUR-GG38]). The Administration relies on data compiled by U.S. Customs and Border Protection (CBP), which supports the Administration’s claim. See, e.g., id. (citing Avery Lotz & Stef W. Kight, Border Crossings Plunge to Lowest Levels in Decades: New Data, Axios (Mar. 4, 2025), https://www.axios.com/2025/03/04/illegal-border-crossings-february-decline-trump [https://perma.cc/Z6MK-TL2L] (sourcing data from CBP)). For graphic visualizations of CBP data pertaining to encounters, drug seizures, and other border enforcement metrics, see Visualizations of Data Related to U.S. Border Governance and Migration, WOLA Border Oversight, https://borderoversight.org/category/infographics [https://perma.cc/8YUC-78QY]. To my knowledge, there is no third-party verification of this data.

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  7. ^ Graeme Blair & David Hausman, Deportation Data Project: Immigration Enforcement in the First Nine Months of the Second Trump Administration 1 (2026), https://deportationdata.org/analysis/immigration-enforcement-first-nine-months-trump.pdf [https://perma.cc/Y6TA-CUPK] (finding that in the first nine months of the second Trump Administration, “[i]nterior deportations surged to more than four and a half times their pre-inauguration level”).

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  8. ^ DHS Sets the Stage for Another Historic, Record-Breaking Year Under President Trump, DHS (Jan. 20, 2026), https://www.dhs.gov/news/2026/01/20/dhs-sets-stage-another-historic-recordbreaking-year-under-president-trump [https://perma.cc/RBK5-M2B8]. The government statistics regarding removal are higher than those of independent tracking services like the Transactional Records Access Clearinghouse (TRAC), which recorded the entry of 500,972 deportation orders from February to December 2025. Outcomes of Immigration Court Proceedings: By State, Court, Hearing Location, Year, Charge, Nationality, Language, Age, and More, TRAC: Immigr., https://tracreports.org/phptools/immigration/closure [https://perma.cc/EC3W-NX8D] (choose “Removals” for Outcome Type; “All-Removal Order” for Immigration Court State). Data collected by the Deportation Data Project, as analyzed by the New York Times, also suggest slightly lower numbers. Raj Saha et al., Inside the Deportation Machine, N.Y. Times (Dec. 22, 2025), https://www.nytimes.com/interactive/2025/12/22/us/trump-immigration-deportation-network-ice-arrests.html [https://perma.cc/DN9F-3F56] (“An analysis of less detailed data on deportations shows that their pace accelerated after July; as of December, ICE is on track to deport about 390,000 people in Mr. Trump’s first year.”). The same reporting recorded an average monthly volume of about 23,000 removals during the first half of 2025. Id. (showing a monthly average of 11,400 removals pursuant to standard procedures and 11,500 expedited removals). I have not found any independent data sources to verify the Administration’s claimed number of “self-deportations,” DHS, supra, though it is surely the case that these numbers have increased when compared to prior administrations, see Blair & Hausman, supra note 7, at 1, for reasons discussed in greater detail below.

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  9. ^ See, e.g., United States v. Brignoni-Ponce, 422 U.S. 873, 877 (1975); United States v. Martinez-Fuerte, 428 U.S. 543, 563 & n.16 (1976); United States v. Manzo-Jurado, 457 F.3d 928, 935 (9th Cir. 2006).

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  10. ^ See Stephanie J. Silverman & Amy Nethery, Understanding Immigration Detention and Its Human Impact, in Immigration Detention: The Migration of a Policy and Its Human Impact 1, 5 (Amy Nethery & Stephanie J. Silverman eds., 2015) (describing how the U.S. government used immigration detention to deter Haitian migration starting in the 1990s with the detention center at Guantanamo); Maureen A. Sweeney et al., Detention as Deterrent: Denying Justice to Immigrants and Asylum Seekers, 36 Geo. Immigr. L.J. 291, 294–97 (2021) (describing the increase of detention under both the Obama and first Trump Administrations, id. at 294–96, and the “deter[rence]” effect such “prolonged detention” creates, id. at 297).

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  11. ^ See Demore v. Kim, 538 U.S. 510, 513 (2003); Jennings v. Rodriguez, 138 S. Ct. 830, 836 (2018); Ahilan Arulanantham, Four Years Frozen in ICE, HuffPost (Apr. 8, 2012, at 13:48 ET), https://www.huffpost.com/entry/immigrant-detention-mental-illness_b_1260363 [https://perma.cc/Y9LN-2VD3] (discussing the case of Jose Franco, who was held in immigration detention for four years); see also Anil Kalhan, Rethinking Immigration Detention, 110 Colum. L. Rev. Sidebar 42, 45–46 (2010) (describing “extended periods” of detention, id. at 45); César Cuauhtémoc García Hernández, Immigration Imprisonment’s Failures, 36 Immigr. & Nat’y L. Rev. 37, 38–39 (2015) (explaining the traditional justifications for detention pending removal proceedings: “flight risk, public safety threat, [and] deterrence,” id. at 39).

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  12. ^ Pub. L. No. 82-414, 66 Stat. 163 (1952) (codified as amended in scattered sections of 8 U.S.C.).

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  13. ^ 8 U.S.C. § 1182(a)(4).

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  14. ^ Ben Harrington & Theresa A. Reiss, Cong. Rsch. Serv., LSB10458, Presidential Actions to Exclude Aliens Under INA § 212(f) 2 (2020) (explaining that “[s]ince 1981, every President has invoked § 212(f) at least once” “to authorize Department of State regulations restricting alien entry”); see, e.g., Proclamation No. 10,773, 89 Fed. Reg. 48487, 48490–91 (June 3, 2024) (President Biden relying on § 212(f) to suspend and limit “entry of any noncitizen into the United States across the southern border,” id. at 48491); see also Trump v. Hawaii, 138 S. Ct. 2392, 2403 (2018) (describing President Trump’s use of this authority during his first term to institute the so-called “Muslim ban,” id. at 2417).

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  15. ^ See 1991–NOW: Deportation Nation, Mapping Deportations, https://mappingdeportations.com/timeline-1991-now [https://perma.cc/U6FB-VNHB].

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  16. ^ See generally Beth C. Caldwell, Deported Americans: Life After Deportation to Mexico (2019) (chronicling the experiences of individuals removed from the United States and separated from their U.S.-based family members).

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  17. ^ See, e.g., Nadine Yousif, Six Big Immigration Changes Under Trump — And Their Impact So Far, BBC (Jan. 27, 2025), https://www.bbc.com/news/articles/clyn2p8x2eyo [https://perma.cc/A5J2-PAG2] (explaining major changes in immigration policy under the second Trump Administration, including mass deportations, fortification of the United States-Mexico border, and cancellations of existing CBP appointments).

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  18. ^ See Noem v. Vasquez Perdomo, 146 S. Ct. 1, 3 (2025) (Kavanaugh, J., concurring in the grant of the application for stay).

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  19. ^ See Am. Immigr. Council, Immigration Detention Expansion in Trump’s Second Term 4 (2026), https://www.americanimmigrationcouncil.org/wp-content/uploads/2026/01/immigration-detention-report.pdf [https://perma.cc/SQ4R-CT8L]. Immigration detention is also being deployed in punitive ways. See Note, Protecting Noncitizens’ Liberty When the Executive Seeks to Punish, 139 Harv. L. Rev. 753, 773–74 (2026) (analyzing the use of “Alligator Alcatraz” as a form of punishment, id. at 773).

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  20. ^ Proclamation No. 10,998, 90 Fed. Reg. 59717, 59719–20 (Dec. 16, 2025).

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  21. ^ Am. Immigr. Council, Mass Deportation: Analyzing the Trump Administration’s Attacks on Immigrants, Democracy, and America 40 (2025), https://www.americanimmigrationcouncil.org/wp-content/uploads/2025/07/mass_deportation_trump_attacks_democracy.pdf [https://perma.cc/GR79-5YVG] (explaining how “the first six months of the Trump administration’s enforcement agenda is unprecedented”).

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