Case: Maria L. v. Noem

1:25-cv-13471 | U.S. District Court for the District of Massachusetts

Filed Date: Nov. 20, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

This case challenges the Department of Homeland Security’s revival and mass imposition of civil penalties—totaling up to $1.8 million per person—on noncitizens who allegedly failed to depart the United States. On November 20, 2025, two individuals—Maria L. and Nancy M.—and the Immigrant Legal Resource Center filed this class action in the District of Massachusetts challenging the Biden-rescinded but newly reinstated DHS civil-fine program under 8 U.S.C. §§ 1229c and 1324d. The complaint alleged…

This case challenges the Department of Homeland Security’s revival and mass imposition of civil penalties—totaling up to $1.8 million per person—on noncitizens who allegedly failed to depart the United States.

On November 20, 2025, two individuals—Maria L. and Nancy M.—and the Immigrant Legal Resource Center filed this class action in the District of Massachusetts challenging the Biden-rescinded but newly reinstated DHS civil-fine program under 8 U.S.C. §§ 1229c and 1324d. The complaint alleged that soon after President Trump’s second inauguration, DHS, ICE, CBP, DOJ, and EOIR began issuing thousands of civil penalties against noncitizens who had remained in the United States after a voluntary-departure deadline or removal order—without assessing whether their failure to depart was “willful” or “voluntary,” as the statutes require.

The plaintiffs alleged that, beginning in early 2025, ICE issued roughly 10,000 fines based on boilerplate allegations and without individualized evaluation, sometimes at the statutory maximum of $998 per day, resulting in debts of hundreds of thousands to $1.8 million per person. DHS concurrently announced plans to garnish wages, seize savings and assets, and refer debts to the Treasury for collection. The complaint asserted that plaintiffs had been charged despite actively pursuing lawful forms of relief, including humanitarian protection and family-based immigration benefits.

On June 27, 2025, DHS and DOJ issued an interim final rule (IFR)—without notice and comment—that replaced long-standing civil-penalty procedures with a new process designed to impose penalties “swiftly and at scale.” Plaintiffs contended that the IFR unlawfully restricted the time to respond, eliminated interviews, allowed service by regular mail despite known delivery failures, and assigned adjudication to any “immigration officer,” including personnel with no relevant training. They argued that the IFR reversed decades of practice, ignored reliance interests, and created an unreasonably high risk of erroneous deprivation of property.

Plaintiffs asserted seven causes of action, including: (1) violation of the Excessive Fines Clause due to financial penalties they characterized as grossly disproportionate; (2) violation of the Seventh Amendment, because civil penalties historically required jury adjudication; (3) violation of procedural due process under the Fifth Amendment; (4) failure to conduct APA notice-and-comment rulemaking; (5) issuance of an arbitrary and capricious rule; and (6–7) unlawfully imposing penalties without statutorily required individualized findings of willfulness or voluntariness. They sought class certification for all individuals fined since January 20, 2025 (and subclasses for § 1324d fines and post-IFR fines), vacatur of the IFR, vacatur of all penalties, declaratory and injunctive relief, and attorneys’ fees.

The case remains ongoing.

Summary Authors

Jack Buckfire (12/15/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/71938107/parties/maria-l-v-noem/


Attorney for Plaintiff

Chen, Joy A. (Massachusetts)

Henley, Evan (Massachusetts)

L., Maria (Massachusetts)

M., Nancy (Massachusetts)

Moore, Charles Barrera (Massachusetts)

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Documents in the Clearinghouse

Document
1

1:25-cv-13471

Class Action Complaint for Vacatur, Declaratory Relief, and Injunctive Relief

Nov. 20, 2025

Nov. 20, 2025

Complaint

Docket

See docket on RECAP: https://www.courtlistener.com/docket/71938107/maria-l-v-noem/

Last updated Jan. 11, 2026, 12:36 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against All Defendants Filing fee: $ 405, receipt number AMADC-11369761 (Fee Status: Filing Fee paid), filed by Immigrant Legal Resource Center, Maria L., Nancy M.. (Attachments: # 1 Civil Cover Sheet, # 2 Category Form)(Moore, Charles) (Entered: 11/20/2025)

1 Civil Cover Sheet

View on RECAP

2 Category Form

View on PACER

Nov. 20, 2025

Nov. 20, 2025

Clearinghouse

Notice of Case Assignment

Nov. 20, 2025

Nov. 20, 2025

2

ELECTRONIC NOTICE of Case Assignment. Judge George A. OToole, Jr assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge M. Page Kelley. (SEC) (Entered: 11/20/2025)

Nov. 20, 2025

Nov. 20, 2025

3

Summons Issued as to Pamela Bondi, Executive Office of Immigration Review, Todd Lyons, Daren Margolin, Kristi Noem, Rodney Scott, U.S Department of Homeland Security, U.S. Customs and Border Protection, U.S. Department of Justice (DOJ), U.S. Immigration and Customs Enforcement (ICE). Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (FGD) (Entered: 11/20/2025)

Nov. 20, 2025

Nov. 20, 2025

4

MOTION for Leave to Proceed Under Pseudonyms by Immigrant Legal Resource Center, Maria L., Nancy M. (Moore, Charles) Modified on 11/24/2025: Memo in support, affidavit and proposed order have been removed and correctly refiled as a separate entry. Please see entry 5 . (FGD) (Entered: 11/24/2025)

Nov. 24, 2025

Nov. 24, 2025

5

MEMORANDUM in Support re 4 MOTION for Leave to Proceed Under Pseudonyms filed by Immigrant Legal Resource Center, Maria L., Nancy M.. (Attachments: # 1 Affidavit of Alina Das, # 2 Text of Proposed Order). (FGD) (Entered: 11/24/2025)

Nov. 24, 2025

Nov. 24, 2025

6

NOTICE of Appearance by Joy A. Chen on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Chen, Joy) (Entered: 11/24/2025)

Nov. 24, 2025

Nov. 24, 2025

7

NOTICE of Appearance by Evan Henley on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Henley, Evan) (Entered: 11/26/2025)

Nov. 26, 2025

Nov. 26, 2025

8

MOTION for Leave to Appear Pro Hac Vice for admission of Hasan Shafiqullah, Mariam Elbakr, Shelby Leighton, Leila Nasrolahi, Alina Das, and David Bennion Filing fee: $ 750, receipt number AMADC-11391882 by Immigrant Legal Resource Center, Maria L., Nancy M..(Moore, Charles) (Entered: 12/02/2025)

Dec. 2, 2025

Dec. 2, 2025

9

MOTION for Leave to Appear Pro Hac Vice for admission of Richard Caldarone, Addison Thompson, Stephen Rees, and Ranganath Sudarshan Filing fee: $ 500, receipt number AMADC-11391903 by Immigrant Legal Resource Center, Maria L., Nancy M..(Moore, Charles) (Entered: 12/02/2025)

Dec. 2, 2025

Dec. 2, 2025

10

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 8 Motion for Leave to Appear Pro Hac Vice Added Hasan Shafiqullah, Mariam Elbakr, Shelby Leighton, Leila Nasrolahi, Alina Das, and David Bennion. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (FGD) (Entered: 12/03/2025)

Dec. 3, 2025

Dec. 3, 2025

11

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 9 Motion for Leave to Appear Pro Hac Vice Added Richard Caldarone, Addison Thompson, Stephen Rees, and Ranganath Sudarshan. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number under ADDITIONAL FILER INFORMATION on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (FGD) (Entered: 12/03/2025)

Dec. 3, 2025

Dec. 3, 2025

12

NOTICE of Appearance by Shelby Hannah Leighton on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Leighton, Shelby) (Entered: 12/03/2025)

Dec. 3, 2025

Dec. 3, 2025

13

NOTICE of Appearance by Hasan Shafiqullah on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Shafiqullah, Hasan) (Entered: 12/03/2025)

Dec. 3, 2025

Dec. 3, 2025

14

NOTICE of Appearance by Ranganath Sudarshan on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Sudarshan, Ranganath) (Entered: 12/03/2025)

Dec. 3, 2025

Dec. 3, 2025

15

NOTICE of Appearance by Addison Baker Thompson, Jr on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Thompson, Addison) (Entered: 12/03/2025)

Dec. 3, 2025

Dec. 3, 2025

16

NOTICE of Appearance by Stephen Rees on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Rees, Stephen) (Entered: 12/03/2025)

Dec. 3, 2025

Dec. 3, 2025

Order on Motion for Leave to Appear

Dec. 3, 2025

Dec. 3, 2025

17

NOTICE of Appearance by Mariam Elbakr on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Elbakr, Mariam) (Entered: 12/04/2025)

Dec. 4, 2025

Dec. 4, 2025

18

NOTICE of Appearance by Leila Nicole Nasrolahi on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Nasrolahi, Leila) (Entered: 12/05/2025)

Dec. 5, 2025

Dec. 5, 2025

19

MOTION to Stay Agency Action by Immigrant Legal Resource Center, Maria L., Nancy M..(Moore, Charles) (Entered: 12/09/2025)

Dec. 9, 2025

Dec. 9, 2025

RECAP
20

MEMORANDUM in Support re 19 MOTION to Stay Agency Action filed by Immigrant Legal Resource Center, Maria L., Nancy M.. (Attachments: # 1 Declaration of Maria L, # 2 Declaration of Nancy M, # 3 Declaration of Ian Head, # 4 Declaration of Alison Kamhi, # 5 Proposed Order)(Moore, Charles) (Entered: 12/09/2025)

Dec. 9, 2025

Dec. 9, 2025

21

MOTION to Certify Class by Immigrant Legal Resource Center, Maria L., Nancy M..(Moore, Charles) (Entered: 12/09/2025)

Dec. 9, 2025

Dec. 9, 2025

RECAP
22

MEMORANDUM in Support re 21 MOTION to Certify Class filed by Immigrant Legal Resource Center, Maria L., Nancy M.. (Attachments: # 1 Declaration of Maria L, # 2 Declaration of Nancy M, # 3 Declaration of Ian Head, # 4 Declaration of Charles Moore, # 5 Declaration of Hasan Shafiqullah, # 6 Declaration of Richard Caldarone, # 7 Declaration of Alina Das, # 8 Declaration of David Bennion, # 9 Declaration of Ranganath Sudarshan, # 10 Proposed Order)(Moore, Charles) (Entered: 12/09/2025)

Dec. 9, 2025

Dec. 9, 2025

23

MOTION for Leave to File Under Seal and Ex Parte by Immigrant Legal Resource Center, Maria L., Nancy M..(Moore, Charles) (Entered: 12/09/2025)

Dec. 9, 2025

Dec. 9, 2025

25

NOTICE of Appearance by David C. Bennion on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Bennion, David) (Entered: 12/10/2025)

Dec. 10, 2025

Dec. 10, 2025

26

NOTICE of Appearance by Richard Caldarone on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Caldarone, Richard) (Entered: 12/11/2025)

Dec. 11, 2025

Dec. 11, 2025

27

Joint MOTION for Extension of Time to File Response/Reply as to 21 MOTION to Certify Class, 19 MOTION to Stay Agency Action, PARTIES JOINT MOTION FOR BRIEFING SCHEDULE by Immigrant Legal Resource Center, Maria L., Nancy M..(Moore, Charles) (Entered: 12/11/2025)

Dec. 11, 2025

Dec. 11, 2025

RECAP
28

NOTICE of Appearance by Alexander Severance on behalf of Pamela Bondi, Executive Office of Immigration Review, Todd Lyons, Daren Margolin, Kristi Noem, Rodney Scott, U.S Department of Homeland Security, U.S. Customs and Border Protection, U.S. Department of Justice (DOJ), U.S. Immigration and Customs Enforcement (ICE) (Severance, Alexander) (Entered: 12/16/2025)

Dec. 16, 2025

Dec. 16, 2025

29

NOTICE of Appearance by Alina Das on behalf of Immigrant Legal Resource Center, Maria L., Nancy M. (Das, Alina) (Entered: 12/22/2025)

Dec. 22, 2025

Dec. 22, 2025

30

MOTION for Protective Order by Immigrant Legal Resource Center, Maria L., Nancy M.. (Attachments: # 1 Proposed Protective Order)(Moore, Charles) (Entered: 12/26/2025)

1 Proposed Protective Order

View on RECAP

Dec. 26, 2025

Dec. 26, 2025

RECAP
31

Judge George A. OToole, Jr: ELECTRONIC ORDER entered GRANTING 27 Joint MOTION for Extension of Time to File Response/Reply as to 21 MOTION to Certify Class, 19 MOTION to Stay Agency Action, PARTIES JOINT MOTION FOR BRIEFING SCHEDULE. Responses due by 1/6/2026; Replies due by 1/16/2026;Reply briefs in further support of the motions, each not to exceed ten pages. (FGD) (Entered: 12/29/2025)

Dec. 29, 2025

Dec. 29, 2025

Order on Motion for Extension of Time to File Response/Reply

Dec. 29, 2025

Dec. 29, 2025

32

MEMORANDUM in Opposition re 19 MOTION to Stay Agency Action filed by Pamela Bondi, Executive Office of Immigration Review, Todd Lyons, Daren Margolin, Kristi Noem, Rodney Scott, U.S Department of Homeland Security, U.S. Customs and Border Protection, U.S. Department of Justice (DOJ), U.S. Immigration and Customs Enforcement (ICE). (Severance, Alexander) (Entered: 01/06/2026)

Jan. 6, 2026

Jan. 6, 2026

RECAP
33

MEMORANDUM in Opposition re 21 MOTION to Certify Class filed by Pamela Bondi, Executive Office of Immigration Review, Todd Lyons, Daren Margolin, Kristi Noem, Rodney Scott, U.S Department of Homeland Security, U.S. Customs and Border Protection, U.S. Department of Justice (DOJ), U.S. Immigration and Customs Enforcement (ICE). (Severance, Alexander) (Entered: 01/06/2026)

Jan. 6, 2026

Jan. 6, 2026

34

Emergency MOTION for a Temporary Restraining Order and Stay of Detention and Removal by Immigrant Legal Resource Center, Maria L., Nancy M..(Moore, Charles). Modified on 1/8/2026: Updated docketing event and docket text. (FGD) (Main Document 34 replaced on 1/8/2026, with corrected PDF.) (FGD) (Entered: 01/07/2026)

Jan. 7, 2026

Jan. 7, 2026

RECAP
35

MEMORANDUM in Support re 34 Emergency MOTION for a Temporary Restraining Order and Stay of Detention and Removal filed by Immigrant Legal Resource Center, Maria L., Nancy M.. (Attachments: # 1 Declaration in Support of Motion to Stay and Temporary Restraining Order, # 2 Proposed Order)(Moore, Charles) (Main Document 35, 35-1 and 35-2 replaced on 1/8/2026, with correct title PDFs). (FGD) (Additional attachment(s) added on 1/8/2026: # 3 SEALED Ex Parte Unredacted Declaration) (FGD). (Entered: 01/07/2026)

1 Declaration in Support of Motion to Stay and Temporary Restraining Order

View on PACER

2 Proposed Order

View on RECAP

Jan. 7, 2026

Jan. 7, 2026

36

MOTION to Seal Declaration in Support of Motion to Stay and Temporary Restraining Order by Immigrant Legal Resource Center, Maria L., Nancy M..(Moore, Charles) (Main Document 36 replaced on 1/8/2026, with correct title PDF) (FGD). (Entered: 01/07/2026)

Jan. 7, 2026

Jan. 7, 2026

RECAP
37

Judge Myong J. Joun: ELECTRONIC ORDER entered. Plaintiffs have filed an Emergency Motion for a Temporary Restraining Order to Stay Detention and Deportation of Plaintiffs Maria L. and Nancy M. Doc. No. 34 . Given the urgent nature of the motion, Defendants are directed to respond to the motion by 3:00 p.m. on 1/9/26. Plaintiffs' Motion for Leave to File Under Seal and ExParte, Doc. No. 36, is GRANTED. Counsel will receive an email within twenty-four (24) hours of this order with instructions for submitting sealed documents for which leave has been granted in accordance with the Local Rules of the U.S. District Court of Massachusetts. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (SKY) (Entered: 01/08/2026)

Jan. 8, 2026

Jan. 8, 2026

38

Response to Motion

Jan. 8, 2026

Jan. 8, 2026

Order on Motion to Seal

Jan. 8, 2026

Jan. 8, 2026

39

Opposition to Motion

Jan. 9, 2026

Jan. 9, 2026

41

Leave to File Document

Jan. 9, 2026

Jan. 9, 2026

Order on Motion for Protective Order

Jan. 9, 2026

Jan. 9, 2026

Case Details

State / Territory:

Massachusetts

Case Type(s):

Immigration and/or the Border

National Security

Special Collection(s):

Trump Administration 2.0: Challenges to the Government

Key Dates

Filing Date: Nov. 20, 2025

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

Two noncitizens facing massive civil fines for allegedly failing to depart the United States, along with the Immigrant Legal Resource Center, a nonprofit organization providing legal support and advocacy for immigrant communities.

Attorney Organizations:

Legal Services/Legal Aid

NYU Clinical Law Center

Public Justice

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Pending

Case Details

Causes of Action:

Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.

Declaratory Judgment Act, 28 U.S.C. § 2201

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Due Process: Procedural Due Process

Excessive Bail/Fines

Seventh Amendment (civil jury)

Other Dockets:

District of Massachusetts 1:25-cv-13471

Available Documents:

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Sought:

Attorneys fees

Declaratory judgment

Injunction

Relief Granted:

None yet

Source of Relief:

None yet

Issues

General/Misc.:

Fines/Fees/Bail/Bond

Discrimination Basis:

Immigration status

Affected Race(s):

Race, unspecified