Projects · Immigration & Law

Immigration: The Alien Enemies Act & CECOT

A 1798 wartime law invoked for the first time since World War II. Planes sent to El Salvador while a federal judge's order was being defied. A Maryland father with legal status accidentally deported and imprisoned.

Deported to CECOT
238
March 15–16, 2025
Under Alien Enemies Act
137
Remaining 101 under regular immigration law
U.S. paid El Salvador
$4.7M
To house deportees
Last AEA Use
WWII
31,000 interned
Court Contempt Finding
Probable cause
Judge Boasberg, July 2025
Supreme Court Ruling
7–2 against Trump
Due process violated

The Alien Enemies Act is a wartime law enacted during the administration of President John Adams in 1798. It gives the president authority to summarily detain or deport nationals of an enemy nation during a declared war, or when that nation perpetrates, attempts, or threatens an "invasion or predatory incursion" against the United States. The law was designed for wartime use — its most recent prior invocation was during World War II, when it was used to intern 31,000 people, predominantly of Japanese, Italian, and German descent. The Japanese American internment has since been widely condemned as a civil liberties catastrophe.

The Brennan Center for Justice stated that "The Alien Enemies Act may be used only during declared wars or armed attacks on the United States by foreign governments." The United States is not at war with Venezuela; no invasion or attack has occurred. Trump justified the invocation by declaring that Tren de Aragua — a Venezuelan criminal gang — constituted a "hybrid criminal state" that was "invading" the United States. Legal experts widely challenged this framing.

On March 15, 2025, Trump issued a proclamation invoking the Alien Enemies Act against Tren de Aragua. Almost immediately, planes carrying 238 people — alleged gang members — departed for El Salvador. Of the 238, 137 were deported under the AEA; 101 under regular immigration law. Also included were 23 alleged MS-13 members, even though MS-13 was not included in the AEA proclamation.

U.S. District Judge James Boasberg issued an emergency restraining order on March 15 barring the deportations and ordering any planes already in the air to turn around. The planes did not turn around. The Trump administration defied the court order. Boasberg later found "probable cause" to hold the administration in criminal contempt of court — a finding that has been on pause at the D.C. Circuit Court of Appeals.

The men were not given due process: no fair trials, no individual hearings on gang membership, no release dates, no sentences. Many were identified as gang members based solely on their tattoos — including tattoos of crowns, soccer balls, and palm trees that human rights organizations said bore no necessary gang association. Parents disputed gang membership claims, providing official Venezuelan documents showing no criminal records.

El Salvador's President Nayib Bukele posted videos of the men arriving — handcuffed, heads shaved, kneeling on the ground surrounded by guards — at CECOT, the Terrorism Confinement Center. Homeland Security Secretary Kristi Noem visited CECOT and declared the deportees should remain there "for the rest of their lives." The men were held incommunicado — no access to family or lawyers. El Salvador formally stated to the United Nations that the men were not being held under Salvadoran law but under U.S. custody — effectively a lease arrangement.

The Administration Admitted Error

Kilmar Armando Abrego Garcia is a Salvadoran man with protected legal status in the United States. On March 15, 2025, he was mistakenly deported to El Salvador and imprisoned at CECOT — an action the Trump administration admitted was an "administrative error." A court order already prohibited his removal due to the risk of persecution he would face in El Salvador.

Despite admitting the error, the administration simultaneously accused Abrego Garcia of being a member and leader of MS-13 — claims he denied, and which human rights groups and bipartisan lawmakers questioned. The administration stated it "doesn't have the authority" to bring him back from El Salvador.

A government attorney, Erez Reuveni, was fired after refusing to sign an appeal brief that included assertions he believed to be untrue. Abrego Garcia's wife and their disabled son, both U.S. citizens, filed a lawsuit. His case became the most high-profile symbol of the due process failures in the mass deportation program.

March 15, 2025
AEA invoked; emergency order defied
Trump invokes AEA against Tren de Aragua. Judge Boasberg issues TRO barring deportations. The administration sends planes anyway. Officials lied to some deportees, telling them they would be taken to Venezuela. The planes landed in El Salvador.
First defiance of a federal court order
April–May 2025
Supreme Court: 24-hour notice violates due process
The Supreme Court rules 7–2 that the Trump administration violated due process by giving migrants approximately 24 hours' notice before removal — "devoid of information about how to exercise due process rights." The court prohibits further AEA deportation flights in a rare middle-of-the-night ruling. Justices Alito and Thomas dissent.
July 2025
Boasberg finds probable cause for contempt; CECOT detainees moved
Boasberg says there is "probable cause" the administration is in criminal contempt of his original order. The CECOT detainees are moved from El Salvador to Venezuela as part of a prisoner swap — the U.S. receives 5 American citizens and 5 other individuals from Venezuela in exchange.
December 2025
Federal judge: due process violated for all CECOT class
Judge Boasberg rules all 238 CECOT migrants had their due process rights violated — removed "with virtually no notice and no opportunity to contest" the gang designation. Orders administration to submit plans for hearings. The DOJ was expected to appeal.
Full class: due process violated
Constitutional Challenge
Birthright Citizenship EO
On his first day in office, Trump signed an executive order ending birthright citizenship for children of non-citizens — despite the 14th Amendment's clear guarantee. Four separate federal judges struck it down as unconstitutional within weeks. U.S. District Judge Leo Sorokin: the order is "likely unconstitutional" and the "14th Amendment broadly confers birthright citizenship."
Mass Enforcement
Operation Metro Surge
A January 2026 immigration enforcement operation that led to violent confrontations with migrants and protesters. Multiple high-profile killings of U.S. citizens by federal agents were reported, triggering large nationwide protests that increased in intensity throughout early 2026.
American Citizens Affected
Citizens Detained & Deported
Multiple U.S. citizens were detained and in some cases deported during the mass deportation campaign. Trump and Vance suggested suspending due process entirely — Vance characterized due process protections as using "fake legal process" to accomplish political goals. Trump said: "We cannot give everyone a trial."
Policy
Remain in Mexico & CBP One
Trump resumed the Remain in Mexico policy, revoked parole status for CBP One entrants, ended humanitarian parole for Cubans, Haitians, Nicaraguans, and Venezuelans, and used the Alien Enemies Act in a novel way. The administration also designated drug cartels as terrorist organizations and declared an "armed conflict" with them.

NPR — AEA Deportations & Due Process Ruling

NPR, December 22–23, 2025. Documents the AEA invocation, Boasberg's due process ruling, and the class certification for all CECOT migrants.

Wikipedia — March 2025 Deportations of Venezuelans

Detailed account of the 238 deportees, Abrego Garcia's case, tattoo identification controversy, and individual stories of those imprisoned.

Courthouse News Service — Supreme Court Ruling

Documents the 7–2 ruling finding due process violations and the rare middle-of-the-night injunction against further AEA flights.

American Immigration Council

"United States Frees Venezuelans Held in El Salvador," July 21, 2025. Documents the prisoner swap, El Salvador's statement that CECOT was leased to the U.S., and the ongoing litigation.

ABC News — Boasberg Order

ABC News, December 24, 2025. Documents the $4.7M U.S. payment to El Salvador and the due process ruling for the full CECOT class.