A federal judge in Texas on Monday blocked a Biden administration immigration rule that allowed judges to close deportation proceedings indefinitely, ending the policy the same day Texas Attorney General Ken Paxton and a conservative legal group challenged it in court.
U.S. District Judge Reed O’Connor, a nominee of former President George W. Bush, entered a final consent judgment vacating the rule after the Trump administration’s Justice Department agreed with Texas that the regulation should be set aside. The sequence of events brought the litigation to a close within hours of its filing, marking a major win for President Donald Trump‘s immigration enforcement agenda.
The lawsuit, filed in the Wichita Falls Division of the Northern District of Texas by Paxton and Trump-aligned America First Legal on Monday, challenged a 2024 DOJ rule enacted under former President Joe Biden that expanded immigration judges’ authority to administratively close removal proceedings.
Administrative closure removes a case from an immigration judge’s active docket without resolving whether an immigrant is removable from the United States. Under the Biden-era rule, immigration judges could close cases after considering arguments from both the government and the immigrant, particularly when the person was pursuing another immigration benefit that could allow them to remain in the country legally.
Texas argued the policy exceeded the DOJ’s authority and effectively created a mechanism for immigrants to avoid removal indefinitely.
“The Administrative Closure Rule effectively grants indefinite amnesty to aliens illegally present in this country,” the plaintiffs argued in their 43-page complaint.
The lawsuit, co-filed with AFL, alleged the rule conflicted with provisions of the Immigration and Nationality Act requiring immigration judges to determine whether a person is removable at the conclusion of proceedings. The group also argued the regulation violated the Administrative Procedure Act.
According to AFL, the number of administratively closed immigration cases grew from roughly 278,000 in January 2021 to nearly 392,000 by January 2025. The organization argued that once cases were removed from active dockets, many remained unresolved for years.
“The same day the lawsuit was filed, the parties reached a settlement, and the court entered a final consent judgment vacating the rule and permanently enjoining its enforcement,” AFL said in a statement following the ruling.
Gene Hamilton, president of AFL and a former Trump administration official, called the decision a major victory.
“Another Biden program that allowed illegal aliens to indefinitely stay in the United States is now gone,” Hamilton said.
O’Connor was assigned the case because it was filed in the Wichita Falls Division, where he is the only active district judge. The Northern District of Texas is divided into seven divisions, several of which operate with a single active judge. Unlike larger federal courthouses that randomly distribute cases among multiple judges, lawsuits filed in those divisions are automatically assigned to the lone district judge presiding over that division.
Some pro-immigration groups voiced frustration over the way the ruling was quickly decided, including the American Immigration Council. Aaron Reichlin-Melnick, a senior fellow with the AIC, suggested in an X post that parties who disagree with this decision may seek to “intervene in the already-completed lawsuit to overturn his actions.”
The rapid resolution mirrors another case involving Texas and the federal government that was resolved quickly, thanks to like-minded leadership paired with O’Connor’s sign-off.
Last summer, the DOJ sued Texas over a state law allowing certain illegal immigrant students to qualify for in-state tuition at public universities. Texas agreed with the federal government’s position and asked O’Connor to declare the law unconstitutional, which he did within hours.
In other high-profile litigation involving the Trump administration, O’Connor has become a recurring venue for the DOJ’s pursuit of medical records from hospitals providing transgender drugs and surgeries to children.
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Last month, O’Connor agreed to enforce an administrative subpoena from the DOJ seeking records from Rhode Island Hospital as part of an investigation into controversial hormone and drug regimens provided to minors diagnosed with gender dysphoria.
In response, attorneys for the healthcare providers have sought to disrupt the government’s investigations by joining lawsuits in more favorable jurisdictions such as California and Rhode Island.