DHS recently issued a press release headlined: “Thanks to President Trump and Secretary Noem, More than 2.5 Million Illegal Aliens Left the U.S.” Well, thanks to Trump, Noem, “Border Czar” Tom Homan, acting ICE Director Todd Lyons, and (most importantly) thousands of ICE officers and countless other agents and officials. It claims, “DHS enforcement operations have resulted in more than 605,000 deportations”, an impressive feat if true. And there are plenty of reasons to believe that’s an accurate depiction of immigration enforcement over the past 11 months.

The Way Things Immigration-Enforcement Related Were

When I started in immigration, large-scale deportation efforts were the norm.

Consider the following, from the Supreme Court’s 1984 opinion in INS v. Lopez-Mendoza: “Immigration officers apprehend over one million deportable aliens in this country every year. A single agent may arrest many illegal aliens every day.”

That was “over one million deportable aliens” arrested per year months before the National Academy of Sciences (NAS) estimated the entire unauthorized population in the United States at 2 to 4 million, total.

Admittedly, NAS’s estimate was likely on the low side, given that around 3 million aliens took advantage of the Reagan amnesty passed shortly thereafter, but the idea that immigration officers were arresting even a sixth of all illegal aliens annually is mindboggling –though it was the norm.

Of course at the time and for years thereafter, immigration officers have to battle against resistance from “sanctuary” states and cities and street-level gadflies when making those arrests.

Unlike now, such jurisdictions were few and far between, and even then weren’t engaged in a conscious effort to protect their illegal population with the tenacity female grizzlies use to safeguard their cubs. States and localities were more than happy to pare down their welfare rolls and school populations, a tendency that was particularly pronounced when the aliens in question were criminals.

When I started as an immigration judge in 2006, a quarter to half of my docket was composed of drunk drivers, domestic abusers, and street brawlers whom local cops collared and (to save incarceration and court costs) handed over to ICE officers when they asked, and it remained that way well into the Obama administration.

That was even after then-INS Commissioner Doris Meissner issued a “prosecutorial discretion” memo in November 2000 (as then then-Clinton administration was on its way out the door), intended to limit immigration enforcement.

The Obama Administration’s “Priorities”

And that was the way immigration enforcement essentially was until one of Meissner’s later successors, then-ICE Director John Morton, issued his own March 2011 memo, “Civil Immigration Enforcement: Priorities for the Apprehension, Detention, and Removal of Aliens”.

Describing immigration enforcement as “a critical mission and one with direct significance for our national security, public safety, and the integrity of our border and immigration control”, that memo nonetheless concluded that “ICE... only has resources to remove approximately 400,000 aliens per year, less than 4 percent of the estimated illegal alien population in the United States”.

Keep that 400,000 figure in mind as I tell you that the agency, in FY 2011, was operating with a budget of $5.8 billion, $2.77 billion of which was directed exclusively to the immigration enforcement operations carried out by the ICE’s Enforcement and Removal Operations (ERO) directorate – enough funding for an estimated 3,000 ICE ERO officers.

In any event, that memo directed ICE to “prioritize” immigration enforcement efforts, focusing on “aliens who pose a danger to national security or a risk to public safety” (terrorists and spies), “recent illegal entrants”, and “aliens who are fugitives or otherwise obstruct immigration controls” (including criminals and fraudsters).

Keep those “priorities” in mind as well, because they were later used under the Biden administration to throttle immigration enforcement to the point of negation.

That said, the 2011 memo didn’t tell ICE to ignore other illegal aliens, but it created an expectation of non-enforcement, and a talking point the president’s critics use to complain about “mass deportation” under Trump II.

Again, “mass deportation” was the standard until late, and most today forget what it really means.

“Interior Removals” versus “Border Removals”

Curiously, ICE removals actually rose following the issuance of the 2011 memo, from nearly 397,000 in FY 2011 to nearly 410,000 in FY 2012. That’s only part of the story, however, and not the important part.

As I have explained elsewhere, two key metrics define the effectiveness of any immigration-enforcement regime: ICE arrests of aliens in the United States (“interior arrests”), and ICE removals of aliens from within the United States (as opposed to at the border), also known as “interior removals”.

Those metrics are the ones to watch because immigration enforcement at the border is reactive, driven by the efforts of foreign nationals to enter the United States illegally. No one looked at millions of annual border apprehensions under Biden and saw an effective immigration policy.

Interior arrests and removals, on the other hand, are a marker for how effective DHS’s enforcement efforts are in dealing with aliens who are already here.

Nearly 224,000 of the FY 2011 deportations were “interior removals”; the rest were aliens who had been apprehended by CBP at the borders and ports and handed over to ICE to be sent out of this country.

By FY 2012, however, interior removals fell to fewer than 181,000, and would continue to decline for the rest of the Obama administration, dropping 64 percent to a mere 65,332 by FY 2016 largely thanks to a second memo, this one issued by then-DHS Secretary Jeh Johnson weeks after the 2014 midterms.

Johnson’s November 20, 2014 “Policies for the Apprehension, Detention and Removal of Undocumented Immigrants” picked up the priorities in the Morton memo and ran with them, further limiting ICE’s ability to go after aliens who weren’t considered priorities.

I was still on the bench, and the drunk drivers and domestic abusers (and worse) of the past were largely replaced by border aliens and “credible fear” claims.

Trump I

A new broom may sweep clean, but interior immigration enforcement during Trump I never rebounded to the lofty heights it had prior to the Morton memo. Interior arrests hit their high under the first Trump administration in FY 2018 (just over 158,500) as did interior removals (95,360).

Renewed border chaos, with hundreds of thousands of adult migrants entering illegally with children in “family units” (FMUs), drew immigration resources south in 2019, and while total removals increased between FY 2018 and FY 2019, interior removals fell roughly 10 percent, to fewer than 86,000.

Pandemic-imposed restrictions sent interior arrests (23,932) and removals (62,739) plummeting in FY 2020, the last full fiscal year of Trump I.

By that point even DHS was playing under the rules established by the 2011 Morton memo, with ICE ERO crowing in its annual report that, “The vast majority of [its] interior removals – 92 percent – had criminal convictions or pending criminal charges, demonstrating ICE ERO’s commitment to removing those who pose the greatest risk to the safety and security of the United States.”

The Lost Biden Years

Things only got worse under a Biden administration that started with an attempted 100-day moratorium on all deportations from the United States and then only slightly improved as time went on.

Through the end of FY 2023, ICE struggled to exceed even 40,000 interior removals per year, even as the illegal population swelled by an estimated 8 million under Biden.

While ICE ERO interior removals nearly hit the 48,000 mark in FY 2024, it was only because the Biden-Harris administration could read the political graffiti on the wall and realized (too late) how unpopular non-enforcement has become.

Trump II, with a Vengeance

When Trump and Homan arrived following the 2024 election, they had their work cut out for them: the unauthorized population had increased to 15.4 million in four lost years, of whom 1.44 million were aliens who received their “due process” and were under final orders of removal.

Note that the phrase “work cut out for you”, which comes from tailoring, has a double-meaning: there’s a lot to be done, for sure, but the conditions are in place to do it – the fabric’s cut, and ready to be assembled.

And with Homan, Noem, Lyons, and the rest – including especially an estimated now 6,000 ICE ERO officers who’d been sidelined for four years under Biden – Trump had the team to do it.

Targeting those nearly 1.5 million aliens with final orders was a logical start, and by the end of FY 2025, as I recently reported, immigration judges added almost an additional half million removal orders to that total.

Consequently, when you read articles claiming there’s been “a shift in enforcement – with individuals with criminal convictions making up only” a fraction of the aliens arrested and deported by ICE under Trump II: (1) take them with a grain of salt; and (2) notice how they never tell you how many of those “non-criminals” have final removal orders.

Add the untold number of alien criminals whom ICE under Biden was aware of, but not allowed to pursue, and countless “collateral” illegal aliens found in the company of those criminals and other aliens under final orders, and the interior arrest numbers were sure to add up fast.

Once in Trump II ICE custody, most of those aliens understand they aren’t going to be released back into this country, so they’re logically taking the option to be released elsewhere instead via deportation. If that sounds questionable, I can assure you from eight years on the bench it happens all the time.

Consequently, even with the sanctuary pushback and a largely hostile media nipping at its heels, DHS’s claim of 605,000-plus deportations since January 20 doesn’t sound that unlikely, particularly with the massive pool of unauthorized targets Homan et al. have to choose from.

DHS also asserts in its press release that “1.9 million other illegal aliens have voluntarily self-deported since January 2025”.

The Center will soon release its latest figures on the recent drop in the unauthorized population, but a mid-November analysis by my colleague, Steve Camarota, estimated a decline in the foreign-born population (both legal and otherwise) of about 2.3 million between January and September, suggesting the 1.9 million self-deports by early December claimed by DHS is definitely in the ball park.

Consequences Breed Compliance

Note that Border Patrol didn’t have the agents and other resources needed to secure the border until well after September 11th; consequently, as recently as 2003, agents were lucky to catch a third of all illegal entrants.

That shifted the immigration enforcement burden to the then-INS in the interior, and as the Supreme Court made clear in Lopez-Mendoza, those INS officers performed that role forcefully, arresting and deporting about 1 million illegal aliens per year.

It wasn’t until 2011, about a third of the way into the Obama administration, that ICE shifted its primary focus from all aliens here unlawfully to just those with criminal arrests and convictions.

That new, Obama-era focus continued throughout Trump I, but quickly became a procrustean standard under Biden DHS leadership that only permitted ICE officers to target the most egregious criminal aliens.

As a result, would-be migrants knew they would be allowed to remain if they made it to illegally to the United States, which overwhelmed Border Patrol and ended any hope of securing the border against a largely unmitigated flow of drugs, weapons, other contraband, and newly arrived illegal entrants.

DHS under Trump II has now secured the Southwest border while Homan and the rest have expanded interior enforcement. Instead of the “either/or” enforcement approach that prevailed for most of modern immigration history – the border or the interior – the department is applying both.

Critics have questioned whether there’s a need for vigorous interior enforcement with a secure border, but that ignores a basic precept of human nature: consequences breed compliance.

If there were no troopers on the highway, we’d all speed; the threat of punishment prompts us to let up on the accelerator.

The border can’t be secured absent interior enforcement, and even with enhanced resources, ICE can only impose consequences against a tiny fraction of the unauthorized population – the “less than 4 percent” claimed in the 2011 memo – if that population constantly refills with new illegal migrants.

Vigorous ICE enforcement is nothing new; it was just shelved as a policy for the last 14-plus years. Now that it’s back, the agency is setting new interior arrest and removal records, aided by the very non-enforcement it was intended to replace.

Has the unauthorized population dropped by more than 2.5 million under Trump II? It wouldn’t surprise me, because once again there are consequences for breaking the immigration laws, and consequences breed compliance.