Status as of October 7, 2026. A federal court in Massachusetts has stayed the Trump administration's 2025 immigration-fine regulations and fines issued under the challenged system after June 27, 2025 while Maria L. v. Mullin proceeds. The ruling is interim relief, not a final judgment on the merits.
U.S. District Judge George A. O'Toole Jr. granted relief on September 30 under Section 705 of the Administrative Procedure Act. The decision affects a streamlined federal system used to impose civil penalties on certain noncitizens for alleged failures to depart or comply with immigration requirements.
What the 2025 rule changed
DHS and DOJ issued an interim final rule on June 27, 2025 changing the procedures for immigration-related civil penalties. The rule took effect immediately.
Among other changes, the government shortened the response period, changed notice procedures and removed some review mechanisms that had existed under the earlier process.
The underlying immigration statutes authorize civil penalties in specified circumstances. The lawsuit challenges the way the government implemented and applied the newer system, including whether the required individualized statutory findings were actually made.
Why the judge granted a stay
The court concluded that the plaintiffs had shown a likelihood of success on multiple Administrative Procedure Act claims and faced irreparable harm from enforcement of the penalties.
The opinion questioned whether the government had adequately made individualized findings required by the statutes, including whether a failure to depart was willful or voluntary where those elements matter.
The judge also found the plaintiffs likely to succeed on their argument that the 2025 rule should have gone through ordinary notice-and-comment rulemaking rather than taking effect immediately as an interim final rule.
How large were the penalties
The litigation describes fines reaching hundreds of thousands of dollars. One named plaintiff faced a penalty of approximately $1.8 million.
The court record also discusses the government's broader use of the civil-penalty program. The scale of the penalties was part of the court's irreparable-harm analysis.
What the stay means
The regulations challenged in the case and the fines covered by the order cannot be enforced while the stay remains in place.
The ruling does not hold that the federal government can never impose an immigration-related civil penalty. It is a procedural and administrative-law ruling in an ongoing case, and later proceedings can change the legal posture.
Factum Immigration's ICE: Detention and Deportation guide covers the broader enforcement and removal framework.
Frequently asked questions
Can DHS enforce the post-June 27, 2025 fines covered by the stay?
No. The court's September 30 order stays the challenged regulations and the covered fines while the case proceeds.
Did the court permanently eliminate immigration fines for failure to depart?
No. The order is interim relief in ongoing litigation and does not erase the underlying statutory provisions authorizing civil penalties.
How large were some of the challenged fines?
The litigation record includes penalties totaling hundreds of thousands of dollars and, for one named plaintiff, approximately $1.8 million.
Official sources
Disclaimer: Factum Immigration provides general information, not legal advice. For guidance on an individual case, consult a licensed immigration attorney.