🏛️ Immigration Court Watch
One Judge, One Hundred Respondents, One Morning
The Justice Department crams more than a hundred people into a single “mega master” hearing, drags dockets forward by years, and banks on the ones without lawyers to trip. The design hands a removal order to anyone who arrives late, misses the roll call, or never had counsel. The statute never bent for the docket. The Seventh Circuit has thrown out orders for less.
More than a hundred respondents, one judge — the master calendar hearing rebuilt as a sorting machine.
The immigration courts inside the Justice Department now do something the system has never done at this scale. They pull hundreds of cases forward on the calendar, stack them into mass first hearings, and order removal against the people who do not appear. Immigration lawyers and the American Immigration Lawyers Association flagged the pattern to NPR Illinois, which reported it on May 26, 2026: settings of 100 or more respondents at once, where the usual first-hearing crowd runs two or three dozen.
The lawyers describe the same fact pattern in every courthouse that runs it. The hearings hit people who have no attorney. The clerk originally set many of these cases for 2027, 2028, even 2029, then yanked them forward with almost no runway. AILA reads it plainly: group the unrepresented, give thin notice, pack a room that runs out of chairs, and you have built a machine that spits out in absentia removal orders on its own. The practice has surfaced in Chicago, Boston, and Chelmsford, Massachusetts, with Dallas reportedly next. It lands as the administration chases a million removals a year against the roughly 600,000 it logged in 2025.
📋 What a Person Actually Walks Into
Picture the person this targets. No lawyer. Limited English, or none. A notice that may or may not have reached the right address, for a date that jumped the calendar by three years. They reach a federal building, clear a security line that wraps the block, and walk into a room holding more bodies than seats. A judge calls a roll the person at the back cannot hear. No individual colloquy. No real chance to say “I don’t understand.” No time to find counsel before the court takes the pleadings.
Arrive twenty minutes late because the elevator bank backed up, or sit through a name you never caught, and you do not get a reschedule. You get an order of removal entered in your absence. That is the entire point of the volume. The crowd is not a side effect of an overloaded docket. The crowd is the strategy.
🧩 How the Tactic Works — and Where It Breaks
Start with what a master calendar hearing does. It opens the case. The judge advises the respondent of their rights, takes pleadings on the Notice to Appear, sorts out counsel, handles language access, and sets the contested matters for a real merits hearing down the road. EOIR describes it exactly that way in its own public materials. It is a gateway, not a verdict.
The mega master keeps the label and guts the function. No judge advises a hundred people of their rights one by one in a morning. No judge confirms that each one understood the charges, had a fair shot at a lawyer, or could follow a word of it in a language they speak. So the law that governs first hearings — notice, counsel, language, a meaningful chance to be heard — is exactly where this tactic stands exposed.
A removal order entered in absentia holds only when the respondent had written notice and DHS proves, by clear, unequivocal, and convincing evidence, that it provided notice and that the respondent is removable. 8 U.S.C. § 1229a(b)(5). A changed hearing date generally demands fresh written notice of the new time or place and the consequences of failing to appear. 8 U.S.C. § 1229(a)(2). The respondent keeps the privilege of counsel at no expense to the government, plus a reasonable opportunity to examine and present evidence and cross-examine witnesses. 8 U.S.C. § 1229a(b)(4). Interpreters come at government expense when a respondent’s English cannot carry full participation — master calendar hearings included. EOIR Policy Manual, ch. 3.10.
The government’s defense writes itself: the docket is overwhelmed, the courts manage their own calendars, mass advisals run efficient. None of that answers the statute. Efficiency is not a notice provision. A judge can run a tight calendar, but no judge can convert “you were in the building” into “you received legally sufficient notice and a meaningful chance to be heard.” The Seventh Circuit has vacated removal orders when an immigration judge cut off material testimony and denied a fair hearing. Kerciku v. INS, 314 F.3d 913 (7th Cir. 2003). The principle reaches past those facts: when volume itself defeats comprehension, counsel, or response, the order stands on sand.
⚖️ What This Actually Does
The real-world rule: a “mega master” setting drops the government’s burden by exactly nothing. Every notice requirement, every counsel and language protection, every reopening route survives the crowd. The volume buys administrative convenience, and convenience does not amend the statute.
| A master calendar hearing is built to | A mega master setting instead |
|---|---|
| Advise each respondent of their rights individually | Runs a mass advisal a hundred people deep and checks nobody’s comprehension |
| Confirm counsel or grant time to find counsel | Targets the unrepresented and takes pleadings before a lawyer appears |
| Arrange interpreters so the respondent can follow | Outpaces the interpreters on hand and proceeds anyway |
| Verify notice of the time and place | Advances dates by years on notice that may never have landed |
| Set contested cases for a real merits hearing | Turns a missed roll call into a final removal order |
⚠️ The Fatal Flaws
My read, strongest argument first.
- Notice is the soft spot, and it carries the burden. When a case jumps from a 2028 setting to a mass hearing today, one question controls: did the respondent get written notice of this date, served at a valid address, with the consequences of nonappearance spelled out? DHS must prove that by clear, unequivocal, and convincing evidence before any in absentia order survives. § 1229a(b)(5); § 1229(a)(2). Advancing the docket multiplies the chances that notice failed — and the government, not the respondent, answers for every failure.
- A mass advisal is not an individualized one. The right to be heard means the respondent understood the proceeding well enough to respond. A crowd advisal proves nothing about whether any particular person grasped the charges, knew they could seek relief, or understood the cost of skipping the hearing. Where comprehension stands in doubt, mass pleadings cannot stand in for the real thing.
- Counsel access gets steamrolled by design. The privilege of counsel means nothing if the court takes pleadings before a pro se respondent can secure a lawyer. § 1229a(b)(4)(A). Target the unrepresented, then move fast, and you have not managed a docket. You have denied a statutory protection and dressed it up as a calendar.
- Language access cannot scale to the crowd. EOIR’s own policy promises interpreters when English falls short. A room of a hundred routinely outruns the interpreters in the building. Proceed without one and the record shows a respondent who could not participate in a language they speak — a clean due-process defect under the agency’s own rules.
⚖️ The In Absentia Rules — and How Campos-Chaves Moved the Fight
Here is the hard truth the mega master exploits: after Campos-Chaves v. Garland, 602 U.S. 447 (2024), and the Board’s 2026 decisions, in absentia law tilts toward the government. The old reliable — attack the defective Notice to Appear and walk — is mostly gone. Campos-Chaves held that a defective NTA alone will not rescind an in absentia order when the respondent received a proper later notice of hearing for the hearing actually missed. The Board has enforced that line hard, and in the Seventh Circuit the openings that remain are narrow and specific.
It reinstated Matter of Laparra, 28 I&N Dec. 425 (BIA 2022) — a compliant notice of hearing supports an in absentia order even on a defective NTA — and reaffirmed it as good law in any circuit without contrary precedent. Matter of Laparra-DeLeon, 29 I&N Dec. 389 (BIA 2026). It told judges they erred by continuing a case instead of entering an in absentia order where notice of the missed hearing was proper and DHS proved removability. Matter of Laurent Castro, 29 I&N Dec. 419 (BIA 2026). It treated the NTA defect as the respondent’s objection to raise — forfeited if not timely, building on Matter of Fernandes, 28 I&N Dec. 605 (BIA 2022) — and directed judges to proceed in absentia rather than terminate. Matter of Lopez-Orellana, 29 I&N Dec. 533 (BIA 2026). And it shut the administrative-closure escape hatch, even for minors, where DHS proves proper notice and removability. Matter of Orozco Becerra & Orozco Becerra, 29 I&N Dec. 600 (BIA 2026).
So the live fights no longer run through “the NTA was defective.” They run through three grounds, and the grounds are concrete.
- No actual or proper notice of the missed hearing. After Campos-Chaves, the document that controls is the § 1229(a)(2) notice for the hearing the respondent missed. In a mega master, that is the notice that advanced the date. Attack its service, the address used, electronic-only delivery, and its proof in the record. This ground carries no time limit, and a proper motion stays removal. 8 U.S.C. § 1229a(b)(5)(C)(ii).
- Exceptional circumstances — with proof, and with prompt contact to the court. File within 180 days and show the failure to appear ran beyond the respondent’s control. The Seventh Circuit just drew the line in Nimaga v. Blanche, No. 20-3065 (7th Cir. Apr. 29, 2026): an Indianapolis man ordered removed in absentia by the Chicago court — robbed, left destitute, his ride gone — still lost his case, because he never told the court he could not make it. The lesson lands blunt. The moment a client knows they cannot appear, they contact the immigration court, in writing, and keep the proof.
- Due process — a meaningful opportunity to be heard. Where notice, language access, counsel access, or the hearing procedure itself denied a real chance to participate, the order turns vulnerable. Kerciku v. INS, 314 F.3d 913 (7th Cir. 2003); Nazarova v. INS, 171 F.3d 478 (7th Cir. 1999) (interpreter confusion and agency-created barriers can support reopening). This is where the mega master’s crowd — the inaudible roll call, the missing interpreter, the pleadings taken before counsel appears — becomes the record.
Campos-Chaves v. Garland, 602 U.S. 447 (2024); Matter of Laparra, 28 I&N Dec. 425 (BIA 2022); Matter of Laparra-DeLeon, 29 I&N Dec. 389 (BIA 2026); Matter of Fernandes, 28 I&N Dec. 605 (BIA 2022); Matter of Lopez-Orellana, 29 I&N Dec. 533 (BIA 2026); Matter of Laurent Castro, 29 I&N Dec. 419 (BIA 2026); Matter of Orozco Becerra & Orozco Becerra, 29 I&N Dec. 600 (BIA 2026); Nimaga v. Blanche, No. 20-3065 (7th Cir. Apr. 29, 2026); Kerciku v. INS, 314 F.3d 913 (7th Cir. 2003); Nazarova v. INS, 171 F.3d 478 (7th Cir. 1999); 8 U.S.C. §§ 1229a(b)(5), 1229(a).
The practice point: after Campos-Chaves, a defective NTA alone will not carry the day. The order falls only on proof of no actual or proper notice of the missed hearing, genuine exceptional circumstances backed by prompt contact with the court, or a due-process failure that denied a meaningful opportunity to be heard. In a mega master, the second and third sit built into the room — if counsel makes the record.
🗣️ Make the Record
The win here is not outrage. It is a record clean enough to survive review — notice failure, language failure, counsel-access failure, no individualized chance to be heard. Put the objections below on the transcript, in the respondent’s own case, the moment the setting turns into a sorting line.
On-the-record moves before pleadings are taken
- State the client’s best language out loud and demand a qualified interpreter; object to proceeding without one.
- For an unrepresented respondent, ask for a good-cause continuance to obtain counsel under 8 C.F.R. § 1003.29, and request the current pro bono list.
- If the court advanced or consolidated the date, make the court and DHS identify the operative notice, the method and date of service, the address used, and the ECAS entry.
- Refuse a mass pleading where comprehension stands in doubt — do not let a crowd advisal substitute for individual understanding.
- Build the prejudice record: name what the volume prevented — hearing the roll, securing counsel, responding to charges, requesting relief, explaining a late arrival.
✅ What To Do Now
- File to continue before the hearing. Good cause under § 1003.29 covers counsel access, language access, and notice irregularities. The template below is ready to caption and file.
- Pin down notice the moment a client surfaces. Pull the NTA, the hearing notice, proof of service, address history, EOIR-33 filings, and any rescheduling order before you concede an in absentia order holds.
- If an order already entered, move to reopen. Within 180 days for exceptional circumstances; at any time for lack of notice or custody through no fault of the respondent. A proper motion stays removal while the judge decides it. 8 C.F.R. § 1003.23(b)(4)(ii).
- Document the room. Crowding, seat shortage, security-line delay, inaudible roll call, interpreter shortage, check-in confusion. Physical chaos is evidence of a procedure that defeated a meaningful chance to be heard.
📄 Motion to Continue — Ready to Caption
Drop your client’s facts into the brackets and file. This tracks the good-cause standard and preserves the objections that matter for any later petition for review.
UNITED STATES DEPARTMENT OF JUSTICE
EXECUTIVE OFFICE FOR IMMIGRATION REVIEW
Immigration Court: [Chicago / Other]
In the Matter of: [Respondent Name] | A No.: [A-Number] | Respondent
Respondent’s Motion to Continue Master Calendar Hearing
Respondent respectfully moves to continue the master calendar hearing set for [date and time]. Good cause supports a continuance under 8 C.F.R. § 1003.29.
Grounds.
- The mass setting prevents meaningful participation. A master calendar hearing exists to advise rights and take pleadings on the Notice to Appear. A setting of this size cannot serve that function individually for Respondent.
- Counsel access. Respondent holds the privilege of counsel at no expense to the government (8 U.S.C. § 1229a(b)(4)(A)) and needs time to secure counsel and review the NTA, hearing notice, pleadings, and relief eligibility.
- Language access. Respondent’s best language is [language] and Respondent cannot fully participate in English. EOIR policy provides interpreters at government expense in that circumstance, master calendar hearings included.
- Notice. If the court advanced, rescheduled, or consolidated this hearing from a later date, Respondent asks the Court to require DHS or EOIR to identify the operative notice, proof of service, address used, service date, and any notice of changed time or place. 8 U.S.C. § 1229(a)(2).
- Preserved objections. Respondent holds a reasonable opportunity to examine and present evidence and cross-examine witnesses (8 U.S.C. § 1229a(b)(4)(B)), and the Seventh Circuit requires a meaningful opportunity to be heard. Kerciku v. INS, 314 F.3d 913 (7th Cir. 2003).
Relief requested. Continue the hearing at least [60/90] days; confirm Respondent’s language as [language] and provide an interpreter; provide the current pro bono list; permit Respondent to obtain counsel and file written pleadings; require DHS or EOIR to preserve proof of notice; and set any future hearing in a manner that lets Respondent hear, understand, and respond individually.
⬇ Toolkit — PDF (print-ready)
⬇ Editable motion + checklist — Word (.docx)
⏱️ The Government Already Ran This Experiment
Strip the name off the mega master and you find a tactic the government already field-tested. The Biden administration built it, ran it, and left the numbers on the floor. They called it the Dedicated Docket.
The plan compressed asylum cases for recent arrivals into 180 to 300 days while everyone else waited years. Judges chose none of it. Prosecutors and administrators decided who landed in the fast lane and who stayed in the general backlog, and the sorting turned on a single variable. Not the merits. Not family ties. Not legal eligibility. Time.
The body count came back fast. In Los Angeles, one of eleven Dedicated Docket cities, removal orders ended 99% of the cases the court completed by February 2022. The court entered 72% of those orders in absentia — against people who never made it into the room. Nearly half of those in absentia orders fell on children, and two-thirds of those children were six years old or younger. Representation started at 15.5% and climbed to 51%, which still left more than 20,000 parents and children to face a federal courtroom alone. Those figures come from the UCLA Center for Immigration Law and Policy and from TRAC.
Linus Chan, the James H. Binger Clinical Professor of Law at the University of Minnesota and director of its Detainee Rights Clinic, traced why the clock did the killing. Congress gutted the immigration judge’s power to grant substantive relief in 1996, and what survived was a single lever: time. A continuance, an administrative closure, a slow docket — each one let a deserving case breathe, find a lawyer, gather proof, and mature. Crush the time and you crush the last chance to be heard. The backlog everyone cursed had quietly worked as a safety valve, and the Dedicated Docket welded it shut.
99%
L.A. cases ended in removal orders
72%
of those orders entered in absentia
180–300
days — the compressed timeline
The mega master is the Dedicated Docket with the clock smashed. Months collapse into a single morning. Same machine, higher gear. We do not have to guess what comes out the other end, because the experiment already published its results: a 99% removal rate and children ordered out of the country without ever seeing a lawyer. The tactic is not a theory. It is a rerun.
R. Linus Chan, Managing Deportation: How Docket Control Replaced Substantive Relief in Immigration Courts, 79 SMU L. Rev. 161 (2026). The Dedicated Docket as natural experiment, and the Los Angeles figures, appear at 184–87.
The Verdict
A first hearing opens a case. It does not close one. The government can run a crowded docket. It cannot turn the opening into an assembly line that manufactures removal orders against people who never understood the proceeding, never got a lawyer, or never got real notice. Strip the volume away and the statute reads the same as it always has.
The Dedicated Docket already showed us the floor of this trajectory, and the floor was a 99% removal rate with kids deported in absentia. The mega master drives toward the same number on a faster clock. Where it goes next: expect the first petitions for review out of the Seventh and First Circuits to test whether a mass setting can support an in absentia order on this kind of notice record. The winners will be the cases where counsel built the record early — at the hearing, not after the order. Dallas is reportedly next, so the pattern spreads before any court has ruled on it.
The crowd is the strategy, and the crowd is the vulnerability. A “mega master” setting changes nothing about the government’s burden — notice, counsel, language, and a meaningful chance to be heard all survive intact. Make the record show exactly how the volume defeated each one, and the order built to run automatic becomes an order built to be reversed.
Update: June 13, 2026
🏛️ The Mega Master Went National. Dallas Is Live.
The post named three courthouses and watched for Dallas. Within a week the tactic ran from New York to Sacramento. The courts kept the design, packed the rooms, and added a form that takes the plea before the lawyer ever arrives.
📍 The rollout reached coast to coast
Chicago, Boston, and Chelmsford opened the practice. The week of June 1 it spread everywhere at once. Each court below ran one judge through a hundred or more first hearings in a single setting, and most of those people walked in without counsel.
-
New York City, June 1
One judge drew 121 cases. The court ordered 39 people removed in absentia by 5 p.m. (THE CITY)
-
New Orleans, June 1
Staff split the room. Counsel walked one way, the unrepresented walked the other. (Verite News)
-
Fort Snelling, Minneapolis, June 1
Advocates called a 73 case mega master unprecedented. (MinnPost)
-
Washington, D.C.
Reporting places the capital among the courts already running it. (MinnPost)
-
Dallas
Confirmed. DOJ hired judges to pack the docket. (Verite News)
-
Memphis
DOJ assigned new judges to feed the same machine. (Verite News)
-
Sacramento, June 9
California courts joined the pattern. (KQED)
-
Baltimore, June 10
The court advanced hearings on a week or two of notice. (The Baltimore Banner)
⚙️ What drove the speed
Three moves built the machine.
- A nationwide directive pulls forward every master calendar set for July or later. The calendar itself became the weapon. (National Immigration Forum)
- DOJ onboarded its largest class of judges to date, 77 of them plus five military lawyers serving as judges, and roughly a third arrived straight from ICE. The hiring targeted Dallas and Memphis. (NPR)
- EOIR added a paper trap, the Pleading Declaration. A respondent signs away the pleadings on a short deadline, often before counsel ever appears. (NIJC)
🗣️ EOIR answered with the backlog
EOIR gave NPR no comment on May 26. Once the rooms filled, DOJ defended the volume as backlog control. A spokesperson said the effort remains one of the highest priorities for this administration. The backlog now runs past three million cases. That is the number the government leans on, and it is the number that never amends the statute.
📊 The numbers behind the design
Source: TRAC Immigration Quick Facts.
⚖️ The case law did not move
Urquia-Yanez v. Blanche (9th Cir. May 8, 2026).
The doctrine sits where the post left it. The Board issued no new in absentia or notice precedent since publication. Its newest Volume 29 decisions reach asylum and particular social group, not the rooms at issue here. The Seventh Circuit has not ruled on a mega master record. The freshest appellate word on notice comes out of the Ninth Circuit, and it cuts for the government. In Urquia-Yanez the panel held that an English notice of the duty to update an address satisfies due process, so a hearing notice the court mails to a stale address still binds the respondent through constructive notice. The ruling sits outside our circuit, yet it marks the exact ground the mega master works: the client who moved, the address that went cold, the notice nobody read. (Verified through Descrybe.)
🔎 What has not happened yet
No systemic lawsuit has landed. The fight stays case by case: motions to reopen, motions to continue, objections on the record. Advocacy groups condemned the practice and pushed know your rights guides, and the National Immigration Project called the hearings a tool for issuing removal orders in bulk. No class action and no restraining order yet aims at the design itself. The petitions for review the post predicted have not arrived. Counsel still builds the record one case at a time.
This post is general legal information about a developing practice in the immigration courts, not legal advice, and it does not create an attorney-client relationship. Removal proceedings turn on specific facts and deadlines. Anyone facing a master calendar hearing or an in absentia order should consult a licensed immigration attorney about their own case without delay.
