The Legal Aid Society, Public Justice, NYU Immigrant Rights Clinic, Free Migration Project, and Covington & Burling LLP filed a class action lawsuit on behalf of two immigrants facing ruinous civil fines of up to $1.8 million, and on behalf of the Immigrant Legal Resource Center, to challenge a long-dormant provision of immigration law revived by the Trump administration and imposed on individuals lawfully applying for immigration relief. The case seeks to represent a nationwide class of people who have received these fines. As of March 18, 2026, the Department of Homeland Security had issued over 65,000 fine notices, for a total of more than $36 billion in pending fines.

In October of 2026, the United States District Court for the District of Massachusetts granted preliminary relief to immigrants challenging the Trump Administration's unprecedented civil penalty scheme. The Court held that the regulations used by the government to impose the fines are likely unlawful because ICE and DHS failed to adequately consider individual circumstances.