Quick Guide: Defending SIJS Clients in Removal Proceedings

This practice advisory, created by The End SIJS Backlog Coalition and partner organizations and last updated in May 2026, is intended to help practitioners navigate removal proceedings for clients with approved SIJS. It offers strategies at every stage of an SIJS client’s removal proceedings to advocate against the client’s removal and to preserve the record for appeal. Section II provides a brief background on SIJS deferred action. Section III covers strategies for pleading to the Notice to Appear. Section IV discusses challenging the Department of Homeland Security’s evidence of removability. Section V highlights arguments that can be made once removability has been established to avoid removal and/or preserve the best record for appeal. Section VI offers strategies after an immigration judge has ordered removal. Section VII discusses detention issues that SIJS youth may face. And Section VIII talks about risk mitigation strategies for SIJS clients who may be vulnerable to expanded expedited removal.