NIPNLG filed a Freedom of Information Act (FOIA) request seeking records regarding administrative removals under § 238(b) of the Immigration and Nationality Act, a summary procedure through which immigration officers may deport certain noncitizens with alleged aggravated felony convictions. After U.S. Immigration and Customs Enforcement (ICE) failed to produce responsive records, NIPNLG filed an administrative appeal. In response to the administrative appeal, ICE released some records, including a 1999 manual on Administrative Removal Proceedings and statistics regarding individuals deported pursuant to administrative removal orders between FY10 and FY15.