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The Trump administration issued, on February 18, 2025, a stop work order that abruptly halted a federal program with more than two decades of existence: government-funded legal assistance for unaccompanied immigrant children in deportation proceedings. The measure affected approximately 26,000 minors in custody or released from the Office of Refugee Resettlement (ORR), mostly children who had crossed the border alone and were under government responsibility while going through hearings in immigration courts. The decision sparked a legal conflict whose practical effects extended throughout the following year.
The Suspended Program
Since the mid-2000s, the Department of Health and Human Services (HHS), through the ORR, contracted the Acacia Center for Justice (formerly operated by the Vera Institute of Justice) to coordinate a national network of nonprofit organizations providing free legal guidance to unaccompanied minors. Among the subcontractors were the Immigrant Defenders Law Center (ImmDef), the Florence Immigrant and Refugee Rights Project, Kids in Need of Defense (KIND), the Catholic Legal Immigration Network, and dozens of local organizations. The active contract, with an annual value estimated in the hundreds of millions of dollars, funded two distinct services: Know Your Rights presentations in ORR shelters and direct legal representation of minors in removal proceedings.
The nature of this work was specific: identify which children were eligible for immigration relief (Special Immigrant Juvenile Status, asylum, T visas for trafficking victims, and U visas for victims of violent crimes) and bring them to immigration court hearings that would otherwise occur without any legal representative. Unlike the criminal system, minors in immigration court have no constitutional right to a public defender; without the Acacia program, thousands of children, some only months old, appeared alone at hearings.
What the Order Required
The stop work order issued by HHS instructed the Acacia Center for Justice and its subcontractors to immediately and indefinitely cease all work funded by the contract. This included:
- Ending individual consultations with minors in ORR shelters;
- Suspending representation at hearings scheduled for the days and weeks following;
- Ceasing Know Your Rights presentations;
- Performing no new work under the federal contract.
The immediate risk was legal: for children with hearings scheduled in the days after the stop work order, failure to appear or presence without legal representation could result in an in absentia deportation order or an unfavorable decision made without the minor even understanding the proceedings. Some of the affected organizations announced they would continue representing their clients pro bono, arguing that ethical obligations under state bars superseded the administrative contract order.
The Litigation and Partial Reversal
On February 27, 2025, the Acacia Center for Justice and ten subcontractors sued the administration in the Federal District Court for the Northern District of California, alleging that the stop work order violated the Trafficking Victims Protection Reauthorization Act (TVPRA), which in 2008 established the federal obligation to ensure, to the greatest extent practicable, legal representation for unaccompanied minors.
On March 26, 2025, Judge Araceli Martínez-Olguín granted a preliminary injunction restoring funding and requiring the government to maintain the active contract while the merits were decided. By mid-2025, parts of the program had resumed, but with complications: some subcontractors reported delays in disbursements, burdensome reporting requirements, and uncertainty about contract renewal at the end of the fiscal year.
The underlying question of whether the Executive Branch can unilaterally cancel legal services for children in federal custody remains in dispute in the courts in 2026. The parallel with the simultaneous interruption of funding for legal orientation services for ICE-detained adults (Legal Orientation Program) is direct: that program was also reactivated after litigation, but with reduced coverage and more restrictive conditions.
Impact on the System
Consistent studies over fifteen years show that children with legal representation are far more likely to obtain some form of immigration relief, including SIJS, asylum, and U visas, than unrepresented children. Research published by the Vera Institute in prior years identified success-rate differences on the order of ten to twenty times higher between represented and unrepresented minors. When the government withdraws funding for representation, it effectively shifts onto overburdened courts the burden of processing complex cases with petitioners who cannot articulate their own defense, increasing the error rate and reducing the accuracy of decisions.
There is also the child protection dimension. Many of these children are victims of trafficking, domestic abuse, or sexual violence in their countries of origin. Eligibility for SIJS requires a state family court order documenting abandonment, abuse, or parental neglect, a step that children cannot complete on their own. Without an attorney, the path to SIJS, even when legally viable, remains closed.
The Landscape in 2026
For families and professionals tracking unaccompanied minor cases in 2026, three practical points remain relevant:
- The Acacia program has partially resumed, but allocation by region and service type may be reduced; verify directly with the local organization before assuming coverage;
- Complementary pro bono organizations such as KIND and Justice for Children operate independently of the federal contract and continue accepting new cases, with varying waitlists;
- Ongoing litigation may result in contractual changes or changes to the program structure itself; monitoring decisions from federal courts and the Ninth Circuit is essential for long-term planning.
The episode exposed a structural vulnerability: federal legal defense programs for vulnerable populations depend on renewable administrative contracts, not on statutorily protected rights. As long as this architecture remains in place, a single stop work order can leave tens of thousands of children, overnight, without a voice in the system that decides whether they will remain in the United States.
Victoria Harper
Editor-in-Chief
Leading journalism and editorial content at Visto n’ Visa, Victoria helps make immigration topics clear, trustworthy, and easy to understand. Her focus is on delivering useful, human, and relevant content for people exploring new paths abroad.
