On January 25, 2017, President Donald J. Trump issued Executive Order 13,768, Enhancing Public Safety in the Interior of the United States (EO), which set forth the Administration’s immigration enforcement and removal priorities. The Department of Homeland Security’s (DHS) February 20, 2017 memorandum, Enforcement of the Immigration Laws to Serve the National Interest(implementation memorandum) provided direction for the implementation of the policies set forth in the EO. The EO and implementation memorandum expanded ICE’s enforcement focus to include removable aliens who (1) have been convicted of any criminal offense; (2) have been charged with any criminal offense that has not been resolved; (3) have committed acts which constitute a chargeable criminal offense; (4) have engaged in fraud or willful misrepresentation in connection with any official matter before a governmental agency; (5) have abused any program related to receipt of public benefits; (6) are subject to a final order of…