As of May 2019, JROs were issued in 13 of all closed cases reviewed for this report. Historically, DOJ and federal court judges have largely avoided issuing judicial removals since they both “generally have insufficient expertise to navigate the immigration code and regulations” and “[e]xplaining the rights that are being waived alone is daunting to the non-expert.”471 However, the Trump administration DOJ appears to be using them more extensively. This approach takes advantage of the historical division of the immigration and criminal systems, thwarting access to any immigration-related defenses to removal that may otherwise be available in any given case. On April 11, 2017, then Attorney General Jeff Sessions made this clear when he directed all U.S. Attorneys to seek JROs at the sentencing phase of every federal case “to the extent practicable.”472 Most deportation orders are handed down by immigration authorities, primarily immigration judges or the Board of Immigration Appeals (BIA), which has exclusive appellate jurisdiction over most decisions issued by immigration judges. Pursuant to 8 U.S.C. § 1228(c)(1), a federal judge can order a person deported by effectively bypassing the immigration court system. There is no statutory or regulatory guidance for federal district and magistrate judges on whether a JRO should be issued. The judge can either grant a JRO upon the prosecutor’s motion, or it can be “stipulated” to in a plea agreement as part of the criminal sentence. Under 8 U.S.C. § 1228(c)(5), a U.S. Attorney can “enter into a plea agreement which calls for the defendant to stipulate to the entry of a judicial order of removal from the United States as a condition of the plea agreement…” The United States district court “may accept such a stipulation and shall have jurisdiction to enter a judicial order of removal pursuant to the terms of such stipulation.” Under the statute, a stipulated JRO means that the defendant “waives a formal immigration hearing and waives the right to appeal from the order of removal.”473 INA § 238(c)(5) requires that the defendant explicitly waive the right to appeal from such orders. As noted in the 2017 DOJ bulletin, many prosecutors and immigration attorneys do not know what a JRO is, but JROs, “specifically those obtained by stipulation, offer a powerful and efficient tool for prosecuting criminal aliens—one that provides enormous value to the Department of Homeland Security (DHS) and furthers new Department of Justice policy.”474 The bulletin highlights the “unique benefits” of using JROs, such as “the defendant will leave the country, presumably permanently,” and “using the JRO as a bargaining chip to negotiate a plea with a defendant.”475 In the cases reviewed for this report, the government routinely includes language requiring the defendant to help facilitate the removal process when a stipulated JRO is included in the agreement. In addition to the inability to appeal a stipulated JRO, the implications for the defendant are immense. The defendant is unable to raise protection claims that would prevent deportation, II. Denaturalization: A Radical Measure in the Hands of Zealots 107