39 U.S. Immigr. & Customs Enforcement, Removals Statistics (Dec. 31, 2024), https://www.ice.gov/statistics#:~:text=REMOVALS,-ICE. 40 8 U.S.C. § 1227(a) (enumerating the grounds for deportation: “[a]ny alien (including an alien crewman) in and admitted to the United States shall, upon the order of the Attorney General, be removed if the alien is within one or more of the following classes of deportable aliens” and that an alien is a noncitizen). 41 8 U.S.C. § 1101(a)(3) (defining noncitizens as aliens, stating, “[t]he term ‘alien’ means any person not a citizen or national of the United States”). But see The White House, Fact Sheet: President Biden Sends Immigration Bill to Congress As Part of His Commitment to Modernize our Immigration System (Jan. 20, 2021), https://buildbackbetter.gov/press-releases/fact-sheet-president-biden-sends-immigrationbill-to-congress-as-part-of-his-commitment-to-modernize-our-immigration-system/ [https://perma.cc/MR7X-MXTH] (proposing a comprehensive immigration bill to remove the term “alien” with the Immigration and Nationality Act); Catherine E. Shoichet, Biden Wants to Remove This Controversial Word from US Laws, CNN (Jan. 21, 2021), https://www.cnn.com/2021/01/21/politics/alien-biden-immigration-law/index.html [https://perma.cc/K648-D9SW] (“The term ‘illegal alien,’ long decried as a dehumanizing slur by immigrant rights advocates, became even more of a lightning rod during the Trump era—with some top federal officials encouraging its use and several states and local governments taking up measures to ban it.”). 42 Id. 43 8 U.S.C. § 1229(a)(2) (“An alien placed in proceedings under this section may be charged with any applicable ground of inadmissibility under section 1182(a) of this title or any applicable ground of deportability under section 1227(a) of this title.”). 44 See generally Homeland Security Act of 2002, Pub. L. No. 107–296, 116 Stat. 2135 (codified as amended in scattered sections of 6 U.S.C. and 8 U.S.C.) (creating the DHS). 45 See generally 8 U.S.C. § 1357 (listing the duties of ICE officers). 46 6 U.S.C. § 211, amended by Pub. L. 116–277, 134 Stat. 3368 (2020) (listing the duties of Customs and Border Protections). 47 See generally 8 U.S.C. § 1357. 48 Press Release, U.S. Immigr. & Customs Enforcement, ICE releases Fiscal Year 2024 Annual Report (Dec. 19, 2024), https://www.ice.gov/news/releases/ice-releases-fiscal-year-2024-annual-report (“ICE continued to prioritize its enforcement resources by arresting noncitizens with criminal convictions or pending charges. Over 81,312 (71.7%) of the 113,431 arrests were of noncitizens with criminal convictions or pending charges. In contrast, 73,822 (43%) of the 170,590 noncitizens arrested in fiscal year 2023 had criminal histories”); see also, TRAC Immigration, Tracking Over 2 Million ICE Arrests: A First Look (Sept. 25, 2018), https://tracreports.org/immigration/reports/529. 49 U.S. Immigr. & Customs Enforcement, Immigration Detainers (Apr. 8, 2025), https://www.ice.gov/immigration-detainers. 50 See generally 8 U.S.C. § 1357. 51 6 U.S.C. § 211, amended by Pub. L. 116–277, 134 Stat. 3368. 52 Off. of Homeland Sec. Stats., Table 34. Aliens Apprehended by Region and Country of Nationality: Fiscal Years 2016 to 2018, https://ohss.dhs.gov/topics/immigration/yearbook/2018/table34 (last visited Apr. 17, 2025); Off. of Homeland Sec. Stats., Table 34. Title 42 Expulsions and Noncitizen Apprehensions by Region and Country of Nationality: Fiscal Years 2013 to 2022, https://ohss.dhs.gov/topics/immigration/yearbook/2022/table34 (last visited Apr. 17, 2025). 53 Susannah N. Tapp & Elizabeth J. Davis, Contacts Between Police and the Public, 2022, Bureau of Just. Stats. (2024), https://bjs.ojp.gov/document/cbpp22.pdf. 54 Tanya Golash-Boza, Deported: Immigrant Policing, Disposable Labor and Global Capitalism (N.Y. Univ. Press 2015) (“Black and dark-skinned immigrants ‘face more systematic and authoritative racial boundaries’ than their lighter-skinned counterparts. . . . Dominican West Indian males in [the] survey were as likely to report problems with the police as African Americans.” (citing Philip Kasinitz et al., Inheriting The City: The Children of Immigrants Come of Age 303 (Russell Sage Found. 2008))). 55 Maddie Khaw, ICE Has Secretly Been Recording Inaccurate Data, Hiding Racial Disparities, truthout (Oct. 31, 2024), https://truthout.org/articles/ice-has-secretly-been-recording-inaccurate-data-hidingracial-disparities/. BAJI’s tabulation of the Department of Homeland Security’s Yearbook of Immigration