10/3/25, 1:43 PM Practice Alert: “Freaky Friday” ICE Operation Targeting Minors

PRACTICE RESOURCES

Practice Alert: “Freaky Friday” ICE

UPDATE: As of 10/03/2025 2:30 PM ET, AILA has not heard of someone receiving one of these threat letters and cannot confirm if this
operation has started.

Confirmed rumors indicate that ICE is planning to launch a nationwide operation today, Friday October 3, reportedly named “Freaky
Friday” that will target unaccompanied children of all nationalities aged 14 and older. AILA has received information from several trusted
sources. Here is what we know:
Children detained and released will be served a “threat” letter from ICE threatening indefinite detention and immediate transfer to
ICE upon age-out if they do not waive jurisdiction under the Trafficking Victims Protection Reauthorization Act (TVPRA) and withdraw
applications for relief, including withdrawing their request for admission with EOIR.
Children will be “offered” $2,500 to return to their countries of origin.
If children do not comply with the “offer,” the letter may indicate their parents/family living in the U.S. will be arrested.
ICE plans to detain all age-outs, and they anticipate legal challenges.
It is possible that the age threshold for this threat letter may be lowered to children 10 years old and older.
Aside from the already existing ICE enforcement actions, ICE will potentially target detained children, but will also focus on children
released from custody. Children 17+ are at heightened risk of being targeted, whether released or detained.
AILA will provide more information as the situation develops.
Some private and non-profit legal service providers have suggested the following steps:
Consider advising children, whether in custody or released about the possibility of receiving a letter and to immediately notify their
attorney if they receive a letter.
Provide Know Your Rights (KYR) presentations to all children and/or their guardians you are working with as soon as practicable,
advising them of this plan and their right not to sign anything without consulting their attorney.
Sign G-28 and L-3 forms for all children, whether in custody or released from custody, as capacity allows. If the child is in the care
and custody of ORR, file your L-3 with the FFS, Program Director, Case Manager, asking you to be notified of ICE enforcement actions,
including the delivery/service of the “threat letter.”
If a child receives a letter, consider the following:
Sending an email to the UC Ombudsman, Ombuds@acf.hhs.gov
Sending an email to the FOJC and OPLA
Sending an email to the FFS and Program Director
Obtain release for advocacy, i.e. sharing case information with media, agency stakeholders, potential class counsel.
Preparing a declaration that particularly highlights the following, which may help litigators challenge this practice:
1. The manner in which the ICE letter was delivered (Was counsel present and able to advise? Was the child able to ask
questions? etc.).
2. Evidence of coercion or intimidation.
3. The underlying fear of return elements related to child’s relief application.
Clients Approaching their 18th Birthday
The Garcia Ramirez permanent injunction requires ICE to comply with the age-out protections in 8 U.S.C. § 1232(c)(2)(B) by considering
“placement in the least restrictive setting available” and ensuring those young people are eligible for alternatives to detention.
The American Immigration Council and National Immigrant Justice Center are class counsel in Garcia Ramirezand are monitoring for
violations of the permanent injunction in that case arising from this new operation. If attorneys have clients in ORR custody who are
approaching their 18th birthday and who are now threatened with ICE detention, they should
contact clearinghouse@immcouncil.org and litigation@immigrantjustice.org.
Clients Impacted by LGML or JOP Litigation
https://www.aila.org/library/practice-alert-freaky-friday-ice-operation-targeting-minors?utm_campaign=24112792-Hubspot-AILA8-10-3-25&utm_medium=email&_hsenc=p2ANqtz-89LrojSXGdI6gA0y2-0OZhsqGGvNa5… 1/2
10/3/25, 1:43 PM Practice Alert: “Freaky Friday” ICE Operation Targeting Minors

In L.G.M.L. et al. v. Kristi Noem, et al., a federal district court for the District of Columbia issued an injunction barring the government from
removing Guatemalan children in ORR custody without due process. Nonetheless, it is possible L.G.M.L. class members may still be issued
a “threat letter.” It is unclear whether the class action protections will remain in place if a child signs the letter.
On November 25, 2024, the U.S. District Court for the District of Maryland granted final approval of the settlement agreement reached by
the parties in J.O.P. v. DHS, No. 8:19-CV-01944-SAG (D. Md.). The settlement prevents DHS from removing J.O.P. class members. It is
possible J.O.P. class members may still be issued a “threat letter.” Whether the class action protections would remain operative if a child
signs the letter is unknown.
Potential Impact of H.R. l
Whether (and how) the July 2025 bill H.R. 1 impacts the Flores settlement is an open question that will likelyneed to be decided in court.

If you have thinkyour clients may be affected by this operation, please report it to the ICE committee through the “Report a Trend” form
linked here.

Special thanks to AILA EOIR and Asylum committee members for their contributions.

https://www.aila.org/library/practice-alert-freaky-friday-ice-operation-targeting-minors?utm_campaign=24112792-Hubspot-AILA8-10-3-25&utm_medium=email&_hsenc=p2ANqtz-89LrojSXGdI6gA0y2-0OZhsqGGvNa5… 2/2