President Donald Trump listens as Secretary of State Marco Rubio speaks during a cabinet meeting at the White House in Washington, Monday, March 24, 2025 (Pool via AP).
A federal judge in Washington, D.C., on Wednesday restored an Indian woman's legal status under an exchange program in a vituperative ruling that takes the Trump administration to task for its "unlawful actions" against international college students writ large.
The 20-page memorandum opinion comes in a series of cases in which judges have had the occasion to restore such statuses after Immigration and Customs Enforcement (ICE) imposed summary terminations affecting thousands of students beginning in April 2025.
In the case, Mansi Reddy Bushireddy was among those thousands of students singled out by ICE and subject to termination of her status in the Student and Exchange Visitor Information System (SEVIS).
On April 11, 2025, Bushireddy sued, alleging violations of the Administrative Procedure Act (APA), the federal statute governing the behavior of administrative agencies. Within days of filing her lawsuit, the plaintiff won a temporary restraining order issued by U.S. District Judge Sparkle L. Sooknanan, a Joe Biden appointee.
Since then, quite a bit has changed — including a substantial effort by ICE to backtrack on the entire SEVIS-ending scheme.
"ICE has since returned Ms. Bushireddy's SEVIS record to active status," the opinion notes. "It has promulgated a new internal policy regarding termination of SEVIS records. And it has represented that it has no plans to re-terminate Ms. Bushireddy's record based on the dismissed shoplifting charge that prompted its earlier termination. In light of these actions, the Government asserts that this lawsuit is now moot because there is no additional relief that this Court can award."
Bushireddy, however, disagreed. So did the judge.
"ICE has not carried its 'heavy burden' of proving that the challenged conduct cannot reasonably be expected to recur," Sooknanan says.
To hear the court tell it, "ICE's actions" since the litigation began "do not make 'absolutely clear' that it will not resume the challenged conduct," despite some assurances from the agency that it has "no plans to re-terminate" her.
That is, in terms both specific — to Bushireddy — and general — to other international students — the court is not taking ICE at its word.
In the plaintiff's case, ICE "offers no guarantee that it would not terminate her record in [the] future for some other comparable event that is similarly untethered to the appropriate statutory and regulatory bases for termination," the court observes.
When it comes to how the SEVIS-ending efforts drew to a close, the court was not convinced by the purported protections for students.
From the opinion, at length:
The [new] policy affirms that [ICE] can terminate SEVIS records when there is "evidence" that an individual has failed to maintain status but sets no additional guardrails for how the agency makes that determination. As a result, it does nothing to prevent ICE from again invoking that basis inappropriately…As other courts in this District have noted, "when [a] revised policy 'disadvantages' the plaintiff 'in the same fundamental way,' there may be serious doubts about whether the promulgation of the new policy has any significant effect on the action."
The court also ruled on the merits of case, finding the termination of Bushireddy's SEVIS record a "final agency action" under the APA from "which legal consequences…flow."
"Termination of a student's SEVIS record requires them to leave the country immediately," the court notes. "And DHS's website advises that students whose SEVIS records are terminated for failure to maintain status lose their employment authorization and may be investigated by ICE to confirm their departure."
And, the court notes, while Bushireddy ultimately was not deported, the action taken by ICE in the first place has resulted in a series of "effects" due to the "alleged violation" which do not just go away.
Again the opinion, at length:
ICE acknowledges that while it has reset Ms. Bushireddy's SEVIS designation to "active," her record will continue to reflect her "prior termination" and subsequent "restoration." This is because "the event history for a given record cannot be deleted from the system." ICE also acknowledges that after it terminated Ms. Bushireddy's SEVIS record, the State Department revoked her F-1 visa. Ms. Bushireddy represents that this revocation "remains in place" and that at some point she "will be required to attend a new interview at a consulate" to get a new visa.
In a footnote, the court says the knock-on effects of the wholesale SEVIS-ending dragnet mean thousands of other international students are still suffering from improperly canceled visas.
"The Court is outraged by the series of events that unfolded that led to the revocation of thousands of student visas," the footnote reads. "ICE referred lists to the State Department with a nudge that it review those students' active F-1 visas. The State Department then revoked visas for thousands of those students, a decision that is unreviewable by any court."
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