This article was published in partnership with The Marshall Project, a nonprofit news organization covering the US criminal justice system. Sign up for their newsletters, and follow them on Instagram, TikTok, Reddit, and Facebook.
For about five days in December, Abdullahi Mohamed seemingly vanished into the US immigrant detention system. Immigration and Customs Enforcement had detained him near Portland, Maine, and held him for more than seven weeks in Massachusetts. Then, without warning, ICE began moving him repeatedly across the country, from state to state and facility to facility, faster than his family could keep up. News of his whereabouts came to them in fragments: an email from his lawyer that he was in Mississippi; a phone call from the wife of a fellow detainee who said he was in Louisiana; and at one point, a call from Mohamed himself—that lasted for about two minutes—from an undisclosed airport.
His lawyer laid out what was happening. “They are doing this now more and more—moving people without any notice,” he wrote to the family in an email. The transfers, he explained, can block people like Mohamed from speaking with an attorney and make it difficult to file legal petitions in the right jurisdiction, while distressing families. “This is cruelty,” he wrote.
Quick and repeated transfers have become more common in President Donald Trump’s second term, a Marshall Project investigation has found. From the final year of the Biden administration to the first year of Trump’s latest term, the number of people transferred five or more times more than tripled. The number of people transferred out of state within 24 hours more than doubled, according to a Marshall Project analysis of ICE detention data obtained by the Deportation Data Project.
Immigration lawyers say the many transfers not only cause undue suffering for people being detained and their families but have significantly undermined due process protections. Because detainees have limited access to phones while in transit, and ICE’s detainee locator does not always reflect their real-time location, immigration attorneys say rapid transfers can leave people unreachable for hours or even days. Families can lose track of their relatives, while lawyers struggle to locate or speak with clients.
During those gaps, attorneys say, some detainees have been pressured to sign forms affecting their immigration cases before they can speak with counsel.
“What often happens is that a lawyer or family member will show up to see somebody and be told, ‘That person’s not here, and we don’t know where they are,’” said César Cuauhtémoc García Hernández, an Ohio State University law professor who focuses on the intersection of criminal and immigration law. “Effectively, that person has just disappeared while in the custody of the US government.”
“Effectively, that person has just disappeared while in the custody of the US government.”
In an emailed response to written questions, an ICE spokesperson said claims that transfers are being “weaponized” are “categorically false,” and that “all detainees receive full due process.” The spokesperson also said detainees have access to phones for contacting relatives and lawyers, receive a court-approved list of free or low-cost attorneys, and can be “easily” located by relatives, lawyers, and media through ICE’s online locator.
“Despite a historic number of injunctions, DHS is working rapidly and overtime to remove these aliens from detention centers to their final destination—home,” the spokesperson said.
Mohamed came to the US from Somalia in 1999 and applied for asylum, he told The Marshall Project. Federal records show that an immigration judge ordered his removal in 2001, and that his appeal was dismissed in 2002. Mohamed was allowed to stay in the US for years during a period when deportations to Somalia were difficult to carry out, as the country had no functioning central government and remained fractured by civil war. Under an order of supervision, he had to check in regularly with ICE for more than two decades to keep a valid work permit. He paid his taxes and had no criminal record, his family said. Eventually, he got married and settled in Maine, where he was working as a cab driver by fall 2025. ICE seized him in October when he showed up for a regular check-in.
After several weeks in detention, he vanished. The decades Mohamed had spent building a life in the U.S. unraveled in less than a week. When his family spoke to him next, he was calling from Somalia. He had been deported. For his sister, Saynab Mohamed, and her daughter, Eza Nour, each update arrived too late and never from ICE itself. “I think the whole point was to traumatize us,” Nour said, “and leave us with a lasting scar.”
“I think the whole point was to traumatize us, and leave us with a lasting scar.”
Transfers have long been a feature of immigration detention. ICE uses a network of hundreds of facilities across the US and has broad discretion to transfer people for bed space, medical care, security and other operational reasons. But during the past year, attorneys say, those moves have carried higher stakes because the legal landscape around detention has changed dramatically.
In July 2025, the Department of Homeland Security adopted a new interpretation of a 1996 immigration law: ICE could now treat people who had come into the US without being formally admitted by immigration officials as if they were “arriving aliens” still seeking admission at the border, even if they had lived here for years before being detained. That made them ineligible for bond hearings before immigration judges. Before this shift, people could ask a judge to decide whether they were a flight risk or a danger to the community, and if they could be released while their immigration case continued.
Then, in September, the Board of Immigration Appeals—an administrative body within the Justice Department that sets precedent for immigration courts—made that interpretation binding nationwide, largely cutting off immigration judges’ ability to grant release and allowing ICE to detain people indefinitely.
Lawyers turned to federal court to file habeas corpus petitions to challenge whether the government had the authority to keep their clients detained. Earlier this year, more than 200 petitions were being filed every day across the country. However, habeas petitions generally must be filed in the federal district where a person is detained. If someone is moved before a lawyer files, the petition has to be filed in the new location, setting up a cycle where lawyers may struggle to file before their clients are moved again.
At the same time, federal courts are divided regarding the legality of the government’s new detention policy. The 5th Circuit Court of Appeals, which covers Texas, Louisiana and Mississippi and is widely regarded as one of the most conservative federal appeals courts, is one of two that have backed the administration on the policy. Those three states are also home to “Detention Alley,” a cluster of sites that include 14 out of the 20 largest detention facilities in the country. Many are located in remote, rural areas, and together they have helped make the region a major hub for detention and deportation in the south. In the first year of Trump’s second term, nearly three-quarters of the people ICE deported were last detained in a state covered by the 5th Circuit.
Transfers can now carry immediate legal consequences, attorneys say. The location where ICE sends someone often determines where a habeas petition is filed and which court gets to hear it. “They’re trying to get as many people to the 5th Circuit as possible,” said Dan Gividen, a Texas-based immigration lawyer who was deputy chief counsel for ICE from 2016 to 2019. “It’s in no way surprising that ICE, [which] in many ways gets to forum-shop, gets to choose the judge, is sending people to this circuit.”
In July 2025, the Department of Homeland Security adopted a new interpretation of a 1996 immigration law: ICE could now treat people who had come into the US without being formally admitted by immigration officials as if they were “arriving aliens” still seeking admission at the border, even if they had lived here for years before being detained. That made them ineligible for bond hearings before immigration judges. Before this shift, people could ask a judge to decide whether they were a flight risk or a danger to the community, and if they could be released while their immigration case continued.
Then, in September, the Board of Immigration Appeals—an administrative body within the Justice Department that sets precedent for immigration courts—made that interpretation binding nationwide, largely cutting off immigration judges’ ability to grant release and allowing ICE to detain people indefinitely.
Lawyers turned to federal court to file habeas corpus petitions to challenge whether the government had the authority to keep their clients detained. Earlier this year, more than 200 petitions were being filed every day across the country. However, habeas petitions generally must be filed in the federal district where a person is detained. If someone is moved before a lawyer files, the petition has to be filed in the new location, setting up a cycle where lawyers may struggle to file before their clients are moved again.
At the same time, federal courts are divided regarding the legality of the government’s new detention policy. The 5th Circuit Court of Appeals, which covers Texas, Louisiana, and Mississippi and is widely regarded as one of the most conservative federal appeals courts, is one of two that have backed the administration on the policy. Those three states are also home to “Detention Alley,” a cluster of sites that include 14 out of the 20 largest detention facilities in the country. Many are located in remote, rural areas, and together they have helped make the region a major hub for detention and deportation in the south. In the first year of Trump’s second term, nearly three-quarters of the people ICE deported were last detained in a state covered by the 5th Circuit.
Transfers can now carry immediate legal consequences, attorneys say. The location where ICE sends someone often determines where a habeas petition is filed and which court gets to hear it. “They’re trying to get as many people to the 5th Circuit as possible,” said Dan Gividen, a Texas-based immigration lawyer who was deputy chief counsel for ICE from 2016 to 2019. “It’s in no way surprising that ICE, [which] in many ways gets to forum-shop, gets to choose the judge, is sending people to this circuit.”
Rapid out-of-state transfers have become more common. In Trump’s first year back in office, ICE transferred nearly 41,700 people to another state within 24 hours, more than double the number the previous year, according to a Marshall Project analysis of detention data. The agency rapidly transferred more than 1 in 10 people out of state within the first day of being detained.
Lawyers can be left with little time to respond, said Cassandra Charles, a senior staff attorney at the National Immigration Law Center. “It seems that people are being transferred out of more favorable jurisdictions to less favorable ones,” she said. “That puts the attorneys in positions where they have to file very quickly.”
By the time a lawyer is ready to act, the case may already belong to a different court. “It’s like having the rug pulled out from under your feet,” she said.
One move after another kept shifting the ground beneath Diana Elizabeth Cartagena Hueso’s case. Hueso and her husband were detained in Elizabeth, New Jersey, on January 27 while on their way to a doctor’s appointment, according to a February 26 federal court opinion granting her release. Hueso, a 29-year-old citizen of El Salvador, had passed a 2016 credible fear interview, a screening that allowed her to continue pursuing protection in the US. She filed an asylum application in 2017, according to her lawyer, Noemi Simbron.
Hueso hired Simbron as her attorney a few weeks after being detained. “[Because] they move people really fast, I make a commitment to the clients [who] retain me that I file a habeas within 24 hours,” she said. Simbron filed the petition from a plane on Feb. 13.
Four days later, a federal judge in New Jersey ordered the government to give Hueso a bond hearing within 10 days and in the meantime barred ICE from transferring her out of state.
But it was already too late. ICE had transferred her to Oklahoma the day before the judge’s order, according to court records. On February 17, the same day the court said she could not be moved—she was transferred again, this time to Texas. Two days later, ICE again sent her to Oklahoma. Simbron said Hueso was moved two more times within Texas after that, for a total of five transfers before she was finally released. She was detained for about a month.
In the ruling, the judge criticized the government’s handling of Hueso’s transfers, noting that officials never clarified why she had been “transferred three times in two days.” Her case, he wrote, reflected a broader pattern of immigrants being “shifted repeatedly around the country without warning or explanation.” The government’s conduct “can now only be deemed intentional,” the judge concluded.
During Hueso’s transfers, her lawyer and family had little idea where Hueso was, Simbron said. “She was moved away so many times, it was just so scary, like how fast they were moving her,” she added. Simbron repeatedly refreshed the detainee locator, called the U.S. attorney’s office, and waited for a call from Hueso. At one point, Simbron said, Hueso managed a single three-minute phone call to her family to say she had been moved. But as her lawyer, Simbron didn’t get the chance to talk to her during these transfers, she said.
Hueso declined to speak with The Marshall Project because her immigration case remains active. Simbron spoke on her behalf, explaining that after her release, Hueso said the repeated shuffling caused fear and frustration. Hueso had known about the judge’s order and kept bringing it up to officers, who told her she was “going home,” Simbron said. At first, she thought they meant New Jersey. Eventually, she realized they meant El Salvador.
“It was like mind games and gaslighting her.”
“It was like mind games and gaslighting her,” Simbron said.
Communication gaps can carry serious consequences if ICE is asking people to make fundamental decisions about their cases—including whether to keep fighting, accept deportation or sign documents they may not fully understand— while not able to speak with a lawyer.
“If an officer is saying, ‘Yeah, you don’t have any chance of staying in the US, this is the best option you have,’ [detainees] don’t have a lawyer who can actually look at the facts of their immigration case and tell them, ‘OK, here are your options,’” said Tess Hellgren, a supervising attorney at the National Immigration Project. “It deprives them of agency over their case so much, and they’re not getting the correct information about what their different choices are.”
In an Oregon case last fall involving farmworkers detained in and near Woodburn, attorney Kelsey Provo wrote in a federal court declaration that she and her colleagues raced to advise detainees because, from prior experience, they knew that “ICE transfers people out of the facility quickly.” Provo added that “both prior to and after transfer, ICE pressures people to sign documents waiving important rights.”
One of those detainees was a woman identified in court records as M-J-M-A, a 45-year-old Mexican citizen arrested on October 30 on her way to work. She and more than two dozen others were taken to the Portland ICE facility, where Provo and her colleagues waited about an hour before meeting with the first detainee. M-J-M-A had entered the country legally in January 2025 and overstayed her visa, the government said in a court filing. In her own declaration, she wrote that she feared returning to Mexico and intended to apply for asylum.
By the time Provo and her colleague met with her at noon, M-J-M-A had already been forced by an ICE officer to sign a document she didn’t understand, according to her declaration. The officer also told her that if she didn’t agree to be removed voluntarily, “it would take a very long time for [her] to leave.”
The document she signed was in Spanish. It is a routine form that detainees and those undergoing immigration proceedings are asked to fill out. It lays out a detainee’s rights and asks them to choose how they want their case to proceed. M-J-M-A selected the option on the form that waived her right to an immigration court hearing and requested that she return to her home country as soon as possible.
Provo said a person has a right to consult a lawyer when answering the questions on the form “because they are making important decisions about the future of their rights and what rights they want to exercise and what rights they want to give up.”
Weeks later, at an evidentiary hearing, the ICE officer who had presented the document to M-J-M-A “was unable to translate lines from the form that he claimed to have discussed with and explained” to her, the judge wrote in a later order. The officer’s testimony raised “significant doubts about the quality and depth of communications” with M-J-M-A “as she considered her due process rights and made vital decisions,” the judge wrote.
When Provo and her colleague finally met with M-J-M-A, they had about 10 minutes before an officer ended the meeting, Provo said in her declaration. Shortly after, ICE officers shackled M-J-M-A and loaded her onto a bus headed to Tacoma, Washington. Nearly a full day would pass before she appeared in the detainee locator, and the earliest her lawyers could meet with her was about two days later.
At that point, Provo was growing increasingly concerned that M-J-M-A, without access to legal advice, might sign documents affecting her case.
But because M-J-M-A’s lawyers had filed a habeas petition just eight minutes before she was moved out of state, the case remained before a federal court in Oregon. Hellgren, who worked with the legal team at the time, said that meant M-J-M-A could be released and that it was still possible for a court to step in and scrutinize what had happened to her. Without that intervention, what happened in her case may have stayed hidden, Hellgren said.
Mohamed was moved so rapidly during the final days of his detention that the narrow options his lawyer and family were pursuing never had a chance to materialize. They were no longer trying to reopen the case involving his old removal order, but were instead trying to get him released from detention long enough for him to get his affairs in order before leaving the country. In emails to the family in mid-December, his lawyer wrote that ICE had not responded to those requests despite weeks of calls and emails. He also didn’t know whether the government had secured the travel documents needed to deport Mohamed, even as the family tried to determine if there was still time to file a habeas petition.
Then, suddenly, ICE started moving Mohamed around the country. He eventually called his family from Mogadishu and relayed his deportation journey. In about five days, he told them, ICE had sent him from Massachusetts to Mississippi to Louisiana and then to Texas. From there, he boarded a deportation flight that crossed several countries in West, Central and East Africa, until he finally landed in Somalia. He said he had been beaten and shackled, and had endured long stretches without food or water.
In about five days, ICE had sent him from Massachusetts to Mississippi to Louisiana and then to Texas. From there, he boarded a deportation flight that crossed several countries in West, Central and East Africa, until he finally landed in Somalia.
“There is no family for me here,” Mohamed told The Marshall Project from Mogadishu. “Nothing. No future.”
Since his deportation, his wife has been in hiding due to her own immigration status. She spent hours on the phone with Mohamed, trying to figure out how to help him and what was left of the future they planned together, Saynab Mohamed said. “When your partner for life is gone, you feel kind of lost,” she said.
Abdullahi Mohamed said he has no way to support himself in Somalia, a country he hasn’t lived in for decades. His parents are dead, and Saynab Mohamed, his only living sibling, is the main reason he had built a life in the U.S. To help offset medical and legal costs, his family has set up a GoFundMe.
In the first year of Trump’s second term, ICE detained and deported 13,500 people in much the same way as Mohamed. Within a week, they were first transferred from the facility where they had been detained for a lengthy period and then sent to a series of other facilities before being deported. This represents more than twice the number of people the US government had similarly deported during the previous year, an increase that far outpaced the growth in the overall number of people the government detained.
According to the agency’s 2025 national detention standards, when deciding on a transfer, ICE takes into account whether a detainee is represented before the immigration court. ICE will consider alternatives to transfer, especially if the lawyer is nearby and court proceedings are underway. The standards also say detainees are not told about a transfer until just before they leave the facility, when ICE notifies them they are being moved to another facility in the U.S. and not being deported. They are then given the new facility’s contact information in writing, and the standards say ICE will contact the attorney of record.
But much of the process that ICE uses to decide when and where to move someone remains opaque, attorneys say.
“The rules are absolutely not clear,” said Hellgren, who was part of the legal team that sued ICE last year for records explaining how the agency decides where to detain and when to transfer those in its custody. “We don’t even know what all their own policies are because of the lack of transparency here,” she said.
During the litigation last year, ICE ultimately produced a limited set of documents, including a three-page “detainee transfer checklist” used when the agency moves someone outside the “area of responsibility,” meaning the geographic region overseen by a local field office. The checklist directs officers to document whether the detainee has an attorney of record in that region, immediate family ties, or a pending court case. If any of those factors apply, a senior official must approve the transfer. The form also says attorneys are to be notified of a transfer “as soon as practicable” and no later than 24 hours after it happens.
In her experience, Hellgren sees no evidence that those factors are being considered. “The speed of transfers is so extreme,” she said, “it’s hard to understand how they could be considering these factors.”
In late March, a federal judge in Minnesota extended an order that barred ICE from transferring people out of state during the first 72 hours of detention, a restriction meant to stop rapid transfers from cutting detainees off from their lawyers. The order also required ICE to ensure that the locator stays updated, and required that it provide free, private phone access to detainees while informing them where they would be transferred. Attorneys say broader reforms could follow the same logic by requiring ICE to give people notice of available legal help as soon as they’re detained, and to provide the time and private space for meeting with lawyers, interpretation when needed, and access to relevant arrest and detention paperwork before they are transferred.
After Mohamed’s sudden removal, his family flew to Maine to retrieve his car and drive it back to North Carolina, where they live. They had to sort out the title and the rest of his belongings, Nour said.
On the drive, they called Mohamed so he could guide them through the roads from memory. “He’s American, he’s telling us the roads,” Nour said. “He knows it better than we do.”
Methodology
The Marshall Project analyzed detention stint data from ICE obtained and processed by the Deportation Data Project.
Each row of data represents a detention stint, a person’s period of confinement in a single facility. Many people have multiple detention stints as they are transferred from facility to facility throughout their stay in detention. The data includes a unique identifier for each person. Some people were detained for multiple stays in the period covered by the data.
We began our analysis by grouping the stints into stays, counting the stints and then calculating the time between the book-in and book-out dates of the person’s stay, as well as the book-in and book-out of each stint.
The Deportation Data Project’s data contains records for people in detention between October 1, 2022, and March 11, 2026. We analyzed detention stays with book-in dates during the first year of the second Trump administration (January 20, 2025, through January 19, 2026) and the last year of the Biden administration (January 20, 2024, through January 19, 2025).
To identify detainees rapidly transferred to a different state, we ordered stints within stays by book-in date and identified the first stint that was in a different state than the initial stint. We then calculated the duration between the stay book-in date and the book-out date before they were first transferred to another state. If that duration was less than a day, the stay was included in the count of rapid transfers. We counted the unique identifiers within that set of stays to determine the number of people who experienced the rapid out-of-state transfers.
To identify people who were rapidly transferred leading up to deportation, The Marshall Project identified stays where the release reason listed deportation. We then identified the longest stint of at least 30 days and calculated the duration between the book-out date and time of that stint and the book-out date and time of the entire stay. If that duration was less than seven days and the person was detained in at least two facilities after their longest stint, they were included in the count.
We also analyzed the entire time period covered by the data, comparing all available book-ins before the beginning of the second Trump administration to all book-ins after, and found similar trends.


























