How did immigration court outcomes and voluntary departures change between 2024 and 2025, and how do they affect removal totals?
Executive summary
Immigration-court outcomes shifted noticeably from FY2024 to FY2025: judges issued removal or voluntary departure orders at higher rates in 2025 (about 45% of completed cases) than in 2024 (about 39%), driving a sharp rise in recorded removal-related resolutions and contributing to higher removal totals when combined with stepped-up enforcement activity [1] [2]. Voluntary departures, which were a small share of outcomes in FY2024 (about 1%), also appear to have grown in absolute terms in 2025 — both in court grants and in other DHS programs — and that growth changes the composition and fiscal implications of “removals” even if it sometimes reduces the long-term penalties associated with formal deportation [3] [4].
1. Courts moved faster and ruled against respondents more often in FY2025
Immigration courts increased throughput and issued a larger share of adverse decisions in FY2025: judges ordered removals or voluntary departures in roughly 45% of completed cases in early FY2025, up from 39% in FY2024, a trend driven by accelerated case processing and policy-driven timelines [1] [2]. EOIR and third‑party analyses show a substantial climb in case completions in late 2024 and into 2025, with court closures hitting record levels and projections of roughly 852,000 deportation-case decisions for the FY2025 year, which mechanically raises the count of removal orders issued [1] [5].
2. Voluntary departures remained a small share of outcomes but grew in absolute numbers
Voluntary departure made up only about 1% of immigration court outcomes in FY2024, per EOIR summaries reproduced in CRS analysis [6] [3], yet external data sources and macroeconomic analysts report court resolutions classified as voluntary departures surged from roughly 10,000 in 2024 to about 40,000 in 2025 — a fourfold rise in absolute terms that reflects both court practices and DHS programs aimed at encouraging exits without formal removal records [4]. That shift matters because voluntary departure typically carries fewer immigration penalties than formal removal, altering the legal and fiscal profile of enforcement despite contributing to the headline “ordered removed or departed” tallies [4].
3. Removal totals rose because more cases were decided and a greater share ended in removal-type outcomes
Removal totals are a product of both enforcement actions and court dispositions; FY2024 already saw historic activity with hundreds of thousands of removals, and FY2025’s higher decision volume plus the raised share of adverse outcomes translated into a projected 383,400 orders for removals or voluntary departures on pace for FY2025 in TRAC analyses cited by reporting [1]. In addition to more rulings against respondents, increases in in‑absentia orders and asylum denials — which surged markedly in 2025 according to multiple trackers — contributed to higher recorded removals even where some individuals left via voluntary departure rather than formal deportation [7] [2].
4. Policy shifts and agendas shaped outcomes; alternative interpretations exist
Policy changes — including the Biden administration’s expedited asylum and border rules in mid‑to‑late 2024 — are explicitly linked to the increase in court decisions and the higher denial/removal rate in 2025, and analysts from Brookings to CRS highlight that DHS/DOJ rules reduced admissibility and sped adjudication, which can produce both higher removal counts and more voluntary departures [8] [4]. Observers differ on what that means: enforcement advocates point to the surge in removals as evidence of restored deterrence and efficiency, while immigrant‑rights groups warn rapid processing and policy restrictions can raise denial rates and in‑absentia removals, compromising due process [1] [7].
5. What the data do — and don’t — settle
Available sources show a clear numerical pattern: higher case completions in FY2025, a larger proportion of those completions resulting in removal or voluntary departure (about 45% versus 39% in 2024), and an absolute rise in voluntary departures recorded in 2025 from around 10,000 to roughly 40,000 in TRAC/analyst counts [1] [3] [4]. What the reporting does not fully resolve is the downstream legal status of those who took voluntary departures versus formal removals over longer horizons, the precise breakdown of voluntary departures inside versus outside court proceedings, and the causal weight of administrative policy versus underlying case characteristics — gaps that require granular EOIR/TRAC tables and DHS program data not fully reproduced in the cited reporting [4] [3].