How do interior ICE removals compare to border expulsions across the Obama, Trump, and Biden administrations?

Checked on January 17, 2026
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Executive summary

Interior ICE removals and border expulsions have shifted in emphasis across the three administrations: the Obama years emphasized interior removals with a focus on criminal cases and broad deportation totals (including many returns), the Trump presidency pushed harder on interior enforcement and local partnerships but also counted many border returns as removals, and the Biden administration moved enforcement toward rapid border expulsions (notably Title 42) and reprioritized interior ICE activity toward criminal cases while diverting personnel to the border [1] [2] [3].

1. Obama: interior removals were central and numerically large

During the Obama administration ICE carried out high volumes of interior removals and the agency’s prioritization policies—especially after 2014—meant that by FY2016 almost all interior removals fit the government’s enforcement priorities and a very high share were convicted of crimes (about 92 percent of interior removals that year) reflecting an interior-focused, crime-priority enforcement posture [1].

2. Trump I: aggressive interior enforcement plus changes in counting

President Trump’s first term sought to expand interior enforcement—using local law‑enforcement partnerships, increasing detention capacity, and loosening prior prioritization—which raised ICE’s interior removal ambitions compared with the late‑Obama period, even as observers warned resources and detention limits constrained full implementation; at the same time, public debates about “deportation” totals were complicated by differences in whether border turn‑backs and quick returns were counted as removals [1] [4] [2].

3. Biden: a pivot to the border and narrower interior priorities

The Biden administration reasserted prosecutorial discretion similar to Obama, directing ICE to focus interior removals on those posing national‑security or serious public‑safety risks, and—especially with Title 42 expulsions in effect—shifted much of the agency’s enforcement to processing and returning people at the border, so that by FY2023 more migrants were returned directly across the border than were removed from the interior for the first time since FY2010 [5] [3].

4. Trump II and 2025–26: rebound, mixed data, and contested narratives

The return of Trump produced renewed pressure to ramp up removals and a surge of reported repatriations in early 2025, with advocates and critics disputing how many removals were interior arrests versus border expulsions; some analyses show high numbers of removals in FY2025 that may include many border returns and undocumented breakdowns by original arresting agency, complicating simple comparisons of interior versus border removals [6] [7] [8].

5. What the numbers and the messiness together mean

Comparisons across administrations are constrained by inconsistent counting (returns/expulsions versus formal removals), changing legal authorities like Title 42 or expedited removal, and shifting resource priorities—Obama and early Trump years emphasized interior removals and criminal‑case enforcement, Biden emphasized border expulsions and diverted ICE resources to the border, and Trump II has tried to restore aggressive interior enforcement even while many reported removals appear to be border returns; analysts note the Supreme Court and legal challenges have also shaped capacity and priorities [1] [3] [4] [2].

6. Caveats, competing claims, and political agendas

Different sources carry distinct agendas—policy shops and advocacy groups highlight criminal composition and “who” was removed [6] [3], while media and administration statements may emphasize raw repatriation totals or quick turn‑backs to show results [2] [7]; moreover, ICE’s own public dashboard has limited historical continuity (starts in Oct 2020 and through Dec 2024 in one dataset), leaving gaps that fuel competing narratives about whether interior removals rose or fell under a particular president [6].

Want to dive deeper?
How did Title 42 expulsions change total repatriation counts during the Biden administration?
What proportion of ICE removals since 2009 originated from interior arrests versus border apprehensions?
How do different agencies (ICE vs CBP) report and classify removals, expulsions, and returns?