What role did Title 42 expulsions play in inflating repatriation totals during the Biden administration?

Checked on January 25, 2026
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Executive summary

Title 42 expulsions — the pandemic-era practice of rapidly turning away or flying out irregular border crossers without allowing asylum processing — accounted for millions of the “repatriations” tallied during the Biden presidency and therefore materially inflated headline repatriation totals compared with ordinary deportation/removal figures [1] [2]. Because expulsions are legally and operationally distinct from removals, their inclusion in repatriation aggregates complicates apples‑to‑apples comparisons across administrations and can mislead public perceptions of enforcement activity [1] [3].

1. What Title 42 expulsions were and how they were counted

Title 42 expulsions were rapid departures carried out under a CDC public‑health order that barred many arriving noncitizens from entry and from seeking asylum; migration policy analysts explicitly categorize expulsions as part of “repatriations” while distinguishing them from formal removals that require a legal order [1]. ICE itself documented using charter flights and other means to transport people expelled under Title 42 between March 2020 and May 2023, underscoring that expulsions were an operationally intensive—yet legally different—form of departure included in some federal tallies [2].

2. Scale: why totals jumped

The sheer volume of expulsions explains most of the surge in repatriation counts: Migration Policy notes roughly 3 million expulsions under Title 42 from March 2020–May 2023, the vast majority occurring during the Biden administration’s term, and it reports the administration’s combined repatriation figure approaching 4.4 million when expulsions are folded in [1]. That arithmetic — millions of Title 42 departures added to removals and returns — is the proximate cause of the higher “repatriation” totals attributed to Biden in several analyses [1] [4].

3. Why those totals can mislead when compared to deportations

Counting expulsions as repatriations without highlighting their legal distinction can inflate perceived enforcement success: expulsions under Title 42 denied asylum processing and often represented refusals at the border rather than removal orders after adjudication, so equating them with court‑ordered removals overstates the degree of formal deportation activity [1] [3]. Independent observers and media have warned that different administrations’ statistics mix removals, returns, expulsions and other categories in inconsistent ways, creating apples‑to‑oranges comparisons unless one disaggregates the data [3].

4. Policy and effectiveness: numbers vs. deterrence

Even as expulsions lifted repatriation counts, analysts argue they were not a durable deterrent; Migration Policy finds Title 42 did not produce lasting reductions in unauthorized migration and that many migrants made repeated crossing attempts, meaning high repatriation tallies did not equal sustained border control outcomes [1]. Human Rights First adds that the policy caused severe humanitarian harms and that its operational continuation represented a political choice with real human costs rather than a technical accounting change [5].

5. Data transparency, political uses, and comparison caveats

Comparisons of presidential records are hampered by uneven reporting: The New York Times and other outlets note the federal agencies’ categories and incomplete data releases can obscure which parts of a total are expulsions versus removals, and administrations have sometimes packaged returns and expulsions together in public statements, enabling political narratives on both left and right [3]. Migration Policy and Stateline reporting show different headline figures for recent fiscal years — for example, citations of 778,000 repatriations in a final Biden fiscal year versus other tallies of roughly 685,000 deportations — underscoring the need to read methodology notes before drawing conclusions [4] [6].

Conclusion: what role Title 42 played

Title 42 expulsions were the single largest driver of the elevated repatriation totals attributed to the Biden administration because millions of expulsions were legally counted as repatriations; the practice therefore “inflated” conventional deportation metrics in raw numeric terms even as it differed substantively from formal removals and drew sharp human‑rights criticism and methodological caveats from analysts [1] [2] [5]. Determining whether that inflation is a fair reflection of enforcement depends on whether one treats fast expulsions that block asylum claims as equivalent to judicially ordered removals — a question that the data and legal definitions make clear requires careful disaggregation and context [1] [3].

Want to dive deeper?
How do federal agencies define and report removals, returns, and expulsions in immigration statistics?
What were the humanitarian and legal critiques of Title 42 from advocacy groups and courts during 2020–2023?
How do repatriation totals under Biden compare to previous administrations when expulsions are excluded?