Cozen O’Connor: New Presidential Memo: Preventing Abuses of the Legal System and the Federal Court [Alert]

Overview:

On March 22, 2025, the Trump administration published a Presidential Memorandum titled: Preventing Abuses of the Legal System and the Federal Court.
The memo directs Attorney General (AG) Pam Bondi to seek sanctions against attorneys and law firms who file “frivolous, unreasonable, and vexatious” lawsuits against the federal government.
Specifically, the memo calls out immigration filings stating: “The immigration system — where rampant fraud and meritless claims have supplanted the constitutional and lawful bases upon which the President exercises core powers under Article II of the United States Constitution — is likewise replete with examples of unscrupulous behavior by attorneys and law firms.”
Citing the Federal Rule of Civil Procedure 11 that prohibits attorneys from engaging in certain unethical conduct in federal courts, the memo directs the AG not only to seek sanctions where misconduct is found, but also refer attorneys for disciplinary proceedings if they violate rules governing the filing of meritorious claims.
This memo also instructs the AG to review frivolous litigation against the federal government by identifying misconduct by lawyers and law firms.

Immigration and Customs Enforcement (ICE) stated recently that just over 28,000 deportations were carried out in the first seven weeks of the Trump administration. This is yet another avenue the Trump administration wants to pursue to further crack down on those that may abuse the system with fraudulent filings thereby bogging down the system and causing further delays to the processes.
The memo focuses in part on lawyers and law firms that potentially are engaging in frivolous immigration filings to further deter potential filings that will bog down the already overworked immigration system.
The American Immigration Lawyers Association (AILA) rejects the assertion in the memo that there are “rampant fraud and meritless claims” being committed by immigration lawyers.

The Trump 2.0 administration has made immigration enforcement a key aspect to the administration and this is just another example of this.
We strongly encourage all those in the United States on a visa to ensure that their documentation is 100% in order and to carry proof of their status on their persons at all times.
When selecting an immigration attorney, do your due diligence and ensure their credibility.
At this time, we are still awaiting the much anticipated Trump travel ban targeting certain countries that will further increase obstacles for those seeking to enter the United States from targeted countries. With this travel ban, we are advising all foreign nationals in the United States to consider their international travel plans and potentially only travel if absolutely necessary until more guidance is provided regarding the travel ban. Recently, we have seen and heard of cases whereby green card holders were questioned at the port of entry and, in some situations, denied entry so all foreign nationals in the United States need to be on high alert.

Cozen O’Connor will continue to monitor these developments as they unfold.