Doe

BACKGROUND

25 On April 14, 2025, plaintiff Student Doe filed his complaint against defendants Kristi 26 Noem, Todd Lyons, and Department of Homeland Security (“DHS”) for terminating plaintiff’s 27 Student and Exchange Visitor Information System (“SEVIS”) record, which had the effect of 28 terminating plaintiff’s F-1 visa status. (Doc. No. 1.) In support of the pending motions, plaintiff presents evidence of the following. Plaintiff, an international student with an F-1 visa, received an email on April 8, 2025 from his university notifying plaintiff that “SEVIS has terminated your record” and that the “[e]xplanation” provided by the government was that plaintiff had been “[i]dentified in” a “criminal records check and/or had their VISA revoked.” (Doc. Nos. 2-2 at 2; 5-6 at 2.) The email also stated that ICE “agents may investigate to confirm the departure of the student[,]” “[n]o grace period is allowed[,]” and “[r]emaining in the United States on a terminated status may have serious consequences.” (Doc. Nos. 2-2 at 3–4; 5-6 at 3–4.) There has been a recent surge in hate crimes, and the White House and DHS have communicated anti-immigrant…