Brief of Amici Curiae Social Science Researchers in Opposition to Defendants-Appellants’ Petition for Rehearing En Banc, Community Legal Services
The William T. Grant Foundation
The Foundation for Child Development
Society for Research on Adolescence
The Society for Research in Child Development
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Summary

Amici social science researchers argue that trauma, family separation, detention, and developmental limitations make self-representation impossible for unaccompanied children, making legal counsel essential to prevent lasting harm.

2025 | Federal Juristiction

Brief of Amici Curiae Social Science Researchers in Opposition to Defendants-Appellants’ Petition for Rehearing En Banc, Community Legal Services

Keywords unaccompanied migrant children; direct representation; immigration proceedings; child vulnerability; trauma; legal representation; Office of Refugee Resettlement

ARGUMENT

Amici submit this brief to provide the Court with a summary of the extensive research that demonstrates the exceptional vulnerability of unaccompanied migrant children and the additional trauma that will be inflicted on these children if Appellants eliminate funding for direct representation in immigration proceedings. There is a significant body of research that establishes what Congress has intuited: that unaccompanied minor children in adversarial immigration proceedings are a uniquely vulnerable population that require direct representation to be protected from “mistreatment, exploitation, and trafficking.” See 8 U.S.C. § 1232(c)(5). It is both commonsense and well established in research that it is developmentally inappropriate for any child—much less a child suffering the traumas of migration, parental separation, and detention—to represent themselves in complex and adversarial legal proceedings. Unaccompanied children also face significant risk of abuse both during and subsequent to their detention, particularly if such children lack a trusted adult in their lives. And children who have been separated from their caretakers and detained during migration experience dangerous levels of stress that cause lifelong psychological and physical harm. The precarious physical and mental state of these children is the context in which the Court reviews Appellants’ request for a stay, including its consideration of the public policy interest in granting a stay.

Our research shows that lawyers help to mitigate all of these harms. Granting the stay will significantly and permanently harm the 26,000 unaccompanied children currently receiving direct legal representation funded by the Office of Refugee Resettlement (“ORR”). Without representation, many of these vulnerable unaccompanied children with meritorious claims for immigration relief will be removed to countries where they face abuse, trafficking, and violence. And regardless of the strength of any given unaccompanied child’s claim, lack of representation leads to greater risk of abuse in detention, greater risk of trafficking after detention, greater risk of prolonged detention, and toxic levels of stress that threaten their long-term development and physical and mental health. Such permanent, severe harm to vulnerable children weighs strongly against the Government in the public interest analysis. Cf. Amoco Prod. Co. v. Vill. of Gambell, 480 U.S. 531, 545 (1987) (where there is likely an injury that is “permanent or at least of long duration” the balance of equities “will usually favor the issuance of an injunction.”).

Amici agree with the Panel that a stay of the district court’s preliminary injunction is inappropriate because the Government has not met its burden to establish either a likelihood of success on the merits or irreparable harm. See Cmty. Legal Servs. v. HHS, No. 25-2808, 2025 WL 1393876, at *1 (9th Cir. May 14, 2025). In addition, however, a stay is inappropriate because it is against the public interest because of the significant and permanent harm to vulnerable children that will result if ORR eliminates direct funding for representation of unaccompanied children pending the resolution of this lawsuit. The Government’s attempt to eliminate funding for direct representation undermines Congressional intent to provide this vulnerable class of children with procedural regularity and a fair shot to avoid further trauma associated with detention and unsafe repatriation. That irreversible trauma is all but certain if the Government has its way, even if only during the pendency of the litigation. Consequently, a stay is clearly not in the public interest and en banc review of the Panel’s decision should be denied.

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Summary

This document explains why unaccompanied migrant children need legal help. Research shows these children are very vulnerable. Taking away money for legal representation will cause them more harm. Congress already understood that these children need legal representation to be safe from harm like mistreatment or trafficking.

It is clear that children, especially those who have experienced trauma from migration, being separated from parents, and detention, should not have to represent themselves in court. These children are also at high risk of abuse while in detention and afterwards, especially if they do not have a trusted adult. Being separated from caregivers and detained causes high stress, leading to lasting psychological and physical problems. The Court should consider these issues when deciding whether to stop funding for legal help.

Legal assistance helps lessen these harms. If funding is stopped, 26,000 children currently receiving legal aid will be severely and permanently harmed. Without lawyers, many vulnerable children who deserve to stay in the country will be sent back to places where they face abuse, trafficking, and violence. Even if a child has a strong case, not having a lawyer increases their risk of abuse in detention, trafficking after detention, longer detention times, and harmful stress levels that affect their long-term development and health. The serious and lasting harm to these children means the government should not be favored in the public interest analysis.

A temporary halt to the funding is not appropriate because the government has not shown it is likely to win the case or that it will suffer irreparable harm. A temporary halt is also against the public interest because of the significant and lasting harm it would cause vulnerable children if the Office of Refugee Resettlement (ORR) stops funding legal representation for unaccompanied children while this lawsuit continues. The government's attempt to stop funding goes against what Congress intended: to give these vulnerable children a fair process to avoid more trauma from detention and unsafe returns. This irreversible trauma is almost certain if the government gets its way, even if only during the lawsuit. Therefore, a temporary halt is not in the public interest, and a full court review of the previous decision should not be granted.

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Argument

This brief highlights research showing the extreme vulnerability of unaccompanied migrant children. It argues that removing funding for legal representation will cause more harm to these children. There is much evidence that unaccompanied minor children in immigration proceedings are a very vulnerable group. They need legal representation to protect them from mistreatment, exploitation, and trafficking. It is widely accepted that it is not appropriate for any child, especially one who has experienced trauma from migration, family separation, and detention, to represent themselves in complex legal cases. Unaccompanied children also face a high risk of abuse while in detention and afterwards, especially if they do not have a trusted adult in their lives. Children separated from their caregivers and held in detention experience dangerous levels of stress, which can lead to lifelong psychological and physical problems. This difficult situation for these children should be considered when deciding whether to grant the request for a stay.

Research indicates that lawyers help lessen these harms. Granting the stay would severely and permanently affect the 26,000 unaccompanied children currently receiving legal help funded by the Office of Refugee Resettlement (ORR). Without representation, many of these vulnerable children with valid claims for immigration relief could be sent back to countries where they face abuse, trafficking, and violence. Regardless of how strong a child's claim is, a lack of legal representation increases the risk of abuse in detention, trafficking after detention, longer periods of detention, and harmful levels of stress that threaten their long-term development and well-being. Such serious, lasting harm to vulnerable children strongly supports denying the stay.

A stay of the district court's preliminary injunction is not appropriate because the Government has not shown it is likely to win the case or that it will suffer irreparable harm. Additionally, a stay is not in the public interest because it would cause significant and lasting harm to vulnerable children if ORR stops funding legal representation for unaccompanied children while this lawsuit is ongoing. The Government's attempt to stop funding for legal representation goes against Congress's goal to provide these vulnerable children with fair procedures and a chance to avoid further trauma from detention and unsafe returns. This irreversible trauma is almost certain if the Government gets its way, even if only during the lawsuit. Therefore, a stay is clearly not in the public interest, and a full court review of the Panel's decision should be denied.

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Summary

This brief explains why stopping funding for legal help for migrant children is a bad idea. Research clearly shows that unaccompanied migrant children are very vulnerable. Taking away their legal representation will cause them more harm. Many studies confirm what lawmakers already understood: these children need lawyers to protect them from harm like mistreatment and trafficking. It is not fair or appropriate for any child, especially one who has experienced trauma from migration, to represent themselves in court. These children also face a high risk of abuse while detained and afterwards, particularly if they do not have a trusted adult to help them. Being separated from their caregivers and detained causes children extreme stress, leading to lasting psychological and physical problems. The court should consider these serious issues when deciding whether to grant the request to stop the funding.

Lawyers help reduce these problems for children. If the court allows the funding to stop, it will seriously and permanently hurt the 26,000 unaccompanied children who currently receive legal help. Without lawyers, many of these children with valid claims for immigration relief will be sent back to countries where they could face abuse, trafficking, and violence. Even for children with strong cases, lacking a lawyer increases their risk of abuse in detention, trafficking after detention, and staying in detention longer. It also causes severe stress that harms their long-term development and health. The government's request to stop funding should be denied because it would cause such serious and lasting harm to these vulnerable children.

The government has not shown that it will likely win the case or that it will suffer irreparable harm if the funding continues. Therefore, pausing the lower court's order is not appropriate. Also, stopping the funding goes against the public interest because it will cause significant and permanent harm to vulnerable children. The government's attempt to cut funding for legal representation goes against what Congress intended: to ensure these children receive fair treatment and avoid more trauma from detention or unsafe return to their home countries. This irreversible harm is very likely to happen if the government gets its way, even if only while the lawsuit is ongoing. For these reasons, stopping the funding is not in the public interest, and the court should not reconsider the panel's decision.

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Summary

This brief shares important facts about migrant children who travel alone. These children are very weak and can get hurt easily. Giving them lawyers helps keep them safe. If the government stops paying for lawyers, these children will face even more trouble.

Many studies show that these children need lawyers. The law even says that children traveling alone need help to stay safe from bad treatment, being used, or being forced into work. It is not fair for a child, especially one who has gone through hard times, to speak for themselves in court.

Children traveling alone can also be hurt while they are held or after. If they do not have a trusted adult, they are in more danger. Being away from their parents and held in a center can cause a lot of stress. This stress can hurt their minds and bodies for their whole lives. The court should think about these things when deciding if it will stop paying for lawyers.

Lawyers help make these bad things less likely to happen. If the court agrees to stop the money for lawyers, it will truly hurt 26,000 children who have lawyers now. Without a lawyer, many of these children have good reasons to stay in the country. But they might be sent back to places where they could be hurt or forced into bad situations. Even if a child has a strong case, not having a lawyer means they could be hurt more while held, be used after they leave, or be held for a longer time. It also causes a lot of stress that hurts their growth and health. Such big and lasting harm to children means the government should not win this case.

The brief agrees that the court should not stop the money for lawyers. This is because the government has not shown good reasons for it. Also, stopping the money would hurt children a lot and for a long time. This is not good for the public. The government wants to stop paying for lawyers, but this goes against what Congress wanted. Congress wanted these children to have a fair chance to avoid more pain and being sent back to unsafe places. If the government gets its way, this pain will surely happen, even if it is only for a short time while the case is ongoing. So, stopping the money is not good for everyone, and the court should say no to the government's request.

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Footnotes and Citation

Cite

Brief of Amici Curiae Social Science Researchers in Opposition to Defendants-Appellants’ Petition for Rehearing En Banc, Community Legal Services in East Palo Alto v. U.S. Department of Health & Human Services, No. 25-2808 (9th Cir. June 20, 2025)

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