Nicolai Haugsted
Trump administration faces fresh legal blow over fines that reached as high as $1.8 million.
Donald Trump’s immigration crackdown has relied on more than arrests, detention and deportations. Financial penalties have also become a powerful part of the administration’s enforcement strategy, with some immigrants receiving bills large enough to dwarf what many Americans earn during an entire lifetime.
A federal judge has now stopped one of the administration’s most aggressive approaches to collecting those penalties.
US District Judge George O’Toole Jr. in Boston ruled Monday that the government unlawfully imposed fines reaching as high as $1.8 million on immigrants accused of remaining in the country after receiving final removal orders. The ruling came in a class-action lawsuit brought by two immigrants who had been assessed penalties by the Department of Homeland Security.
The decision does not eliminate the government’s ability to fine immigrants under federal law. Instead, it blocks the Trump administration’s newer procedures for assessing and collecting the penalties.
Billions of dollars in fines
The scale of the program is considerable.
DHS told Bloomberg Law earlier this year that 65,101 civil penalties worth more than $36 billion had been issued between Trump’s return to office in January 2025 and mid-March 2026.
Those numbers have since climbed dramatically.
DHS said in July that more than 103,000 fines totaling approximately $84 billion had been issued since Trump returned to the White House, according to Reuters.
Individual penalties can reach extraordinary levels because fines may accumulate daily. Some recipients have faced demands approaching $1.8 million.
O’Toole concluded that the administration’s implementation of the system failed to properly account for requirements written into the underlying statutes.
Judge finds a major problem with the process
Federal law allows civil penalties under specific circumstances, including when someone “willfully” fails to comply with a final removal order or voluntarily fails to depart within an authorized period.
O’Toole found that the government’s procedures effectively treated remaining in the United States after a removal order as sufficient evidence of a violation, rather than properly establishing whether the conduct met the statutory requirements.
According to the ruling described in the source material, ICE notices relied on standardized forms that did not explain why officials considered an individual’s conduct willful.
The sheer speed of the operation also attracted the judge’s attention.
Nearly 10,000 notices were issued during a three-month period, according to the ruling, undermining the government’s argument that each case received a meaningful individual assessment.
One woman faced a $1.82 million bill
The lawsuit illustrates just how large the financial stakes can become.
One plaintiff, identified as Nancy M., received a penalty of approximately $1.82 million for alleged willful noncompliance while she was living in the United States under an order of supervision.
Her immigration circumstances subsequently changed significantly. According to the source material, she was approved for an immigrant visa and eventually became a lawful permanent resident.
Another plaintiff, Maria L., works as a nail technician and received penalties worth hundreds of thousands of dollars while pursuing legal status.
O’Toole concluded that allowing collection efforts to continue while the lawsuit proceeds could inflict damage that would be extremely difficult to reverse.
“The plaintiffs live in an economically precarious position even without the imposition of the government’s exorbitant fines,” he wrote.
Fifteen days to fight potentially life-changing penalties
Procedural changes introduced by the administration also played a major role in the dispute.
The government’s June 2025 interim rule streamlined how immigration-related civil penalties could be assessed and collected. Federal records show that the rule took effect on June 27, 2025.
According to the source material, the newer system eliminated advance warning before a fine and reduced the period available to challenge a penalty from 30 days to 15.
O’Toole described that shortened timetable as “essentially punitive,” pointing to the practical difficulty of understanding technical legal documents, collecting supporting evidence and submitting a response within such a narrow window.
The judge also found that the administration likely violated the Administrative Procedure Act when implementing the changes without first going through the normal notice-and-comment process.
Losing a home cannot simply be undone
Money sits at the heart of the court’s reasoning about immediate harm.
Government collection efforts could potentially result in wage garnishment, damaged credit or the seizure of property such as vehicles and homes, according to the ruling described in the source material.
Cancelling a fine later would not necessarily repair those consequences.
O’Toole therefore concluded that the plaintiffs could face insolvency if collection continued while the litigation remained unresolved.
The government, meanwhile, retains another route.
Older procedures for pursuing legally authorized immigration penalties remain available, meaning the ruling does not provide blanket immunity from fines for people who violate the relevant statutes.
