Pacito vs Trump Compliance Timeline
This timeline summarizes requirements set forth in the May 5, 2025 compliance order issued in Pacito v. Trump. While accurate to the best of our understanding, implementation and outcomes remain contingent upon the government’s adherence to the court’s directive.
By May 12, 2025 (Day 7)
The government must:
Resume refugee case processing at all levels, including at U.S. embassies.
Lift all admissions suspensions for individuals protected under the injunction.
Reinstate funding, systems access (e.g., START, FileCloud, IRIS), and RSC agreements.
Begin facilitating travel for Injunction-Protected Refugees with unexpired medical and security clearances.
Submit a plan to renew expired clearances.
Provide case-level updates to plaintiffs.
Compliance report due by May 15, 2025
By May 19, 2025 (Day 14)
The government must:
Notify all Injunction-Protected Refugees that their cases are moving again.
Restore funding and provide updated guidance to all RSCs.
Resume IOM-facilitated travel and medical exams.
Allow and support independently arranged travel and medical exams.
Explicitly inform eligible refugees that independent travel remains a valid option.
Compliance report due by May 22, 2025
By May 26, 2025 (Day 21)
The government must:
Resume full Reception and Placement (R&P) services, including housing, job training, case management, and access to benefits.
Reinstate any benefits cut due to the EO-related pause.
Assign R&P agencies to refugees who entered independently after the injunction went into effect.
Compliance report due by May 29, 2025
By June 2, 2025 (Day 28)
If all RSCs are not yet reopened, the government must:
Establish alternate processing channels for eligible refugees outside active RSC jurisdictions.
Compliance report due by June 5, 2025
By June 5, 2025 (Day 31)
All steps outlined in the order must be completed by this date.
This deadline also triggers the start of ongoing compliance reporting.
First weekly report due by June 12, 2025, and every 7 days thereafter.
Additional First Report Requirements (May 15, 2025)
The first report must also include:
A count of all Injunction-Protected Refugees.
Geographic breakdown by country and RSC.
Monthly admission figures for USRAP from August 2024 through January 2025.