4 March 12 - 18, 2026 dallasobserver.com DALLAS OBSERVER Classified | MusiC | dish | Culture | unfair Park | Contents n the day he was scheduled to ap- pear in a Dallas federal immigration courtroom late last year, a young Honduran man lay in his bedroom, curled in a ball, his chest tight with fear. His case was one that his attorney Paul Zoltan expected to win. As a member of the LGBTQ+ community, the man had come to the U.S. to escape the risk of violence and discrimination that per- vades his home country. A report from 2024 by CONADEH, Honduras’ National Human Rights Office, found that between January and October of that year, 38 members of the LGBTQ+ community were murdered in the Central American country. Most of that vio- lence was targeted toward homosexual men. Ninety percent of crimes against the country’s queer community go unpunished, creating a situation that the International Rescue Committee, a humanitarian aid group, describes as “dire.” Those factors left Zoltan, who has practiced immigration law in Dallas for decades, sure that his client had “a compelling asylum claim.” But the man never arrived in court. Despite Zoltan’s assurances, the man was haunted by the images of immigrants being dragged out of courtrooms by masked fed- eral agents that began to circulate online shortly after President Donald Trump took office last year. A panic attack inspired by the fear of being deported, maybe back to Honduras, or maybe to the infamous El Sal- vadoran prison where 250 Venezuelan men were sent by the U.S. government last March, overrode the rationality of a stan- dard court appointment. It is not clear how many people were ar- rested by ICE directly from courtrooms in 2025, but the strategy was rampant across the United States, including at Dallas’ down- town federal courthouse. “[My client’s panic attack] was precisely and consequently because of those arrests. I told him that his case did not fit the pattern,” Zoltan told the Observer. “But it just terri- fied him. His emotional response overcame his readiness to believe me.” Because of his failure to appear in court, the Honduran man’s case was closed with an in absentia order, which calls for the per- son’s deportation for truancy. When the de- portation order is issued, the person is barred from further seeking asylum, relief from deportation or, in a majority of cases, any appeal. If they attempt to reenter the United States after being deported, they can be subject to criminal prosecution. Across the U.S., the number of in absentia orders issued skyrocketed in 2025 as undoc- umented immigrants increasingly no- showed during their scheduled hearings. Dallas’ immigration court was a leading con- tributor. In January of last year, 53% of completed immigration cases in Dallas resulted in an in absentia order, according to data analyzed by NPR. By November, that number had grown to 79%, the most of any city in the U.S. That increase represents thousands of im- migrants who likely would have shown up to their court hearings prior to 2025, but now face deportation orders and are perma- nently ineligible for legal status in America. “I would expect it to be higher, and I think that this is evidence of how firmly im- migrants still cling to their faith in the American justice system,” Zoltan said. Compounding Fear he number of in absentia removal orders issued by judges in the U.S. has trended upward since 2021, according to De- partment of Justice data measured in fiscal years. What were nearly 8,540 removal or- ders in 2021 became 223,154 orders by the end of 2024. Then, in 2025, the number of deportation orders spiked again, jumping to 310,436. Early data shows that 2026 is on pace with the last fiscal year. In the first quarter of FY26, which ran from October through December, 74,804 removal orders were is- sued in immigration courts. That means that each month, 24,935 people who’d started the process to obtain legal residency failed to appear in court. Once an in absentia order is issued, it is nearly impossible to fight. A motion to re- open a person’s immigration case may be granted in “exceptional circumstances,” which is defined by the DOJ as “battery or extreme cruelty,” “serious illness” or “seri- ous illness or death” of the applicant’s spouse, child or parent. If it can be proven that proper notice to appear in court was not granted to the individual, or that the failure to appear was no fault of their own, a case may be reopened. “Fear of arrest is categorically not a rea- sonable cause to reopen a case,” Zoltan said. “If you missed your hearing because you were afraid of apprehension, you will not be excused.” Of the deportation orders issued in FY25, nearly 30% were in cases in which a person had applied for asylum. Asylum grants pro- tection for individuals who believe they will be persecuted in their home country due to their race, religion, nationality, political opinions or social group, which includes sexuality. A person must be present in the U.S. but for less than a year to be eligible to apply. The complexity that applying for asylum entails is part of what Flavia Santos Lloyd, an immigration attorney based in California, describes as a “biased system” that has his- torically rewarded undocumented immi- grants who have the financial means to obtain legal representation and punishes those who do not. These days, she is seeing that inequity more than ever. “If you’re going to court, and if you’re seeing other people getting picked up [by ICE], that has a chilling effect,” Santos Lloyd said. “When you see other people getting picked up, you think you’re going to get picked up.” While failing to appear in court damns a person in the eyes of the U.S. legal system and paves the way for potential deportation, showing up increasingly puts a person at risk of immediate detention. To prevent her clients from being ex- posed to the “visual of people getting picked up,” Santos Lloyd has begun petitioning for their hearings to be held online over a video service called WebEx. The requests can be denied, and if an individual does not have le- gal representation, their appointments are defaulted to in-person. For those who are not granted a virtual appearance, appearing in court is the only way to seek judicial relief, regardless of the stage of the case. To show up is to accept the risk of being arrested. Before 2025, clients rarely asked whether they’d be detained in court, Santos Lloyd said. Now, that’s all they ask. And as ICE changes tactics month to month, targeting courtroom attendees who are there for dif- ferent types of appointments than the indi- viduals detained the month before, she increasingly does not know how to answer them. ICE has been active in the San Diego and San Francisco courtrooms where Santos Lloyd practices. The New York Times reports that in a two-week period last October, 120 immigrants were detained following their hearings at a federal courthouse in San Di- ego. “It is spreading. It’s like a cancer,” Santos Lloyd said. “[The arrests] started in the re- moval proceedings, and now we’re seeing them in adjustment of status [cases].” Doing It the ‘Right Way’ antos Lloyd knows what it’s like to have one’s fate decided in a courtroom. Originally from Brazil, she came to the U.S. on a student visa and overstayed it after giving birth. It’s a situation that isn’t commonly talked about but one many women find themselves in, she said. Re- sponsible for an American child, she couldn’t simply board a plane home or the baby’s father could accuse her of abducting her own infant. Photo-illustration by Sarah Schumacher | UNFAIR PARK | >> p6
