Proclamation 10903: the Alien Enemies Act enforcement record

Audit — written July 2026, covering the order and its enforcement through publication.

What the order directs

Proclamation 10903 was signed March 14, 2025, made public March 15, and published in the Federal Register March 20, 2025 (Immigration Policy Tracking Project). It invoked the Alien Enemies Act of 1798, declaring that members of Tren de Aragua from Venezuela are conducting "irregular warfare" and "hostile actions" against the United States (Immigration Policy Tracking Project). It directed the Attorney General and the Secretary of Homeland Security to use "all available resources" to apprehend, detain, and remove Venezuelan nationals aged 14 or older who are not citizens or lawful permanent residents and are determined to be members, and authorized seizure of property linked to the group (Immigration Policy Tracking Project).

On March 14, 2025, Attorney General Pam Bondi issued "Guidance for Implementing the Alien Enemies Act," authorizing apprehension without warrants and establishing a point-rubric, Form AEA-21A, to validate membership (Immigration Policy Tracking Project). The stated predicate was the State Department's February 20, 2025 designation of Tren de Aragua as a Foreign Terrorist Organization (The White House). The asserted legal authority is the 1798 Act, a wartime statute; the Congressional Research Service flags as disputed whether a president may invoke it in peacetime against a non-state gang rather than a recognized foreign nation at war (CRS).

What enforcement shows

• 2025-02-20: State Department designates Tren de Aragua a Foreign Terrorist Organization, the proclamation's stated predicate (The White House). [announcement]
• 2025-03-14: Proclamation signed; Bondi guidance issued authorizing warrantless apprehension and the AEA-21A membership rubric (Immigration Policy Tracking Project). [announcement]
• 2025-03-15: Three planes carrying more than 250 alleged members are flown to El Salvador's CECOT prison, the order's first major enforcement action (FactCheck.org). [executed]
• 2025-03-16: BBC reports 261 people removed to El Salvador notwithstanding Judge Boasberg's same-day order blocking such removals; the White House said the flights had already left US airspace before the written order issued (BBC). [executed, disputed non-compliance]
• After 2025-03-15: No sustained removals under the Act occurred; the administration's stated intent to remove members without immigration-court process did not materialize into a continuing program (Vandenberg Law). [non-execution]
• Through publication: Human-rights trackers count more than 280 removals to CECOT, more than the initial wave alone accounts for (NILC). [executed removals]
• Through publication: El Salvador acknowledged to UN investigators that the United States retains "jurisdiction and legal responsibility" for the detainees, contradicting public claims they were under Salvadoran custody (Democracy Forward). [executed]

The announced directive reached every Venezuelan national aged 14 or older determined to be a member, nationwide, using "all available resources." The executed record in the payload is a single wave of roughly 261 removals on one day, after which no sustained removals occurred and the Act sits unenforced under a standing court ban. The gap between the sweep of the directive and the size of the executed record is the central fact of this section.

The court record

This is where the audit's weight sits. On 2025-03-15, U.S. District Judge James Boasberg issued a temporary restraining order and class action blocking deportations, ruling the proclamation failed to provide the notice and hearing due process requires before removal, and ordering flights that had already departed to turn back (The Hill; CRS). The flights did not turn back; the Justice Department argued the order was not binding because the planes were outside US airspace (Vandenberg Law). Boasberg subsequently opened a contempt investigation into the administration for flying migrants despite the prohibition, finding "significant evidence" that many were imprisoned on weak claims (NILC). The payload records the inquiry's opening but not its appellate disposition; that outcome is not established in the record available here.

On 2025-04-07, the Supreme Court, per curiam, vacated the TRO, ruling that challenges must be brought as habeas corpus petitions in the district of confinement; all nine justices agreed that individuals subject to removal are entitled to notice and judicial review (Supreme Court; CRS). The Court separately blocked removal of Venezuelan men in custody in AARP v. Trump (Center for Immigration Studies). On 2025-05-14, a federal district judge in Pennsylvania ruled the president may use the Act to deport Venezuelans shown to be members, a ruling in the administration's favor (NPR). On 2025-06-04, a district court ordered the government to facilitate habeas relief for Venezuelans already removed to CECOT, with an appeal pending at the D.C. Circuit (CRS). The Supreme Court also ordered the administration to return Kilmar Abrego Garcia, deported in violation of a court order (NILC). On 2025-12-22, a court certified a class of the March deportees, found they were denied due-process rights, and ordered the government to propose a hearing plan (CRS). The proclamation was not vacated; courts issued stays and blocks, and the ban on using the Act for deportation remains in place (Vandenberg Law; FAIR).

The rhetoric wrapper

The proclamation's own text supplies the framing: Tren de Aragua is cast as conducting "irregular warfare" and "hostile actions," and the order sits within the administration's broader "invasion" declaration at the border, under which ICE was directed to detain "to the maximum extent authorized by law" (Immigration Policy Tracking Project; American Immigration Council). The packaging presents mass removal as a wartime response rather than an immigration-enforcement expansion.

On December 31, 2025, the official DHS account posted an appropriated beach painting captioned "America after 100 million deportations," with the agency's own caption "The peace of a nation no longer besieged by the third world" (Common Dreams). Classified normalization-messaging / demographic-group, per config/rhetoric-taxonomy.md: the image aestheticizes the policy outcome of mass removal rather than threat-framing a named individual. This section describes the packaging; it does not score it, and no rhetoric-track proposal follows from it here.