US District Judge George O’Toole in Boston on Monday issued a ruling blocking the Trump administration from assessing and collecting fines of up to $1.8 million on migrants who fail to willingly leave the US after receiving final deportation orders.

O’Toole resolved the class action suit against the administration by granting a motion to stay the proceedings in favor of the plaintiffs, two affected individuals from the class and the Immigrant Legal Resource Center (ILRC). He held that the plaintiff’s claim that the administration violated the Administrative Procedure Act (APA) by failing to provide a notice-and-comment period for their rule imposing the fines was likely to succeed, and that the balance of equities rules heavily in the plaintiff’s favor.

“The plaintiffs here face assessment and possible collection of enormous fines well beyond their capacity to pay,” said O’Toole. “Given the amount of the fines, the plaintiffs face the possibility of garnishment of wages and bank accounts, seized assets such as vehicles and homes, IRS reports, federal collection suits, and adverse future admissibility determinations.”

The class action lawsuit challenges a January 2025 Executive Order (EO) titled “Protecting the American People Against Invasion,” which directed the Department of Homeland Security (DHS) to take all appropriate action to assess and collect fines from individuals who were unlawfully present in the US. DHS responded in June 2025 by promulgating a rule amending the process for assessing civil monetary penalties to allow the agency to impose civil fines more efficiently and on a larger scale.

O’Toole conveyed that this invoked a “long dormant” provision of the 1996 Illegal Immigration Reform and Immigration Responsibility Act, which authorizes the government to assess civil monetary penalties if an individual “willingly fails to depart” the country following a final order of removal.

The administration has interpreted this to impose fines of $998 per day for those that fail to leave the US, assessed retroactively for up to five years, resulting in the $1.8 million levied against the plaintiff. This action has been subject to subsequent court action, including the plaintiff’s class action suit.

As of July 2026, DHS had issued more than 103,000 total fines to migrants, amounting to approximately $84 billion.

In his opinion, O’Toole wrote that the fines were unreasonable given the immense burden they place on the plaintiffs, stating that “the plaintiffs live in an economically precarious position even without the imposition of the government’s exorbitant fines.”