Judge Blocks $1.8 Million DHS Immigration Fines in Maria L. v. Mullin

On Monday, October 5, 2026, U.S. District Judge George A. O’Toole Jr. of the District of Massachusetts blocked the Department of Homeland Security from continuing to impose the civil immigration fines at the center of Maria L. v. Mullin (formerly Maria L. v. Noem), No. 1:25-cv-13471. The fines run $998 per day, applied retroactively for up to five years, which is how a single notice can reach about $1.8 million.

This is a putative class action. No class has been certified, and there is no settlement, no claim form and no payout for the public. The ruling also does not cancel removal orders or erase every fine already issued.

Quick Facts: Maria L. v. Mullin Immigration Fine Case

Detail	Information
Case	Maria L. and Nancy M., et al. v. Mullin, et al. (originally captioned Maria L. v. Noem)
Case number	1:25-cv-13471 (D. Mass.)
Judge	George A. O’Toole Jr.
Plaintiffs	Maria L., Nancy M. (pseudonyms) and the Immigrant Legal Resource Center
Defendants	DHS, ICE and other federal officials
Law at issue	8 U.S.C. § 1324d (civil penalties for willful failure to depart after a final removal order)
Other law invoked	Administrative Procedure Act (APA)
Daily fine	$998 per day
Retroactive period	Up to five years
Maximum per person	Approximately $1.8 million
Lawsuit filed	November 20, 2025
Ruling	October 5, 2026: DHS’s challenged fine policies blocked as unlawfully imposed
Class status	Putative class action; certification sought, not granted
Settlement or claim form	None

What Is the $998-Per-Day DHS Fine Under 8 U.S.C. § 1324d?

Congress authorized civil penalties in the Illegal Immigration Reform and Immigrant Responsibility Act of 1996. Section 1324d applies to a person under a final removal order who willfully fails or refuses to leave, fails to make a timely good-faith effort to get travel documents, or fails to appear for removal. Reuters reports that no administration tried to impose the penalties until Trump’s first term.

Starting in 2025, the Trump administration began issuing them at scale. The inflation-adjusted rate is $998 per day, and DHS applied it retroactively for up to five years. Five years of daily fines at that rate comes to roughly $1.8 million, which is the ceiling. It is not what every recipient was billed.

How Many Immigration Fines Has DHS Issued Since January 2025?

As recently as July 2026, DHS said it had issued more than 103,000 fines totaling about $84 billion since President Trump returned to office. Those figures are amounts assessed, not money collected.

What Did Maria L. and Nancy M. Challenge in Maria L. v. Mullin?

The plaintiffs, who sued on November 20, 2025, raised two main arguments:

1. No individualized finding of willfulness. They said ICE issued fines on boilerplate forms without independently deciding whether a particular person’s failure to leave was “willful” or “voluntary,” as § 1324d requires.
2. No notice-and-comment rulemaking. They challenged the process DHS and the Department of Justice announced in June 2025 (reported as implemented in July 2025), which removed a 30-day notice period, shortened the window for challenging a penalty, and moved appeals to DHS. They said the change needed public notice and comment under the APA.

On December 9, 2025, the plaintiffs moved to certify a class of people subjected to these penalties on or after January 20, 2025. That motion has not been granted.

What Did Judge George A. O’Toole Rule on the DHS Immigration Fines?

According to Reuters, Judge O’Toole held that the administration imposed the fines unlawfully. He found that:

• the forms and notices did not clearly state what each person did to justify a penalty;
• the streamlined fine process was adopted without giving the public a chance to comment first, as the APA requires; and
• halting the policies was necessary because collecting the fines would likely drive the plaintiffs into insolvency.

The ruling targets how DHS imposed and collected the penalties. It does not repeal § 1324d.

Does the Maria L. v. Mullin Ruling Cancel Every $1.8 Million Immigration Fine?

No. Three limits matter:

• The court blocked the challenged policies. How the order treats notices already issued depends on its exact terms and later orders.
• The government can appeal or ask the court to modify the order.
• Someone outside the plaintiffs and any later-certified class may still need to raise their own defenses.

If you hold a DHS penalty notice, treat it as a live legal matter until an attorney confirms how this order applies to you.

Does the Maria L. v. Mullin Ruling Stop Deportation or Cancel Removal Orders?

No. The fine dispute is separate from a final order of removal. The ruling does not change anyone’s immigration status or the obligation to comply with a removal order.

Is There a Claim Form or Refund for DHS Immigration Fines?

No. This is not a consumer settlement. No administrator, compensation fund or claim form exists, and no refund program has been announced. Anyone charging a fee to “file a claim” in this case is not offering something real.

Whether people who already paid could get relief depends on later court orders and the final outcome of the case.

What Should You Do If You Received a DHS Civil Penalty Notice?

1. Keep the full notice. Save every page, the penalty or tracking number, the amount, the dates and the instructions for challenging it.
2. Gather your removal-order history. Collect immigration court decisions, appeals, stays, motions to reopen and any proof of efforts to comply or get travel documents.
3. Read what the notice says about willfulness. This is the issue at the heart of Maria L. v. Mullin.
4. Do not ignore deadlines. A court ruling does not automatically extend your individual deadline. Speak with an immigration attorney or a Board of Immigration Appeals-accredited representative promptly.
5. Watch the docket. Class certification and further orders in No. 1:25-cv-13471 could widen or narrow who is protected.

For related coverage of other federal immigration cases, see State Dept. Green Card Lawsuits, Every Active Case, 2026.

Maria L. v. Mullin Timeline: Key Dates

Date	Event
1996	Congress authorizes civil penalties for willful failure to depart (IIRIRA)
January 20, 2025	Start of the proposed class period
June 2025	DHS and DOJ announce the streamlined civil-penalty process (reported as implemented in July 2025)
November 20, 2025	Maria L. v. Noem filed in the District of Massachusetts
December 9, 2025	Plaintiffs move for class certification
July 2026	DHS reports more than 103,000 fines, about $84 billion assessed
October 5, 2026	Judge O’Toole blocks the challenged fine policies
Pending	Class certification, scope of relief, possible appeal

Frequently Asked Questions About the Maria L. v. Mullin Immigration Fine Ruling

Is the Trump administration still allowed to fine migrants $998 per day?

The court blocked the policies challenged in Maria L. v. Mullin. Section 1324d itself remains law, and the government may appeal.

Can a DHS immigration fine really reach $1.8 million?

Yes. At $998 per day for up to five years, the maximum is about $1.8 million. Actual amounts varied by case.

Who sued DHS over the $1.8 million immigration fines?

Maria L. and Nancy M., two migrants proceeding under pseudonyms, and the Immigrant Legal Resource Center.

What is the case number in Maria L. v. Mullin?

No. 1:25-cv-13471 in the U.S. District Court for the District of Massachusetts.

Has a class been certified in Maria L. v. Mullin?

No. The plaintiffs asked for certification, and it has not been granted, so the case is a putative class action.

Does the ruling erase my DHS civil penalty notice?

Not automatically. The effect on previously issued notices depends on the scope of the order and later proceedings. Get individualized advice from an immigration attorney.

Will people who already paid DHS immigration fines get refunds?

No refund program has been announced.

What happens next in Maria L. v. Mullin?

The court still has to rule on class certification and the final scope of relief, and DHS may appeal or seek changes to the order.

What the Maria L. v. Mullin Ruling Means Right Now

A federal judge in Boston has stopped DHS from continuing to impose and collect the $998-per-day civil fines, finding they were imposed unlawfully under the Administrative Procedure Act. That is a significant win for the plaintiffs and for people holding these notices. It is not a blanket cancellation of fines or removal orders, and the case is still moving. Keep your notice, keep your immigration records, and get qualified legal advice before assuming the ruling resolves your situation.

Sources

1. Reuters, “US judge blocks Trump policy of fining migrants up to $1.8 million,” October 5, 2026.
2. Maria L. et al. v. Mullin et al. (formerly Maria L. v. Noem), No. 1:25-cv-13471 (D. Mass.), case record.
3. 8 U.S.C. § 1324d, civil penalties for failure to depart.
4. U.S. Department of Justice, Executive Office for Immigration Review, 2025 Federal Register notices on civil-penalty procedures.

Disclaimer: AllAboutLawyer.com is a legal information site, not a law firm, and this article is not legal advice. Immigration outcomes depend on individual facts. If you hold a DHS penalty notice or a final removal order, consult a qualified immigration attorney or accredited representative.

Researched and written by Israr Ahmad, legal content researcher and founder of AllAboutLawyer.com. All facts verified against Reuters’ October 5, 2026 report on the ruling, 8 U.S.C. § 1324d, and the public case record for No. 1:25-cv-13471, as of October 6, 2026. Last Updated: October 6, 2026.