Arrested at the Very Place She Went to Keep Her Word

On February 18, 2026, at approximately 10:30 a.m., at the John Moss Federal Building in Sacramento, California, 42-year-old Maria de Jesus Estrada Juarez appeared at the U.S. Citizenship and Immigration Services (USCIS) office for a green card interview. She had come to the United States as a teenager and had lived in the country for more than 25 years, working legally and paying taxes under the protection of DACA (Deferred Action for Childhood Arrivals). What awaited her when she left the USCIS building that day was not approval of her green card, but agents from Immigration and Customs Enforcement (ICE). Less than 24 hours after her arrest, Estrada Juarez was deported to Puebla, Mexico.

At the same time, in Omaha, Nebraska, the opposite happened. Joel Angel-Becerril, 27, also a DACA recipient, had been held in ICE detention for about three months when an immigration judge dismissed the deportation proceedings against him on the basis of his DACA protection, and he was released. In the same country, under the same program, at the same time, one person was deported and another was set free. These two cases symbolize the extreme uncertainty in which DACA recipients now find themselves.

The Arrest at the Immigration Office: What Happened

"The place she went to obey the law became a trap."

Estrada Juarez's case is not simply an enforcement action. She was in the middle of the green card process and appeared for her interview on the date USCIS had set. According to the Sacramento Bee, during the interview an immigration official referenced an expedited removal order that remained on her record from 1998, when she was 15 years old. Estrada Juarez said she had not even known such an order existed. After the interview, she was handed a document stating, "USCIS is unable to complete your case at this time," and was arrested by ICE the moment she stepped out of the building.

DHS spokesperson Tricia McLaughlin said in a statement that Estrada Juarez "received a final removal order from a judge in 1998 and later illegally reentered the country," asserting that "due process was followed." She added that "DACA does not confer any form of legal status in this country." However, the Sacramento Bee reported that its search of federal immigration databases turned up no record matching Estrada Juarez. What it did find were her DACA renewal records, her lawful-status applications, and documentation of a previously approved reentry (advance parole) permit.

Estrada Juarez's daughter, Damaris Bello, said, "We tried to do it the right way." Local officials, including Sacramento Vice Mayor Karina Talamantes, held a press conference outside the federal building demanding her return. She had worked at a local hotel for more than 15 years — a hotel under contract with the City of Sacramento to provide services for the homeless. According to her family, she claims she was denied necessary medical care while in detention.

261 Arrested, 86 Deported: What the Numbers Reveal

"Individual stories are buried inside statistics, but without statistics, the full picture cannot be seen."

Estrada Juarez's case was not an isolated incident. On February 26, 2026, the contents of a letter from DHS Secretary Kristi Noem to federal senators were made public, revealing the scale of the problem. According to Secretary Noem's letter, between January 1 and November 19, 2025, ICE arrested 261 DACA recipients and deported 86 of them. Because this period includes the final 19 days of the Biden administration, it is unclear exactly how many of these arrests occurred after the Trump administration returned to office.

Secretary Noem's letter claimed that 241 of the 261 people arrested had "criminal histories." According to reporting by CBS News and Politico, DHS declined to disclose the specifics of these criminal histories — what kinds of offenses were involved, or whether they were convictions or merely arrests — citing "privacy" concerns. In response, Senators Alex Padilla, Dick Durbin, and Mark Kelly issued a joint statement criticizing the arrests, saying, "These arrests tear apart families and harm communities."

As of June 2025, approximately 515,600 people held active DACA status in the United States. The 261 arrests amount to 0.05% of that total, but the psychological weight of this number is far greater than the percentage suggests. For individual DACA recipients, this number becomes grounds for fear that they, too, could be next. In particular, cases like Estrada Juarez's — someone arrested while properly appearing at the immigration office — send the paradoxical message that complying with the law can itself become grounds for enforcement.

The vagueness of the term "criminal history" also deserves attention. Under U.S. immigration law, "criminal history" is a broad concept that can include not only convictions but also mere arrests, charges that were later dismissed, and even traffic violations. As Angel-Becerril's case shows, a dismissed charge alone became grounds for ICE detention. Unless DHS discloses what level of criminality its claim about the 241 people actually reflects, this number alone makes it difficult to judge whether the arrests were justified.

Same Program, Opposite Outcomes

"One law produces two fates."

The case of Joel Angel-Becerril in Nebraska stands in stark contrast to Estrada Juarez's. Angel-Becerril was arrested by ICE in Douglas County on December 2, 2025. According to Grant Friedman, an attorney with the ACLU of Nebraska who represented him, Angel-Becerril had never been criminally convicted. County court records showed an assault-related charge from the previous summer, but that charge had been dismissed. On the very day the charge was dismissed, ICE took him into custody from the county jail and transferred him to an immigration detention facility.

After roughly three months in detention, on February 21, 2026, an immigration judge in Omaha dismissed the removal proceedings against Angel-Becerril. The basis for the dismissal was his DACA protected status. The ACLU of Nebraska stated that "DHS filed a motion to terminate the removal proceedings, and the immigration judge granted it." In other words, the government itself withdrew the removal case. Along the way, a federal court order requiring a bond hearing in response to ICE's no-bond detention policy also helped shape the outcome through judicial intervention.

What decided the difference between the two cases was not the law itself, but the exercise of enforcement discretion. In Estrada Juarez's case, a removal order issued 28 years earlier took precedence over her DACA protection. In Angel-Becerril's case, DACA protection took precedence over the grounds for removal. The official USCIS website still defines DACA as "an exercise of prosecutorial discretion not to pursue removal of an individual." Yet which way that discretion will be exercised has become unpredictable. Even under the protection of the same program, outcomes diverge depending on which immigration judge one happens to appear before or which ICE field office has jurisdiction. Angel-Becerril had the benefit of legal representation through the ACLU, and his case reached federal court, but for Estrada Juarez, less than 24 hours passed between arrest and deportation, effectively shutting off any real chance at legal recourse.

The End of Protected Locations and Where DACA Renewal Stands Today

"When the rules change, the same act can produce a different result."

Behind the fact that Estrada Juarez could be arrested inside a USCIS building lies an institutional change. On January 20, 2025, the Trump administration rescinded the "Protected Areas" policy put in place under the Biden administration. That policy, which had stood for more than a decade, restricted immigration enforcement at so-called sensitive locations, including schools, hospitals, houses of worship, and courthouses. Once the policy was rescinded, ICE agents became able to carry out arrest operations even in places that had previously been effectively off-limits. USCIS offices, too, are no longer a blind spot for enforcement.

This change poses a particularly direct threat to DACA recipients. DACA must be renewed every two years, and the renewal process can require a visit to the immigration office for fingerprinting (biometrics). Appearing at the immigration office is likewise required during green card or citizenship application proceedings. The very act of appearing at the immigration office has itself become an act that carries potential enforcement risk. According to the official USCIS website, DACA renewal applications continue to be accepted and processed, and current DACA status and its associated Employment Authorization Document (EAD) remain "valid until they expire or are individually terminated."

Still, the future of DACA itself remains legally unstable. The U.S. District Court for the Southern District of Texas ruled in 2021 that DACA was unlawful, and the Fifth Circuit Court of Appeals upheld that ruling. The courts did, however, allow renewals for existing recipients to continue. New applications have remained suspended since 2017. Roughly 515,000 people currently hold active DACA status, but with new entries blocked, that number keeps shrinking under a structure in which only departures occur from the existing pool of recipients. The program is quietly dying out even before it is formally eliminated. The fact that the recipient population, once close to 800,000, has fallen into the 510,000s illustrates this trend. The places left empty by people who gave up on renewing, aged out, were deported, or transitioned to another status such as a green card are not being filled by new entrants.

Closing

In the wake of Estrada Juarez's case, Sacramento City Council member Lisa Kaplan called her detention and deportation "unlawful," and local elected officials have demanded a federal investigation. DHS, however, continues to repeat its position that "DACA does not confer any legal status." It is technically true that DACA is a program built on prosecutorial discretion rather than a system that confers legal status, but to people who have held work authorization, paid taxes, and obtained driver's licenses under that program for decades, this distinction can only sound like a cruel technicality. Caught in that gap, DACA recipients are left weighing whether to renew and whether it is even safe to appear at the immigration office.

What can be confirmed at this point is the following. DACA renewal applications remain available and continue to be processed. Yet a precedent has now been set showing that the mere act of visiting the immigration office can carry enforcement risk. There are cases, like Angel-Becerril's, where DACA protection is recognized in court, but there are also cases, like Estrada Juarez's, where a past removal order takes precedence over DACA. This is an environment in which consistent outcomes are difficult to expect.

There are practical steps a DACA recipient can take. As the renewal date approaches, it is recommended to file the application 120 to 150 days before the expiration date. Because a delayed renewal after the employment authorization document has already expired results in the loss of lawful work authorization, filing with enough lead time matters. If an appearance at the immigration office is scheduled, it is important to check in advance whether one's immigration record contains any past removal order or unresolved legal issue. As Estrada Juarez's case shows, a past record the person is not even aware of can exist. Requesting one's own immigration file (A-file) through a Freedom of Information Act (FOIA) request to the immigration office is one way to do this.

And whatever immigration proceeding one attends, having an immigration attorney present, or consulting one beforehand, is needed now more than ever. The paradox of a person who tries to follow the law not being protected by it is a problem the system itself must fix, but until that system is repaired, what an individual can do is secure every piece of information and legal assistance available.

Disclaimer: This column is provided for general informational purposes only and does not constitute legal advice for any specific case. For matters concerning your individual immigration situation, please consult an immigration attorney.

Law Office of Jin D. Cho, P.C.

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