By Ariana Camarena*
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Introduction
For many international students, the F-1 visa is not merely a travel document—it is their lifeline to education, opportunity, and stability in the United States.[1] Yet, this legal status can be remarkably fragile.[2] A single administrative error, a misunderstanding of work authorization rules, or even a delay in a school’s recordkeeping can unravel years of students’ careful compliance.[3] Once the government labels a student out of status, these students are thrust into a legal limbo, facing possible deportation, bars on reentry, and the permanent taint of an immigration violation.[4]
The current administration has overseen an alarming escalation in deportation actions targeting F-1 students for exercising constitutionally protected speech.[5] The consequences are severe. Unlike U.S. citizens or lawful permanent residents, F-1 students are often stripped of status without formal notice or the opportunity to be heard, as the U.S. Immigration and Customs Enforcement (“ICE”) has begun to directly terminate Student Exchange Visitor Information System (“SEVIS”) records without Designated School official (“DSO”) involvement or academic-related grounds.[6] Their status is often terminated electronically through SEVIS, with little opportunity to respond.[7] Similarly, under doctrines such as consular nonreviewability, courts have upheld limited procedural rights for nonimmigrants.[8]
This reflects a broader legal reality—namely, that under U.S. immigration law, nonimmigrants like F-1 students are afforded only minimal procedural safeguards.[9] The absence of a hearing is a feature of this framework rather than an oversight.
This forum piece examines the precarious legal structure governing F-1 status, the disproportionate consequences students face, and the unsettling reality that even those who follow the rules can find themselves exiled for a single misstep. Alarmingly, some students now face removal from the United States, not for technical violations, but for exercising their First Amendment right to free speech, whether through social media posts, political expression, or views deemed contrary to U.S. policy.[10] In this system, lawful presence offers little protection when due process is limited, and constitutional protections are inconsistently applied.
Waves of Student Visa Revocations Across the United States Spark Confusion
As of April 24, 2025, the federal government has terminated the immigration status of international students at more than 280 colleges and universities, often without any meaningful explanation to either the students or their institutions.[11] In April 2025 alone, more than 6,000 students across the campuses received revocation notices, leaving them suddenly without legal status and vulnerable to deportation.[12] Many of these students, enrolled at U.S. institutions, learned in early April that their legal status had been revoked with little notice, despite having committed no deportable offense.[13] Immigration officers have arrested international students outside of their homes and transported them hundreds, and in some cases thousands of miles away to remote detention facilities, isolating them from their families, attorneys, and universities.[14] The Trump administration’s message is very clear: The United States is no longer a welcoming place for many international students.
Understanding SEVIS and DHS Authority
SEVIS is the centralized federal database managed by the Department of Homeland Security’s (“DHS”) Student and Exchange Visitor Program (“SEVP”), a division of U.S. Immigration and Customs Enforcement.[15] SEVIS tracks F-1 students’ enrollment, compliance with full-time study requirements, employment authorization, and other visa-maintaining conditions.[16]
Originally crafted as an administrative and national security tool, SEVIS has evolved into a mechanism that affords DHS sweeping, largely unreviewable authority, most notably the ability to terminate student records without prior notice or explanation.[17] DHS recently argued in court that deleting a SEVIS record does not automatically revoke status, a position that illustrates both legal ambiguity and the system’s opacity.[18]
Revocation Without Due Process
The First Amendment of the U.S. Constitution protects freedom of speech, ensuring that individuals cannot be punished by the government for expressing their views, even if those views are unpopular or controversial.[19] Similarly, the Fifth Amendment’s Due Process Clause guarantees that all individuals on U.S. soil, including international students, have the right to a hearing before being deprived of life, liberty, or property, such as through deportation.[20]
These protections work together to safeguard students against government actions that target them for their speech or status.[21] The Constitution’s protections extend to all individuals on U.S. soil, regardless of their immigration status.[22] This affirms that individuals have the right to remain silent and cannot be compelled to disclose their name, country of origin, or immigration status to immigration or law enforcement officers.[23] It also underscores that international students, like all persons on U.S. soil, are entitled to due process protections, including a hearing before removal.[24]
However, under the current administration, President Trump suggested that he may even deport American citizens to international prisons, explicitly stating that “homegrowns are next.”[25] This message indicates a potential erosion of constitutional protections for American citizens.[26] This raises serious questions about what protections remain for students. This uncertainty calls into question the scope of constitutional protections afforded to international students.[27] The federal government should be prohibited from targeting international students based on protected speech. Such actions not only undermine the First Amendment’s guarantee of free expression but also violate the due process protections the Constitution affords to all persons, including non-citizens.[28]
When Words Become Grounds for Removal
So, what happens when a student lawfully present in the United States on an F-1 visa exercises her First Amendment right to free speech, perhaps by expressing a political view that diverges from U.S. foreign policy? In such a moment, your right to remain silent may be cold comfort if you are met with summary exclusion, not due process. Without the safeguard of appointed counsel, even the most fundamental rights can feel theoretical.[29]
Recent events underscore this reality. In March 2025, Rumeysa Ozturk, a Turkish national and Tufts University student, was detained after DHS agents revoked her visa, reportedly in connection with her political speech.[30] She was transported to a detention center in Louisiana and held without access to meaningful legal counsel until a federal court ordered her release on bail.[31] Her case highlights how speech alone can trigger visa revocation, detention, and due process violations.[32]
In 2025, thousands of international students had their SEVIS records terminated without notice, explanation, or opportunity to respond.[33] Many were left in limbo, unable to continue their studies or contest the government’s actions.[34] These mass terminations provoked legal challenges, and several courts intervened.[35] In California, a federal judge “blocked the Trump administration from terminating the legal statuses of international students,” and other judges have granted temporary restraining orders mandating reversal of SEVIS-based deportations linked to protest activity.[36] In Texas, another judge reinstated the status of an Iranian student at Texas A&M after his visa was wrongly revoked.[37] These rulings affirm that the government’s actions raised profound due process concerns.[38]
Consider the case of Ismail Ajjawi, a seventeen-year-old Palestinian student admitted to Harvard on an F-1 visa.[39] Upon arrival at Boston Logan Airport, Ajjawi was detained, his devices were searched for several hours, and his visa was revoked after an immigration official objected to political and religious posts made by his friends on social media.[40] Although Ajjawi explained that he had not engaged with the posts himself, he was still deemed “inadmissible.”[41] Despite being legally admitted to study, he was deported to Lebanon without meaningful access to counsel or an opportunity to contest the allegations, an acute example of due process violations rooted in speech-based and religious profiling.[42]
International Students Challenge Sudden Revocations
To challenge sudden revocations, students and their advocates have turned to the courts, and in several instances, federal judges have issued temporary restraining orders to reinstate students’ statuses while legal challenges proceed.[43] DHS contends that affected students can transfer their academic credits or pursue opportunities in other countries.[44] However, students and their advocates highlight that the disruptions to their education and future careers, as well as the mental and financial toll of the sudden status changes, far outweigh these proposed alternatives.[45]
Consider the case of Anjan Roy, a student from Bangladesh enrolled at Missouri State University.[46] Roy received an unexpected email notifying him that his legal status had been terminated.[47] The abrupt loss of legal status led to significant emotional distress and fear of detention or deportation.[48] Roy’s case is among several where a federal judge has issued a temporary restraining order.[49] His case illustrates how the government’s proposed alternatives fall short of addressing the harm caused by sudden revocation.
Critique: Procedural Gaps and the Chilling Effect on Free Speech
While the U.S. government justifies these actions by citing national security concerns and potential threats posed by politically motivated speech, the lack of due process for international students facing visa revocation is deeply troubling.[50] Immigration law grants the executive branch broad authority to exclude or remove noncitizens deemed to endanger national security or foreign policy.[51] Courts have historically deferred to such claims, upholding visa denials so long as the government offers a “facially legitimate and bona fide reason.”[52] Yet applying these broad powers to silence student dissent conflates political expression with security threats, thereby undermining the constitutional values the government claims to defend.[53]
Unlike U.S. citizens or lawful permanent residents, students on F-1 visas face summary removal from the country without a formal hearing, depriving them of their right to contest the allegations.[54] This process is further exacerbated by the lack of appointed counsel, which compounds the already fragile legal position of noncitizens in the U.S. immigration system.
Proposed Reforms
To mitigate these harms, several reforms are necessary. First, Congress should require that international students, like other noncitizens, receive basic procedural protections such as notice and an opportunity to be heard before their immigration status is terminated.[55] Legal scholars and courts have long recognized that due process protections extend to noncitizens residing within the United States, and many now argue that immigration law’s existing framework falls short of offering adequate procedural safeguards.[56]
Although judicial deference in immigration has been historically broad, scholars increasingly argue that the plenary power doctrine[57] must be narrowed to allow for meaningful review in cases involving free speech or due process claims.[58]
Third, greater transparency and oversight are needed in the operation of the SEVIS.[59] Terminations should not occur without a clear explanation and an opportunity for students to respond. Oversight reports have already criticized the lack of accountability in SEVIS, and immigration scholars have urged that prosecutorial discretion in this area be exercised with transparency and restraint.[60]
Finally, universities themselves must play a stronger role in safeguarding their students. Institutions of higher education have already demonstrated their capacity to advocate for international students in moments of heightened restriction.[61] Policy experts likewise emphasize the need for a coordinated federal-university response to protect students’ rights and ensure they can continue their studies without fear of abrupt status loss.[62] By pairing procedural protections with institutional advocacy, these reforms would safeguard due process while maintaining the government’s legitimate security interests.
Conclusion
This trend raises significant concerns regarding the freedom of speech in academic environments. The sudden and arbitrary revocation of students’ visa status based on their political views or participation in protests creates a chilling effect. If students fear retaliation for expressing dissenting political opinions, particularly when such opinions may diverge from U.S. foreign policy, they may self-censor or avoid participating in public discourse altogether.
The First Amendment safeguards the right to free speech,[63] but when political expression becomes grounds for immigration penalties, that protection is effectively undermined for noncitizens. Protecting the rights of international students is not only a constitutional imperative but also a practical one: F-1 students contribute to the nation’s future as leaders in medicine, commerce, research, and the arts.[64] Their presence reflects the diversity that has long been a source of strength for the United States, and safeguarding their ability to speak freely ensures that academic institutions remain vibrant spaces of democratic exchange.
* Ariana Camarena, J.D., Esq., University of San Francisco School of Law, 2024; B.S., University of California, Davis. This piece is dedicated to my family and friends, without their unwavering support, encouragement, and love throughout my academic and professional journey, this work would not have come to life. To every law student: let this be a reminder to pursue the work that ignites your passion. As Maya Angelou beautifully said, “My mission in life is not merely to survive, but to thrive; and to do so with some passion, some compassion, some humor, and some style.” Finally, my deepest gratitude to USF Law Review for providing a platform to spotlight the urgent need for reform in how our nation enforces immigration policy, particularly towards international students.
[1]. Alison Moodie, The F-1 Student Visa, Explained, Boundless (July 21, 2025), https://www.boundless.com/immigration-resources/f-1-student-visa-explained/ [https://perma.cc/CE2S-2D7A].
[2]. Maintaining Status, U.S. Dep’t Homeland Sec.: Study in the States, https://
studyinthestates.dhs.gov/students/maintaining-status [https://perma.cc/5JSE-L2DD] (last visited Oct. 11, 2025).
[3]. Loss and Reinstatement of F-1 Status, Univ. Md., Balt. Cnty.: Off. Int’l Students & Scholars, https://isss.umbc.edu/international-students-f-1/current-students/reinstatement-of
-f-1-status/ [https://perma.cc/JY4F-MEYG] (last visited Oct. 11, 2025).
[5]. Visa Revocation Litigation: AAUP v. Rubio, Presidents’ All. on Higher Educ. & Immigr., https://www.presidentsalliance.org/litigation/visa-revocation-litigation/ [https://
perma.cc/BM93-U7JR] (last visited Oct. 11, 2025); see also Am. Ass’n Univ. Professors v. Rubio, 780 F. Supp. 3d 350 (D. Mass. 2025) (discussing alleged violation of the First Amendment right to engage in political speech due to public officials’ policy of targeting noncitizens who engaged in pro-Palestinian or anti-Israel speech and association for arrest, detainment, and deportation).
[6]. Presidents’ All. on Higher Educ. & Immigr., International Student Visa Revocations and SEVIS Record Terminations: Guidance for Colleges & Universities 3 (2025), https://www.presidentsalliance.org/wp-content/uploads/2025/05
/Updated-FAQ-Understanding-Recent-International-Student-Visa-Revocations-and-Apprehensions_-Guidance-for-Colleges-Universities.pdf [https://perma.cc/Q483-N6VU].
[7]. William J. Manchinton Jr., F-1 Student Visa Revoked and SEVIS Status Terminated? Here’s What You Need To Know!, Law Off. Matthew W. Peterson (Apr. 7, 2025), https://
mwpetersonlaw.com/f-1-visa-revoked-and-sevis-status-terminated/ [https://perma.cc/9UC9
-BJNG].
[8]. See Kleindienst v. Mandel, 408 U.S. 753, 764, 782–83 (1972); see also Landon v. Plasencia, 459 U.S. 21 (1982) (holding that returning lawful permanent residents were found to have only minimal due process protections at the border).
[9]. Presidents’ All. on Higher Educ. & Immigr., supra note 6, at 3, 7.
[11]. International Student Visas Revoked, Inside Higher Ed, https://
www.insidehighered.com/news/global/international-students-us/2025/04/07/where-students
-have-had-their-visas-revoked [https://perma.cc/T5RS-KZF4] (last visited Oct. 11, 2025); see F-1 Student Visa Revocations / SEVIS Terminations, Murthy L. Firm (Apr. 4, 2025), https://www.murthy.com/2025/04/04/f-1-student-visa-revocations-sevis-terminations/ [https://perma.cc/S7P7-BSVU]; see also Kim Lovaas, Update From the ISS Director: SEVIS Records Cancelled, Univ. Wash.: Int’l Student Servs. (Apr. 8, 2025), https://iss.washington.edu
/immigration-update-sevis-records-cancelled/ [https://perma.cc/8Q6J-TQNK] (describing the cancelation of UW students’ F-1 visas and SEVIS records).
[12]. See Solcyré Burga, The State Department Has Revoked More Than 6,000 Student Visas, Time (Aug. 20, 2025, at 12:49 PT), https://time.com/7310743/student-visas-revoked-us-trump-immigration/ [https://perma.cc/9KEW-FP7T].
[13]. Annie Ma, Makiya Seminera & Christopher L. Keller, Visa Cancellations Sow Panic for International Students, With More Than 1,000 Fearing Deportation, Associated Press (Apr. 17, 2025, at 9:57 PT), https://apnews.com/article/international-student-f1-visa-revoked-college
-f12320b435b6bf9cf723f1e8eb8c67ae [https://perma.cc/PWK6-BDNK].
[14]. Eric Levenson & Gloria Pazmino, Why ICE Is Really Moving Detainees Over a Thousand Miles From Where They Were Arrested, CNN (Apr. 10, 2025 at 13:06 ET), https://www.cnn.com/2025/04/10/us/immigration-detainees-trump-ice-students-visa [https://perma.cc/G5SD-ELMN].
[15]. Student and Exchange Visitor Program, U.S. Immigr. & Customs Enf’t, https://www.ice.gov/sevis [https://perma.cc/4H6M-9DTE] (last visited Sep. 6, 2025).
[16]. See SEVIS Reporting Requirements for Designated School Officials, U.S. Immigr. & Customs Enf’t (Dec. 11, 2024), https://www.ice.gov/sevis/dso-requirements [https://perma.cc/NXD2
-CMTV].
[17]. Sara Yang, Due Process in Question: The Right Violations Behind SEVIS System and F-1 Visa Revocations, Colum. Undergraduate L. Rev. (Aug. 17, 2025), https://www.culawreview.org
/current-events-2/due-process-in-question-the-right-violations-behind-sevis-system-and-f-1-visa
-revocations [https://perma.cc/M8JW-68UG].
[18]. See Mahsa Aliaskari & Fanny Wong, The New Risk for Global Talent: F-1 SEVIS Terminations and Student Visa Revocations, Seyfarth: Through the Immigr. Lens (Apr. 22, 2025), https://www.throughtheimmigrationlens.com/2025/04/the-new-risk-for-global-talent-f-1-sevis
-terminations-and-student-visa-revocations/ [https://perma.cc/XF75-MWN3].
[19]. See U.S. Const. amend. I; see also Texas v. Johnson, 491 U.S. 397, 414 (1989) (“[T]he government may not prohibit the expression of an idea simply because society finds it offensive or disagreeable.”).
[22]. Erica Bryant, What Does “Due Process” Mean for Immigrants and Why Is It Important?, Vera (June 4, 2025), https://www.vera.org/news/what-does-due-process-mean-for-immigrants-and
-why-is-it-important [https://perma.cc/7F6E-GZUJ].
[23]. Immigrants’ Rights, ACLU (Sep. 3, 2025), https://www.aclu.org/know-your
-rights/immigrants-rights [https://perma.cc/L8VF-SJSA] (noting the right to remain silent includes not disclosing immigration status or country of origin in most states).
[25]. Brian Mann, ‘Homegrowns Are Next’: Trump Hopes to Deport and Jail U.S. Citizens Abroad, NPR (Apr. 16, 2025, at 11:56 ET), https://www.npr.org/2025/04/16/nx-s1-5366178/trump
-deport-jail-u-s-citizens-homegrowns-el-salvador [https://perma.cc/Y6QE-TN29].
[27]. See Tinker v. Des Moines Indep. Cmty. Sch. Dist., 393 U.S. 503, 506 (1969).
[28]. See Plyer v. Doe, 457 U.S. 202, 210 (1982).
[29]. Ingrid Eagly & Steven Shafer, Am. Immigr. Council, Access to Counsel in Immigration Court 1 (2016), https://www.americanimmigrationcouncil.org/wp-content
/uploads/2025/01/access_to_counsel_in_immigration_court.pdf [https://perma.cc/49AM
-EJ7G].
[31]. See Gloria Pazmino, Andy Rose & Yash Roy, What We Know About the Tufts University PhD Student Detained by Federal Agents, CNN (Mar. 28, 2025, at 21:20 ET), https://www.cnn.com/2025/03/27/us/rumeysa-ozturk-detained-what-we-know [https://perma.cc/M9C8-WHRM]; Press Release, ACLU, Rümeysa Öztürk To Be Freed From Detention as Case Proceeds (May 9, 2025, at 13:27 ET), https://www.aclu.org/press-releases
/rumeysa-ozturk-to-be-freed-from-detention-as-case-proceeds [https://perma.cc/QZ9T
-CAKN].
[35]. Ashley Mowreader, Federal Government Reverses SEVIS Terminations, Inside Higher Ed (Apr. 25, 2025), https://www.insidehighered.com/news/global/international-students
-us/2025/04/25/ice-reverses-course-sevis-terminations [https://perma.cc/U6U3-EDBL].
[36]. Kimmy Yam & Chloe Atkins, Federal Judge Blocks Trump Administration From Revoking International Students’ Legal Status, NBC News (May 22, 2025, at 18:37 PT), https://www.nbcnews.com/politics/immigration/judge-blocks-trump-revoking-international-students-legal-status-rcna208625 [https://perma.cc/2B57-NZDY].
[37]. Samantha Ketterer, Federal Judge Orders Temporary Restoration of Legal Status for Iranian Student at Texas A&M, Hou. Chron. (Apr. 24, 2025), https://www.houstonchronicle.com/news
/houston-texas/education/article/texas-a-m-student-iran-given-reprieve-visa-revoked-20293170.php [https://perma.cc/X3FT-QTJ2].
[38]. See Yam & Atkins, supra note 36.
[39]. Sarah Ruiz-Grossman, Student Says U.S. Immigration Denied Him Entry After Seeing Friends’ Social Media Posts, HuffPost (Aug. 27, 2019, at 16:22 ET), https://www.huffpost.com/entry
/student-palestinian-immigration-denied-harvard_n_5d6586f6e4b022fbceb25926 [https://perma.cc/UWC5-S4ZU]; see also Rob Frehse & Evan Simko-Bednarski, Harvard Student Previously Denied Entry into US Is Now on Campus for Classes, CNN (Sep. 3, 2019, at 12:39 ET), https://www.cnn.com/2019/09/02/us/harvard-student-allowed-into-us [https://perma.cc/683P-6P4A] (describing Ajjawi’s initial denial of entry and his later return to campus).
[40]. Ruiz-Grossman, supra note 39.
[43]. See id.; Sterling Davies, Students Granted Temporary Restraining Orders Against the Trump Administration After Visa Revocations, Stan. Daily (Apr. 30, 2025, at 00:18 PT), https://
stanforddaily.com/2025/04/30/students-granted-temporary-restraining-orders-against-the
-trump-administration-after-visa-revocations/ [https://perma.cc/K24S-LDU2].
[44]. See Ruiz-Grossman, supra note 39; Harvard University Loses Student and Exchange Visitor Program Certification for Pro-Terrorist Conduct, U.S. Dep’t Homeland Sec. (May 22, 2025), https://www.dhs.gov/news/2025/05/22/harvard-university-loses-student-and-exchange-visitor-program-certification-pro [https://perma.cc/VV62-KK3P].
[45]. See Ruiz-Grossman, supra note 39.
[46]. Christopher L. Keller & Hannah Fingerhut, Missouri State University Student, Other International Students Stripped of U.S. Status Winning Court Battles, KY3 (Apr. 23, 2025, at 08:29 PT), https://www.ky3.com/2025/04/23/missouri-state-university-student-other-international
-students-stripped-us-status-winning-court-battles/ [https://perma.cc/LZ4G-8ZV5].
[50]. See Alyssa Lukpat & Victoria Albert, On College Campuses, Students Weigh the Risk of Resistance, Wall St. J. (Sep. 6, 2025, at 12:00 ET), https://www.wsj.com/us-news/education/college
-protest-risk-e5481800 [https://perma.cc/9WG8-X9NG].
[51]. See 8 U.S.C. § 1182(f); Trump v. Hawaii, 585 U.S. 667, 683 (2018).
[52]. See Kleindienst v. Mandel, 408 U.S. 753, 770 (1972).
[53]. See U.S. Const. amend. I; Speech on Campus, ACLU (Dec. 18, 2023), https://www.aclu.org/documents/speech-campus [https://perma.cc/PMS9-K7BA]; see also Alice Speri, The FBI Has a Long History of Treating Political Dissent as Terrorism, Intercept (Oct. 22, 2019, at 12:03 PT), https://theintercept.com/2019/10/22/terrorism-fbi-political-dissent/ [https://perma.cc/5RWT-X56W] (discussing the FBI’s continuous efforts to conflate dissent with terrorism); see generally Hanna Park, Trump’s Crackdown on University Protests is Casting a Long Shadow. Activists Hope He’s Also Providing a Spark, CNN (Apr. 6, 2025, at 6:00 ET), https://www.cnn.com/2025/04/06/us/trump-crackdown-university-protests-student-activism-hnk [https://perma.cc/4GTP-VUS8] (discussing students’ experience with protests in relation to the current administration).
[54]. See 8 U.S.C. § 1225(b); see also Landon v. Plasencia, 459 U.S. 21, 32–33 (1982).
[55]. See generally Stephen H. Legomsky et al., Immigration and Refugee Law and Policy (7th ed. Supp. 2022) (discussing constitutional limits on immigration powers and rights of noncitizens).
[56]. See generally Raquel E. Aldana & Thomas O’Donnell, A Look Back at the Warren Court’s Due Process Revolution Through the Lens of Immigrants, 51 U. Pac. L. Rev. 633 (2020) (discussing the impact of the Warren Court’s criminal due process legacy and its effect on immigration law over fifty years).
[57]. See u.s. const. art. I., § 8, cl. 18 (indicating that “Congress retains broader power with respect to aliens seeking to enter this country.”).
[58]. See Michael Kagan, Plenary Power Is Dead! Long Live Plenary Power, 114 Mich. L. Rev. First Impressions 21, 25–27 (2015).
[59]. See Student and Exchange Visitor Program, supra note 15; Shoba Sivaprasad Wadhia, The Role of Prosecutorial Discretion in Immigration Law, 9 Conn. Pub. Int. L.J. 243, 264–65 (2010).
[60]. Wadhia, supra note 59, at 265.
[61]. See generally 180 Institutions of Higher Education Join Litigation in Opposing Administration’s “International Student Ban”, Presidents’ All. on Higher Educ. & Immigr. (Oct. 17, 2022), https://www.presidentsalliance.org/press/180-institutions-of-higher-education-join-litigation-in-opposing-administrations-international-student-ban/ [https://perma.cc/6SUU-HBJB] (announcing that the Presidents’ Alliance on Higher Education and Immigration has “led 180 member colleges and universities in filing an amicus brief in support of Harvard University and the Massachusetts Institute of Technology’s legal complaint against the U.S. Department of Homeland Security”).
[62]. See The United States Needs a Coordinated National Strategy for International Education, NAFSA: Issue Brief 1 (May 2023), https://www.nafsa.org/sites/default/files/media/document
/National_Strategy_Issue_Brief_May_2023.pdf [https://perma.cc/FQG7-46LM].
[63]. See U.S. Const. amend. I.
[64]. See Press Release, NAFSA, Int’l Students Contribute Record-Breaking Level of Spending and 378,000 Jobs to the U.S. Economy, (Nov. 18, 2024), https://www.nafsa.org/about
/about-nafsa/international-students-contribute-record-breaking-level-spending-and-378000-jobs [https://perma.cc/8NEP-QKAC].