J.E.F.M. v. Holder
United States District Court for the Western District of Washington
107 F. Supp. 3d 1119 (2015)
The federal government (defendant) placed nine minor aliens (plaintiffs) in removal proceedings; although they had a statutory right to representation, they couldn't afford counsel, and the government refused to pay for it. The minors sued, claiming their inability to obtain counsel violated due process, and the government moved to dismiss, arguing the Mathews v. Eldridge balancing test didn't apply to their claims or, if it did, that they couldn't satisfy it.
Whether the Mathews test — balancing the alien's interest, the risk of erroneous deprivation, and the government's administrative burden — applies to a due process claim for a right to counsel in removal proceedings.