Between 2021 and 2025, ICE removed an average of 239,064 immigrants annually from 29 states, and 189,159 of them never had a lawyer. As removal numbers surged by thousands of percent in some states, the gap between those with legal counsel and those without widened dramatically.
The study byThe Mendoza Law Firmanalyzed ICE removal case data from TRAC Immigration Reports to examine legal representation rates across U.S. states from 2021 to 2025.
TOP 10 STATES BY PERCENTAGE OF REMOVALS WITHOUT LEGAL REPRESENTATION
Colorado’s 90.14 percent unrepresented rate means approximately 9 in 10 immigrants faced removal without an attorney. Texas, while ranking 10th by percentage, accounts for the largest raw number of unrepresented removals at 42,646 annually.
TOP 5 STATES BY VOLUME OF UNREPRESENTED REMOVALS
The top five states by volume account for over 105,000 unrepresented removals per year, more than half of the national total. The leading state alone averaged more unrepresented removals annually than the second and third-ranked states combined.
TOP 5 STATES BY PERCENTAGE INCREASE IN ICE REMOVALS (2021 vs. 2025)
Tennessee saw removals grow from 205 to over 16,700, an 8,085% surge. These dramatic increases outpaced any proportional expansion in legal representation resources.
TOP 5 STATES BY GROWTH IN UNREPRESENTED REMOVALS (2021 vs. 2025)
Texas added more than 77,000 unrepresented removals between 2021 and 2025, an increase that alone exceeds the total annual unrepresented removals of any other single state. The combined increase across these five states represents over 200,000 additional unrepresented removals compared to 2021 levels.
Source: Insider Paper
