KEY TAKEAWAYS
- States with the highest unrepresented removal: Three states recorded unrepresented removal rates exceeding 87 percent, with the highest reaching 90.14 percent between 2021 and 2025.
- Regional concentration in the South and Midwest: Eight of the top 10 states with the highest unrepresented removal rates are in the South or Midwest.
- States with the best access to legal representation: Indiana led the nation with 74.74 percent of removed immigrants having legal counsel, while New Jersey and Massachusetts exceeded 30 percent representation rates.
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 by The Mendoza Law Firm analyzed 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
| Rank | State | Avg. Annual Total Removals | Avg. Annual Unrepresented Removals | % Without Legal Representation |
| 1 | Colorado | 6,138 | 5,533 | 90.14% |
| 2 | Missouri | 2,486 | 2,213 | 89.02% |
| 3 | North Carolina | 10,744 | 9,425 | 87.72% |
| 4 | Nevada | 1,732 | 1,505 | 86.90% |
| 5 | Tennessee | 7,040 | 6,057 | 86.04% |
| 6 | Ohio | 4,668 | 3,953 | 84.69% |
| 7 | Georgia | 11,339 | 9,588 | 84.56% |
| 8 | Minnesota | 4,229 | 3,569 | 84.41% |
| 9 | Illinois | 6,866 | 5,726 | 83.41% |
| 10 | Texas | 51,473 | 42,646 | 82.85% |
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
| Rank | State | Avg. Annual Unrepresented Removals | Avg. Annual Total Removals | % Unrepresented |
| 1 | Texas | 42,646 | 51,473 | 82.85% |
| 2 | California | 22,339 | 29,973 | 74.53% |
| 3 | New York | 19,642 | 25,858 | 75.96% |
| 4 | Florida | 11,293 | 14,532 | 77.71% |
| 5 | Georgia | 9,588 | 11,339 | 84.56% |
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)
| Rank | State | 2021 Removals | 2025 Removals | Increase | % Change |
| 1 | Tennessee | 205 | 16,779 | +16,574 | +8,085% |
| 2 | Minnesota | 300 | 8,322 | +8,022 | +2,674% |
| 3 | New York | 2,110 | 49,007 | +46,897 | +2,223% |
| 4 | Texas | 4,715 | 98,339 | +93,624 | +1,985% |
| 5 | Virginia | 1,217 | 24,097 | +22,880 | +1,880% |
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)
| Rank | State | 2021 Unrepresented | 2025 Unrepresented | Increase |
| 1 | Texas | 2,872 | 79,929 | +77,057 |
| 2 | California | 1,788 | 50,044 | +48,256 |
| 3 | New York | 922 | 38,307 | +37,385 |
| 4 | Florida | 1,238 | 24,388 | +23,150 |
| 5 | Georgia | 930 | 19,117 | +18,187 |
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.
TOP 5 STATES BY ACCESS TO LEGAL REPRESENTATION
| Rank | State | % WITH Legal Representation | Avg. Annual Removals |
| 1 | Indiana | 74.74% | 403 |
| 2 | Massachusetts | 42.07% | 4,741 |
| 3 | New Jersey | 31.44% | 7,359 |
| 4 | Hawaii | 28.43% | 120 |
| 5 | Nebraska | 28.01% | 1,656 |
Indiana saw nearly three-quarters of removed immigrants receive legal representation, a rate significantly higher than any other state. The second-ranked state upheld a representation rate more than twice that of most Southern and Midwestern states, despite handling over 4,700 removals annually.
METHODOLOGY
This analysis examined ICE removal case data from TRAC Immigration Reports for the fiscal years 2021-2025, focusing on 29 states. It looked at cases where immigrants had no legal representation at the time of case closure. National totals show an average of 239,064 annual removals, with 79.1% unrepresented. The dataset does not establish a causal relationship between legal representation and removal outcomes, and 21 states have incomplete data.
DATA SOURCES
TRAC Immigration Reports: Transactional Records Access Clearinghouse (TRAC) Syracuse University: https://tracreports.org/phptools/immigration/closure/
Research Datasheet: https://docs.google.com/spreadsheets/d/1Bwzx3FIuvaCcGOQuox5O8qjSojdq6ggnpHspSv9E5wM/
Study by: https://mendozafirm.com/
ABOUT THE MENDOZA LAW FIRM
The Mendoza Law Firm, LLC, is a U.S.-based immigration law firm dedicated to helping immigrants obtain work permits, permanent legal residence, and humanitarian protection. The firm provides legal services across a range of immigration matters, including family-based petitions, asylum applications, and visa processing, with a commitment to accessible and ethical representation.
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