- A federal court ruled that ICE acted unlawfully by terminating a student’s visa based on a dismissed speeding ticket.
- Judge Reyes found the agency’s mass screening program violated the Administrative Procedure Act and denied due process.
- The decision ordered the immediate restoration of status for the Indian-origin student at the University of Wisconsin–Milwaukee.
(MILWAUKEE, WISCONSIN) — A US federal court ruled on February 27, 2026, that ICE acted unlawfully when it terminated the F-1 visa status of Akshar Patel, an Indian-origin student at the University of Wisconsin–Milwaukee, based solely on a dismissed 2018 speeding ticket.
Judge Ana C. Reyes, presiding in Patel v. Lyons, found the agency’s action violated the Administrative Procedure Act as arbitrary, capricious, and lacking due process because the traffic ticket involved no conviction and no evidence of risk.
The decision ordered Patel’s status restored and faulted ICE for terminating his SEVIS record without warning or any opportunity to respond, after a review that swept in minor or dismissed matters.
Patel’s case grew out of ICE’s early 2025 Student Criminal Alien Initiative, a program that screened approximately 1.3 million international students against the FBI’s NCIC database.
That screening flagged matches that included dismissed cases, not just criminal convictions, and Patel’s SEVIS termination came during that activity, the court record shows.
Patel, an Indian national studying at the University of Wisconsin–Milwaukee on an F-1 visa, had no criminal convictions, with the sole issue a fully dismissed 2018 traffic citation described as speeding or reckless driving.
Even so, ICE’s SEVIS termination left him out of status, which barred him from classes and put him at risk of removal.
Patel sued ICE and secured a temporary restraining order restoring his status while the case proceeded.
ICE later attempted a quiet restoration of his status, but Patel continued to press the lawsuit and prevailed on the merits after the court rejected the government’s argument that the dispute had become moot.
Reyes’ ruling framed the dispute around administrative law limits on agency action, concluding ICE acted in a way the APA does not allow when it relied on a dismissed traffic ticket to end a student’s immigration status without notice and without due process.
The court’s reasoning also criticized mass enforcement sweeps that rely on minor or dismissed infractions, stressing that agencies must follow legal procedures when they take steps as consequential as terminating a SEVIS record.
Although the case centered on one student in Milwaukee, it addressed a broader enforcement mechanism that affected international students whose records were flagged in a database screen that did not limit itself to convictions.
In Patel’s situation, the consequences were immediate: once out of status, he could not attend classes and faced the possibility of removal, a chain of events the court linked to a termination process that offered no warning or chance to contest the basis for the decision.
The judge’s decision highlighted the gap between the underlying conduct and the penalty imposed, describing an action that rested on a matter that ended in dismissal rather than a finding of guilt.
The Student Criminal Alien Initiative’s use of the FBI’s NCIC database sat at the center of that process, with the screening designed to identify matches among international students and leading to SEVIS terminations even when the match involved a dismissed case.
By finding the termination arbitrary and capricious, Reyes placed the case squarely within the APA’s framework for reviewing agency decisions, and the ruling cited APA review under 5 U.S.C. § 706.
Patel’s case also fit into a developing set of legal challenges in which students sought emergency relief after losing SEVIS status based on minor or non-conviction matters.
In another Wisconsin case involving a University of Wisconsin student, US District Judge William Conley halted deportation for Krish Lal Isserdasani after a SEVIS termination tied to a non-conviction misdemeanor, citing a denial of due process.
Beyond Wisconsin, temporary restraining orders in Georgia reinstated SEVIS for 133 students—mostly Indian—after cancellations connected to programs described as “Catch and Revoke,” often based on minor issues such as traffic tickets.
Those related outcomes underscored the stakes for students whose ability to remain enrolled and legally present in the United States can turn on SEVIS status, and they reflected judicial concern about terminations that do not provide notice and an opportunity to respond.
Reyes’ decision did not create binding nationwide precedent and did not identify a circuit split or any binding precedent from the Board of Immigration Appeals.
Still, the ruling offered persuasive authority for future cases that challenge SEVIS terminations as arbitrary under the APA, particularly when the record termination rests on a minor incident or a case that ended without a conviction.
The opinion’s focus on due process and procedure also signaled that courts may scrutinize how ICE reaches a decision to end a student’s SEVIS record, not only the underlying incident that triggered the flag.
For international students and their lawyers, the case pointed to a path of legal challenge in federal court through APA claims, though the ruling also indicated that results can depend on specifics, including whether an allegation resulted in a conviction and how the agency explains its rationale.
The practical considerations highlighted by the decision included whether ICE provided notice before termination, whether a student had any chance to respond, and whether the infraction at issue was a conviction or a dismissal.
Patel’s case presented the scenario at the heart of the court’s criticism: a dismissed 2018 traffic citation, no criminal convictions, and a SEVIS termination that cut off his ability to attend classes and exposed him to removal risk.
Reyes’ rejection of the government’s mootness argument after an attempted quiet restoration also carried procedural implications, showing that restoring status after a lawsuit is filed did not automatically end the dispute in this case.
The ruling’s language about mass sweeps signaled skepticism of enforcement efforts that rely on broad screening and database matches when those matches include dismissed matters.
The case also showed how rapidly an administrative action can escalate for students: a database flag during a screening of approximately 1.3 million students, followed by a SEVIS termination without notice, and then the sudden loss of F-1 visa status in practical terms.
Patel’s lawsuit, the temporary restraining order, and the final ruling on the merits together traced a timeline that moved from abrupt termination to judicial restoration and a finding that ICE’s action violated the Administrative Procedure Act.
By ordering restoration and condemning the lack of warning or opportunity to respond, the court placed procedural safeguards at the center of what can otherwise look like a mechanical database-driven decision.
The ruling also connected that procedural failure to concrete consequences—barred classes and the risk of removal—that can follow quickly once a student falls out of status.
For students flagged in the Student Criminal Alien Initiative or similar efforts, the decision suggested that a dismissed case can still trigger serious immigration consequences if an agency treats a match as sufficient grounds to terminate SEVIS, and it showed how a court may respond when that approach lacks due process.
Reyes’ judgment in Patel v. Lyons left Patel with restored status and a court finding that ICE acted unlawfully, while also adding to a broader body of district court decisions that students have cited in pushing back against SEVIS terminations tied to minor or non-conviction records.
