By: Mary Leniton

View/Download PDF Version: What Happened to Liam? The Detention of Immigrant Youth (Leniton)

The image of a five-year-old Minnesotan boy standing teary-eyed before federal agents in a blue bunny-eared cap is ingrained in the public’s mind. United States Immigration and Customs Enforcement (ICE) took the boy from a running car. ICE agents then had Liam Conejo Ramos, in his blue cap, knock on the door of his family’s home in an attempt to lure Liam’s family outside. Immigration officers “essentially us[ed] a [five]-year-old as bait.”

A Living Hell

What happens to detained children like Liam? The South Texas Family Residential Center in Dilley, Texas, where the United States Department of Human Services sent Liam, has a troubled history of prison-like conditions and excessive detention periods. Described as a “living hell,” parents struggle to get water to mix formula for babies, food contains bugs and debris, and children are malnourished and extremely ill. Court filings describe a child being told to report for medical care only if they vomited eight times. Children suffer from severe psychological stress, with parents reporting children hitting and wetting themselves.

CoreCivic runs the South Texas Family Residential Center. Formerly Corrections Corporation of America, CoreCivic is a for-profit prison company that has shifted towards immigration detention with the United States Immigration and Customs Enforcement (ICE) as its largest customer. In 2021, the Biden administration closed the facility’s doors. The Trump administration reopened its doors in 2025.

The new administration has enforced an alarming detention strategy geared towards facilitating the deportation of children and parents. After the Trump administration reinitiated family detention, over 1,300 children have been held for longer than the legal limit of 20 days by December 2025.  The administration is holding families for extended periods with the aim of deporting them straight from detention and to pressure self-deportation.

This is not the Trump administration’s first instance of egregious treatment of families. During President Trump’s first term in office, the administration implemented its “zero tolerance” policy that resulted in at least 2, 737 family separations. The policy called for prosecuting all immigrants who unlawfully crossed into the United States and then separating children from parents subject to these prosecutions. The policy aimed at deterring immigration by weaponizing family separation. Like Liam, children under President Trump’s first term became a tool to induce fear.

The Flores Settlement

The Trump administration’s family separation policy did not prove invincible. In Ms. L. v. U.S. Immigration and Customs Enforcement, the United States District Court for the Southern District of California issued a preliminary injunction requiring reunification of families, holding that the “zero tolerance” policy violated due process rights. Specifically, the government could not remove children from their parents without the parents being determined unfit by an immigration judge.

Another legal challenge loomed in the background of Trump’s “zero tolerance” detention strategy. In 1997, the federal government settled a class action on behalf of immigrant youth requiring detained children to be housed in facilities meeting certain standards. Flores led to the 20-day limit for holding children and established other protections. The settlement requires children’s prompt release from facilities and placement in the least restrictive facilities. Additionally, the federal government must ensure facilities are safe and sanitary and licensed to care for children. The facilities are also required to provide access to drinking water and food, as well as medical assistance. Further, facilities cannot place children with unrelated adults for more than 24 hours. The settlement also included a policy in favor of family reunification and access to education.

Following Ms. L, in 2019, the Trump administration sought to eliminate the 20-day limit on detaining children and alter licensure requirements by replacing the long-established Flores settlement. These efforts proved unsuccessful, and the district court overseeing the Flores settlement denied the motion to terminate, and the Ninth Circuit upheld the denial. Although problematic “zero tolerance” policies continued through arbitrary determinations of unfitness in immigration court.

Flores is under attack again, under President Trump’s second term. On May 22, 2025, the administration moved to terminate the Flores settlement. The government argued that changed circumstances, Supreme Court precedent against long-term decrees and federal district courts issuing class wide injunctive relief for detainees, equity and public interest considerations, and laws governing judicial review of orders of removal called for ending the settlement. The district court judge who had overseen the Flores settlement denied the motion to terminate. The Trump administration appealed to the Ninth Circuit on December 22, 2025.

The government’s appeal repeats old arguments rejected by the Ninth Circuit in 2020. Chief Legal Counsel at Children’s Rights, co-counsel opposing the government’s motion, Leecia Welch states, “[a]t a time when the government seeks free rein to rip children from our communities and detain them indefinitely in prison-like settings, there could not be more at stake than this latest attempt to end Flores.” The end of Flores would mark the collapse of key safeguards for immigrant youth. The settlement is sometimes the sole tool for protecting children like Liam, who are locked away in a living hell.

A judge ordered Liam Conejo Ramos’s release with a scathing opinion: “[o]bserving human behavior confirms that for some among us, the perfidious lust for unbridled power and the imposition of cruelty in its quest know no bounds and are bereft of human decency.” Back home in Minnesota, Liam wakes up screaming for his father.