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Every immigrant deserves a day in court and an independent review of his or her continued detention. Kazarov v. Ashcroft challenged the government's procedures for continuing to detain individuals who have been given an order of deportation, where removal cannot be effectuated.
 
The district court judge issued a decision on this case finding that an injunction was not necessary because, compelled by the lawsuit, the government had modified its practices as a result of the lawsuit, 2007 WL 647453 (N.D.Ill., Feb. 27, 2007). The Chicago District Office of U.S. Immigration and Customs Enforcement had established a special unit to conduct case reviews in a timely fashion, resulting in a dramatic reduction in the number of individuals detained after receiving final removal orders.