Lens’ scholarship informs Second Circuit’s analysis in a high-profile immigration case.
Tuesday, December 2, 2025

Written by: Blake Etringer 

Jill Lens, the Dorothy M. Willie Professor in Excellence at the University of Iowa College of Law, was cited in a recent Second Circuit ruling in Öztürk v. Hyde.

This case is one of numerous lawsuits challenging the Trump administration’s abrupt termination of immigration visas, primarily affecting international students and workers. A Second Circuit motions panel previously denied a stay of the injunction pending appeal. The Trump administration then sought a rehearing en banc of that denial, which the Second Circuit also rejected. Lens’ scholarship was cited in the denial regarding the purposes of stays and how they differ from preliminary injunctions.