The immigration court system—an executive agency that adjudicates hundreds of thousands of deportation cases every year—is experiencing profound crises of undercapacity and politicization of the adjudication process. Adjudicators in the system face extraordinary pressures to rush through cases as quickly as possible, even if that means ignoring material evidence or relying on biased heuristics to streamline proceedings.

Against this backdrop, judicial review plays an important oversight role, with courts counterbalancing the relentless need for speed by insisting on a certain minimum baseline of quality in adjudication. Courts engage in quality control by requiring agency adjudicators to exhibit reasoned decision-making—that is, to show they have considered relevant evidence in the record and to explain their reasoning. The goal is to incentivize more careful and impartial adjudication in each case in which a person’s potential banishment from the United States is at stake.

The Supreme Court gave short shrift to judicial review’s quality-control function when it held in a 2021 case called Garland v. Ming Dai that federal courts must affirm deportation orders even when the agency’s analysis is unclear. Ming Dai, which did not purport to alter existing review standards, has flown under the scholarly radar. But circuit courts are paying attention. Invoking Ming Dai, judges across the country are contending that the reasoned decision-making requirements demand too much of the agency and exceed the power of federal courts to impose.

This Article describes and defends rigorous judicial review in deportation cases, sounds the alarm about the doctrinal experimentation that Ming Dai has inspired, and catalogs what we stand to lose if the more anemic form of judicial review being auditioned in the circuits gains prominence. At a time when many are deeply concerned about the judiciary’s war with the administrative state, this Article unearths a more obscure but no less consequential judicial project that aims to endow certain segments of the federal bureaucracy with vast power to administer justice as they see fit.