Zach Samalin

Dear Ms. Wolfe, Petitioner-Appellee Rümeysa Öztürk submits this Rule 28(j) letter to advise the Court that on January 29, 2026, the immigration court held that the Department of Homeland Security had not met its burden of proving removability, and the immigration court thereby terminated removal proceedings against Ms. Öztürk.' This development underscores the dangers of the government's interpretation of the Immigration and Nationality Act. Under the government's view, it could punitively detain any noncitizen in retaliation for her speech for many months, so long as it simultaneously institutes removal proceedings—no matter how unmeritorious—all without any federal court review of the lawfulness of detention at any time. To be clear, the termination of Ms. Öztürk's removal proceedings does not moot her habeas case. (By contrast, as Ms. Öztürk has argued, this appeal is moot. Br. 18-20.) Without habeas jurisdiction and the bail order that is currently in place, any government appeal to the Board of Immigration Appeals would again subject Ms. Öztürk to re-detention. See 8 C.F.R. § 1003.6(a). For that reason, she continues to suffer the threat of continuing "now-or-never" First and Fifth Amendment harms. Br. in Opp. 55-57.

NEW: An immigration court has terminated removal proceedings against Tufts doctoral student Rümeysa Öztürk, finding that DHS did not meet its burden of establishing that she was removable, her lawyers tell the Second Circuit. live-awp-vermont.pantheonsite.io/app/uploads/...

Just filed: @knightcolumbia.org brief asking the Eleventh Circuit to reverse Judge Cannon and release Jack Smith’s Mar-Lago report. knightcolumbia.org/documents/v4...

Read this fantastic roundtable that @andyhines.bsky.social put together featuring faves Vineeta Singh, Annie McClanahan, Dan Nemser, and Rana Jaleel. The possibility of the university lives!

Defending the Possibility of the University: A Roundtable on “University Keywords” - Public Books “What would it look like for faculty unions and graduate student unions to collaborate or work together with K-12 teachers’ unions to push back against anti-DEI legislation or book bans?”

For our roundtable on “University Keywords,” Dan Nemser offers “revenue” and highlights four flows: 1) state appropriations; 2) tuition and housing; 3) research funding (whether public or private); and 4) distributions from endowments and gifts.

NYU ‘Falls Flat’ Without Us: More than 900 NYU Professors to Vote on Strike Authorization — Work-Bites By Steve Wishnia Fifteen months after they began talks for their first union contract, more than 900 professors at New York University will begin voting on whether to authorize a strike on Monday, F...

"Fifteen months after they began talks for their first union contract, more than 900 professors at New York University will begin voting on whether to authorize a strike on Monday, Feb. 9."

@uawregion9a.bsky.social

www.work-bites.com/view-all/nyu...

Olfactory Arts in a Warming World A public lecture by Silke Felber on "Olfactory Arts in a Warming World," and a conversation between Felber, Zachary Samalin & Brandon Woolf

Please mark your calendars for 2/24 at 6 PM when we present "Olfactory Arts in a Warming World," a public lecture by Silke Felber, followed by a conversation among Felber, @zachsamalin.bsky.social, and moderator Brandon Woolf. More details and RSVP info here: www.eventbrite.com/e/olfactory-...

For all the fearmongering about capital flight from New York City, there’s an exodus few want to talk about: working people.

Sky-high rents and outrageous child care costs are already pushing families out of the city they keep running.
 
That’s what we have to change.

Proposed Order to Judge – #17 in State of Minnesota v. Noem (D. Minnesota, 0:26-cv-00190) – CourtListener.com PROPOSED ORDER TO JUDGE re 5 MOTION for Temporary Restraining Order filed by City of Minneapolis, City of St. Paul, State of Minnesota.(Carter, Brian) (Entered: 01/12/2026)

I’ll try to live-blog for @lawfaremedia.org the TRO/preliminary injunction hearing in MN v. Noem this morning at 10am ET/ 9am CT. MN seeks to pause, reduce, or restrict DHS’s Operation Metro Surge, citing the 10th Amendment. Relief sought is below:
/1
storage.courtlistener.com/recap/gov.us...

A doctor who witnessed the shooting submits a sworn declaration in federal litigation to halt ICE surge in MN:

"I did not see him attack the agents or brandish a weapon of any kind."

and

"The victim had at least three bullet wounds in his back."

Read storage.courtlistener.com/recap/gov.us...

Pam Bondi just sent a letter to Minnesota officials saying ICE will leave if the state turns over its voter database to Trump.

Guess what? This has never been about safety or immigration. It’s a pretext for Trump to take over elections in swing states.

You have to read this. Firsthand affidavit from one of the women who was there and recording the video. She talks about how Alex Pretti was directing traffic when she arrived. She watched him be killed in front of her. She's afraid to go home, worried she'll be arrested.

D.H.S. Cited Foreign Students’ Writings and Protests Before Their Arrests

“The docs indicate that.. the arrests of the students were recommended based on their involvement in campus protests and public writings, activities that the Trump administration routinely equated to antisemitic hate speech and support for terrorist organizations.”

www.nytimes.com/2026/01/22/u...

Judge Young's final "annotated order" in AAUP v. Rubio, just issued. A huge First Amendment victory. Very proud of my colleagues @ramyakrishnan.bsky.social @alexabdo.bsky.social @georgewang.bsky.social & grateful to our clients @aaup.org @mesa1966.bsky.social. knightcolumbia.org/documents/k4...

There was some catchphrase around 1848…something like ‘everything stable dissolves into liquid’…can’t quite remember who said it…

This is next week!

ICE OUT FOR GOOD Friday January 23 4pm Union Square Solidarity with Minneapolis March on ICE profiteers (Amazon, Home Depot, Palantir) Sponsored by many different unions

(If you don't know, the *BIG* NYC protest against ICE is Friday at 4pm in Union Square, here's the flyer, please come, and let me know if you'd like to meet up. I'll be with a 3-year-old trying to find a spot that's high-energy, high-chanting, relatively-low-noise)

Chokehold: Donald Trump’s War on Free Speech & the Need for Systemic Resistance This Free Press report examines the Trump administration’s hostile relationship with dissent and free expression in 2025. It analyzes how Trump and his political enablers have sought to undermine and ...

I've been tracking Trump's attacks on the First Amendment -- & the broader federal govt ethos of retaliation -- all year. I've seen roughly 200 incidents of attacks on dissent & free speech, w/ particular aggression towards press, protesters, public servants: www.freepress.net/attack-on-fr...

On only hours notice, hundreds of New Yorkers are gathering in Foley Square to protest the murder of Renee Nicole Good

Definitely worth reading! I'm doing a similar research project about 1950s firings at NYU -- we'll have an exhibition in the fall, will keep you posted!

His whole testimony was fire. This recent report about CUNY and McCarthyism is really good: academicworks.cuny.edu/cgi/viewcont...

"Many colleges now make policies, syllabi...with an eye on what congressional committees may think...I warn you gentlemen, there are some shocking things in Plato and the Bible." -- Prof. Oscar Schaftel (Queens College), 1952, before the McCarran Committee

Don’t forget the various voids and vortexes where our essays have disappeared

“Written it? I haven’t even published it”

(updates “read it? I haven’t even taught it”)

When I went to college a hundred years ago (2000-4), my school was actively recruiting humanities majors, w scholarships etc. Institutions incentivize areas of study in order to grow them. And they underfund them intentionally to strangle them. It’s not a random natural phenomenon.

Calling all students, parents, and friends of the New School! Send the Board a letter TODAY - the deadline for us to enroll in voluntary separation and early retirement approaches!

Tell them to stop the cuts and chop from the top!

To send a quick letter go to linktr.ee/aauptns

AAUP-TNS explains how the New School is vanguard in its approach to cuts, but its a model that will be rolled out elsewhere. Our fight is your fight!

Solidarity is the only way forward, and no data or consultant can control or manipulate it.

Join our struggle today: linktr.ee/aauptns

Stop the Cuts at the New School The restructuring proposed by the New School’s upper administration will harm faculty, students and the larger New School community. Faculty and staff—who have given decades of their lives to the un...

Thank you @bradlander.bsky.social!
Please take two minutes and join our letter writing campaign, demanding the Board of Trustees take immediate action to STOP the MAGA-inspired violent austerity at The New School: actionnetwork.org/letters/stop...

The New School is a beacon of higher education thanks to the labor of its faculty & staff. 

I strongly urge @thenewschool.bsky.social to extend the deadline for faculty to consider separation packages, engage in good faith & protect the programs that make New School a globally renowned institution.

Higher ed workers at The New School are rejecting the admin's strategies of divide and conquer to mount a unified challenge to austerity.

In this AAUP TV episode, Laura Liu of AAUP-TNS talks about how faculty, students & staff come together despite weaponized employment contracts that divide them.

Democracy Now! is looking for early-career journalists to join our team as one-year fellows in the video and digital departments. All fellowships are paid, full-time positions with benefits. More details at democracynow.org/jobs