Court Rules
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Enforcement ActionLow RiskMultistate

States Sue Trump Admin Over Unlawful $100K H-1B Visa Fee

U.S. Department of Homeland SecurityDecember 12, 2025Oregon Attorney General

Summary

Other enforcement action: Oregon Attorney General Dan Rayfield, joined by 18 other states, sued the Trump Administration over its unlawful $100,000 fee for H-1B visa petitions. The lawsuit alleges that the policy violates the Administrative Procedure Act by exceeding congressional authority and bypassing required rulemaking procedures, harming educational institutions and employers.

Remedy

The lawsuit seeks an injunction to prevent the enforcement of the $100,000 fee policy and to declare it unlawful.

Injunction

Contract Impact

In-house legal teams should review employment agreements, independent contractor contracts, and vendor agreements that involve H-1B visa sponsorships or foreign worker hires. Focus on clauses addressing visa application fees, cost allocation for immigration processes, compliance with government regulations, and provisions for handling fee changes or new governmental impositions. Specifically, examine terms related to fee burden sharing, regulatory adjustment mechanisms, and adherence to administrative procedures like the Administrative Procedure Act. Potential changes may include amending contracts to clarify responsibility for new fees such as the $100,000 H-1B petition fee, incorporating clauses that allow for fee adjustments due to regulatory changes, and ensuring alignment with congressional intent to avoid violations.

Contract Search Terms

H-1B visa fee clauseimmigration compliance provisiongovernment fee pass-throughregulatory change impact clauseemployment visa sponsorship agreementfee reimbursement mechanismadministrative procedure compliancevisa petition cost allocation

Laws Cited

Administrative Procedure Act

Violation Types

Entity Details

Entity

U.S. Department of Homeland Security

Also known as: Department of Homeland Security

Industry

Other

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"implemented by the Department of Homeland Security (DHS)"
Laws Cited
"Administrative Procedure Act (APA)"
Summary
"imposes a massive fee outside of the bounds of what is authorized by Congress"

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