In late 2021, Frankie Disintonio and Idelky Gonzalez began to see people lurking on sidewalks begging for money in the Miami suburb of Hialeah. On the handwritten signs these people held up, they noticed a request they found unusual: Please give me money for a lawyer.

They learned that these people were migrants looking for assistance to secure a legal status in the United States, and Disintonio and Gonzalez immediately thought of their immigrant parents.

"It was a reminder of just what our parents were going through when they first arrived," Disintonio, 32, the son of Ecuadorian immigrants, told Law360. "It was just kind of a reminder of what we came from."

"We saw all these people who needed help. The pastor of the church couldn't assist them," said Gonzalez, 32, who was born in Cuba and came to the U.S. with her parents at age 2. "That was a wake-up call."

Seeing firsthand how desperate immigrants were for legal help, Disintonio and Gonzalez realized they needed more than good intentions — they needed the credentials to be able to help them effectively. This realization led them to get trained in immigration law and pursue a little-known path to become "accredited representatives" — nonlawyers authorized by the federal government to represent immigrants.

"We saw a big need here in South Florida for systems like ours, and which is what would really propel us to start a nonprofit," Disintonio said. The pair launched One Wish Immigration Relief in April 2023 and underwent the accreditation process through a U.S. Department of Justice program.

Experts say the accredited representative model, which has been allowed under federal regulations since the 1950s, is not used as often as it should, considering the enormous need for legal representation immigrants face.

As of March 17, the program consisted of 939 recognized organizations and 2,791 accredited representatives providing immigration legal services across the country, according to official government data.

Laura Vazquez, the director for immigrant integration at UnidosUS, a national Latino civil rights organization that advocates for immigration policy changes and assists immigrants through programs that employ both attorneys and nonlawyers, said the model is still little-known.

"I think the potential to grow is huge, if we can have more people know about it," she said.

But just as the program has the potential to dramatically scale up the availability of legal aid to noncitizens, advocates are concerned that the Trump administration could shut it down.

The DOJ could eliminate the accreditation program either by issuing an executive directive to shut it down through regulatory changes, or by defunding the office that administers the program — the DOJ's Office of Legal Access Programs — rendering it nonfunctional.

Advocates worry that if accreditation is removed, nonlawyer representatives would be breaking the law if they continued providing legal services. Congress would have no power to reverse such executive decisions.

During Donald Trump's first term, the administration did not officially end the program but instead slowed it significantly by delaying accreditation applications. This led to longer processing times, preventing new accredited representatives from starting their work. Advocates had to push Congress to investigate delays and demand more funding for staffing to process applications.

Eréndira Rendón, the vice president of immigrant justice at The Resurrection Project, a legal nonprofit based in Chicago, said the second Trump presidency presents a greater threat.

"I'm worried about the accreditation and recognition program completely going away," she said. "They could completely defund the office."

Representatives for the White House declined to comment and deferred to the DOJ. The DOJ did not respond to requests for comment.

Rebecca L. Sandefur, a professor at Arizona State University who researches ways to improve access to legal representation, said that it's unclear what Trump's executive decisions could mean for the future of the accreditation program.

"If that office stops being functional for whatever reason," she said, "would the currently authorized entities still be able to do their work? I don't know."

How the Accreditation Process Works

The accredited representative model is not unique to immigration law. Similar models exist in Social Security disability cases, tax courts, labor and wage disputes, and unemployment claims. Experts say that these models prove that trained nonlawyer representatives can effectively handle complex legal matters with the same level of professionalism and competency as attorneys.

The DOJ administers the Recognition and Accreditation Program, which authorizes nonattorney representatives to provide immigration legal services. Organizations seeking recognition must demonstrate access to adequate knowledge and experience in immigration law and procedure.

People affiliated with recognized organizations who have demonstrated sufficient education and experience in immigration law can apply to become accredited representatives. To do so, an individual must demonstrate training and moral character.

The accreditation has a two-tiered system: partial accreditation permits nonlawyers to represent immigrants before the U.S. Department of Homeland Security, including agencies like U.S. Citizenship and Immigration Services. Full accreditation allows representatives to also appear on behalf of noncitizens in immigration courts and during appeals.

Villanova University, a private Catholic research university in Villanova, Pennsylvania, offers a specialized study curriculum to train people to become immigration justice workers.

The course, called Villanova Interdisciplinary Immigration Studies Training for Advocates, or VIISTA, is asynchronous and entirely online. It's divided into three modules, each one lasting 14 weeks. The first model prepares future advocates to work effectively with immigrants. The second covers immigration law and practice, training students to become partially accredited representatives. The third one deepens immigration law and practice knowledge, preparing students for full accreditation.

Since launching in September 2020 with an initial cohort of about 40 students, the appeal of the program, which is unique in the country, has grown. There are about 200 students enrolled in the current semester, according to the program's director, Michele Pistone.

"We're trying to create a robust new layer in the legal services ecosystem," she said. "It's a new way of looking at the practice of law."

Rendón said one of the challenges of the accredited representatives model is that there isn't a road map for how people can get accredited.

Organizations like The Resurrection Project, National Partnership for New Americans and Catholic Legal Immigration Network offer training and seminars in immigration law practice, but there isn't a checklist people can follow. Programs like VIISTA can provide the academic credentials, but aspiring accredited representatives must then find a nonprofit willing and able to hire them to receive accreditation.

"There is no one formula for how to do this," Rendón said.

To streamline the pathway to accreditation, Rendón's organization, which employs five fully accredited representatives and a half-dozen attorneys, created the Colibrí Fellowship to train nonprofit staff to become DOJ-accredited representatives.

As part of the fellowship program, members of The Resurrection Project guide aspiring representatives through the process by gathering training certificates, writing letters attesting to good moral character, and documenting legal knowledge and experience. The program also helps organizations apply for DOJ recognition by training their leadership.

The fellowship program has 26 participants in Illinois and 13 in Oregon, recruited through a partner organization called Innovation Law Lab. Nearly 80 people have graduated from the fellowship over the past three years. More than half of them are now accredited representatives working at nonprofits, Rendón said.

"We recruit from organizations across the state," she said. "It's a way for us to build capacity in the field, not just for our own legal clinic."


Nonlawyers With Skin in the Game

In 2009, nearly 20 years after she crossed the border illegally from Mexico and settled in the Denver area, Maria De Jesus Banuelos suffered an unspeakable loss. Her son, Eduardo Sanchez, was killed at age 19, leaving her heartbroken and depressed to the point that she wished she were dead.

Then, as her son's killers were being brought to justice, a criminal court judge told Banuelos she might qualify for a special U.S. visa for victims of certain crimes. But navigating the immigration system is complex and costly, and Banuelos didn't have the money to hire an attorney.

To her luck, a social worker at a local nonprofit connected Banuelos with a legal aid organization that could help her at little to no cost. Instead of an immigration attorney, Banuelos was assisted by accredited representatives employed by the San Luis Valley Immigrant Resource Center, a nonprofit based in Alamosa, Colorado.

The representatives helped Banuelos adjust her status from unauthorized immigrant to holder of a "U" visa designed for victims of crimes, and later successfully petitioned for her to receive permanent resident status, known as a green card. The representatives also connected Banuelos with a therapist to help her cope with her grief.

"I will describe them as angels on my path, the light I needed during those times," Banuelos told Law360 through an interpreter.

Banuelos, 57, is now in the process of applying for U.S. citizenship, a move that would shield her from deportation amid the Trump administration's ramped-up immigration enforcement and give her the opportunity to apply for residency permits for her aging mother and her second son, who is in the country illegally. She also said she looks forward to voting.

Carmen Stevens, an accredited representative who has assisted Banuelos since 2013, said assisting migrants who cannot afford lawyers has become her true calling.

"Especially during this administration, when we're having really tough days, I wonder if I should keep doing this immigration work," Stevens said. "Stories like Maria's remind me that I need to keep going."

Stevens went even further in her advocacy by co-founding the Colorado DOJ Accredited Representatives Network, which now comprises more than two dozen immigration justice workers from organizations across the Centennial State.

A 2001 scholarly study in the United Kingdom comparing the performance of nonlawyers and attorneys on a range of civil rights matters, including immigration, found that nonlawyers were six times more likely than lawyers to produce work that reviewers rated as excellent.

Sandefur said that the study, although dated, does suggest that properly trained nonlawyer representatives can perform as well as attorneys — if not better. That's in part because civil rights workers tend to specialize in fewer aspects of legal representation in specific fields, often learning to master them.

"They become very good at not just the substantive law, but also the people that they have to interact with, the way the forum works, what the procedures are, and so on," Sandefur said.

Another crucial factor is that the overwhelming majority of accredited representatives come from immigrant backgrounds, which makes them more culturally competent and personally invested in helping immigrants navigate the system.

Vazquez of UnidosUS said that accredited representatives are the "backbone" of the community-based legal services system.

"They have the substantive knowledge, but they also have this cultural competency and that really allows them to be, I think, excellent advocates for their clients," Vazquez said. "They know what's at stake. They know what can happen if there's a mistake made or someone has given incorrect guidance."

Stevens was born in Mexico and immigrated to the U.S. at age 10 through her father's application under President Ronald Reagan's amnesty program. She became a U.S. citizen before turning 18. Growing up in Oxnard, California, in the 1990s, Stevens was inspired to help immigrants due to her early awareness of immigration scams and notarios in nearby Los Angeles.

"I remember thinking and telling my parents, 'I want to be an immigration attorney. I want to help people,'" she said.

After moving to Alamosa to pursue a bachelor's degree in sociology, Stevens worked as a victim advocate at a domestic violence shelter, focusing on immigrant survivors. She then joined the San Luis Valley Immigrant Resource Center, became partially accredited and provided immigration legal services.

Five years later, after moving to Denver and joining the Justice and Mercy Legal Aid Center, Stevens trained in immigration court litigation and trial advocacy through the VIISTA program at Villanova. In February 2024, she applied for full DOJ accreditation to represent clients in immigration court. USCIS approved her application, and she is now waiting for the Office of Legal Access Programs to give final approval.

"We got a letter from USCIS Kansas saying they reviewed my application and have no objections," she said. "Hopefully, it will get approved."

Filling the Legal Representation Void

Growing up in South Florida, Disintonio and Gonzalez have long been aware of the needs of the immigrant community, and the perils associated with lacking an immigration status.

According to U.S. Census data, more than 80% of the population in Hialeah is made up of Cubans or Cuban-Americans, the highest percentage in any city in the United States. Nearly 40% of the people living in the city are not U.S. citizens.

Disintonio and Gonzalez kept seeing people in desperate need of lawyers and a black market of people who preyed on them.

Their surroundings were filled with immigrants who, lacking the money to hire attorneys, turned to fraudsters branding themselves as legal aides or experts, often under the term "notarios" — Spanish for notaries. These people often ended up with botched cases that led to severe immigration consequences that haunted them for years.

As a child who spoke English, Disintonio often helped his family members and acquaintances translate documents into Spanish. Growing up, he witnessed his parents' journey from arriving in the U.S. on a visa to becoming U.S. citizens and eventually casting their first votes in an election.

"There's a lot of families that come through the same things," he said. "My reasoning behind opening a nonprofit was to be able to provide that opportunity."

But neither Disintonio nor Gonzalez had a background in immigration law.

After learning about the accreditation program, he attended Villanova's VIISTA program in 2023 and met Gonzalez, who was studying as part of the same cohort. That April, they started their nonprofit and ran it out of an office space in Doral, another suburb west of Miami with a large population of people of Venezuelan descent. Disintonio said he found it ironic that his office is just a short drive from Trump's Doral resort, something he likes to joke about with his clients.

Gonzalez said opening an immigration legal aid nonprofit is "not as easy as it sounds." Aspiring accredited representatives need to spend a minimum amount of hours in court presenting cases alongside an immigration attorney, which needs to be documented and presented to the DOJ as evidence to obtain the accreditation. Finding attorneys to serve as mentors is challenging, in part because they are busy, and also because some lawyers see aspiring representatives as potential competitors.

"When we spoke to attorneys, we said, 'Look, we're not here to take clients away from you. On the contrary, what we want to do is, those clients that could come and approach you but cannot afford you, please refer them to us and we can assist them,'" Disintonio said.

One Wish Immigration Relief, which since receiving its DOJ recognition in January 2024 has assisted more than 1,000 people, does not receive federal funding and relies on small donations and a fee-for-service model, meaning that clients only pay for a specific transaction.

Fees are much lower than private attorneys. For instance, the nonprofit charges $80 for a work permit application, $320 for a green card application, and $380 to file an asylum case. To complete an asylum application and represent a client in person during an asylum interview at the USCIS office, it charges $1,500. One Wish Immigration Relief employs an immigration attorney who can represent clients in court while Disintonio and Gonzalez work on getting their full accreditation.

"Our cost is very, very, very low compared to attorneys out there," Gonzalez said.

Scaling Up Potential of the Accredited Reps Model

Trump promised the largest deportation campaign in the country's history, part of a broader crackdown on immigration that has involved highly publicized arrests and deportations, deployment of the military at the southern border, suspension of asylum, and attacks on birthright citizenship, among other things.

Official government data published at the end of February show the number of noncitizens detained by U.S. Immigration and Customs Enforcement reached 44,000, the highest level since November 2019.

According to the Transactional Records Access Clearinghouse, a research institution based at Syracuse University tracking official data, about 52% of people held in ICE detention have no criminal records.

Rendón said The Resurrection Project has witnessed an increase in enforcement, including specifically an increase in deportations and arrests.

"For us, it's mainly been a scramble to be able to increase our capacity for deportation defense, and so we've been focused on training a lot of attorneys on that, and training our fully accredited reps for it," she said.

There are nearly 3.7 million people currently facing deportation proceedings in the country. About 75% of them are unrepresented. Experts say the lack of representation is consistent in other portions of the immigrant population, not just people actively facing deportation.

Sandefur said that if the Trump administration moves forward with aggressive enforcement using the immigration court process, the need for legal representation could grow even more rapidly.

The accredited representatives program, which she says is underutilized, could greatly expand the capacity to represent immigrants.

"What's important for people to understand is that there are already not enough attorneys assisting these folks. There already is an enormous need," she said. "One of the great things about the accredited rep model is that it is scalable."

Creating a pipeline for accredited representatives is cheaper and faster than it is for lawyers. Unlike attorneys, Sandefur said, accredited representatives do not require years of education or massive student debt.

"We can train people to be very effective at a precise part of legal work," she said. "And that's a much easier proposition."

Rendón noted that nonprofits often struggle with funding, which limits their ability to hire and train accredited representatives.

With an administration now bent on slashing DOJ programs catering to noncitizens — for instance, representation for unaccompanied minors and help desks inside immigration court buildings — Rendón said efforts by state and local governments to secure funding for legal nonprofits as part of their budgets are all the more crucial.

As large metropolitan areas and populous states have created funding streams for legal aid, accredited representatives have received increased attention as a working solution to the lack of legal representation in the nation.

"There's been a large movement to get more public funding in this field. And as that has happened, there's been a recognition that we're not going to have enough attorneys," she said. "We should be getting more people to become accredited."

--Editing by Orlando Lorenzo.

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