DHS to maintain control of the border and guard against illegal entry, and despite clear evidence of the devastating consequences of his actions, he failed to take action to fulfill his statutory duty to control the border. According to his first Chief of the U.S. Border Patrol, Alejandro N. Mayorkas summarily rejected the multiple options to reduce the illegal entries...through proven programs and consequences provided by civil service staff at DHS. Despite clear evidence of the devastating consequences of his actions, he failed to take action to fulfill his statutory duty to control the border, in that, among other things: (1) Alejandro N. Mayorkas terminated the Migrant Protection Protocols (hereinafter referred to as MPP ). In Texas v. Biden , 20 F.4th 928 (2021), the United States Court of Appeals for the Fifth Circuit explained that [t]he district court...pointed to evidence that the termination of MPP has contributed to the current border surge ...(citing DHS’s own previous determinations that MPP had curbed the rate of illegal entries) . The district court had also pointed out that the number of enforcement encounters —that is, instances where immigration officials encounter immigrants attempting to cross the southern border without documentation—had skyrocketed since MPP’s termination . (2) Alejandro N. Mayorkas terminated contracts for border wall construction. (3) Alejandro N. Mayorkas terminated asylum cooperative agreements that would have equitably shared the burden of complying with international asylum accords. In all of this, Alejandro N. Mayorkas breached the public trust by knowingly making false statements to Congress and the American people and avoiding lawful oversight in order to obscure the devastating consequences of his willful and systemic refusal to comply with the law and carry out his statutory duties. He has also breached the public trust by willfully refusing to carry out his statutory duty to control the border and guard against illegal entry, notwithstanding the calamitous