the separation of powers in the Constitution of the United States, it also threatens our national security and has had a dire impact on communities across the country. Despite clear evidence that his willful and systemic refusal to comply with the law has significantly contributed to unprecedented levels of illegal entrants, the increased control of the Southwest border by drug cartels, and the imposition of enormous costs on States and localities affected by the influx of aliens, Alejandro N. Mayorkas has continued in his refusal to comply with the law, and thereby acted to the grave detriment of the interests of the United States. Alejandro N. Mayorkas engaged in this scheme or course of conduct through the following means: (1) Alejandro N. Mayorkas willfully refused to comply with the detention mandate set forth in section 235(b)(2)(A) of the Immigration and Nationality Act, requiring that all applicants for admission who are not clearly and beyond a doubt entitled to be admitted...shall be detained for a [removal] proceeding... . Instead of complying with this requirement, Alejandro N. Mayorkas implemented a catch and release scheme, whereby such aliens are unlawfully released, even without effective mechanisms to ensure appearances before the immigration courts for removal proceedings or to ensure removal in the case of aliens ordered removed. (2) Alejandro N. Mayorkas willfully refused to comply with the detention mandate set forth in section 235(b)(1)(B)(ii) of such Act, requiring that an alien who is placed into expedited removal proceedings and determined to have a credible fear of persecution shall be detained for further consideration of the application for asylum . Instead of complying with this requirement, Alejandro N. Mayorkas implemented a catch and release scheme, whereby such aliens are unlawfully released, even without effective mechanisms to ensure appearances before the immigration courts for removal proceedings or to ensure removal in the case of aliens ordered removed. (3) Alejandro N.