In a July 23 memo titled “ Terminology,” Acting Director of the Executive Office for Immigration Review (EOIR) Jean King directed immigration judges to instead use terms like “undocumented noncitizen” and “undocumented individual.” King also directed judges to stop using the term “unaccompanied alien child” to describe unaccompanied alien children, directing them to use terms like “unaccompanied non-citizen child” and “unaccompanied non-U.S. citizen child.” The memo references a pair of President Joe Biden’s executive orders and notes that neither uses the term “alien” or “illegal alien” to describe illegal aliens. It also points to two recent Supreme Court opinions in which the justices opted to substitute the term “noncitizen” for the statutory term “alien.”