The Biden administration suffered a legal blow when a federal judge on Friday struck down guidelines meant to limit the number of illegal immigrants that can be arrested or deported.

U.S. District Court Judge Drew Tipton declared the directive, issued in September, to be unlawful.

Homeland Security (DHS) Secretary Alejandro Mayorkas issued a memorandum to Immigration and Customs Enforcement (ICE) limiting arrests and deportations to those posing a threat to national security and public safety or who had more recently crossed the border.

The Mayorkas memo refers to illegal immigrants as “undocumented noncitizens.”