On June 3, 2009, Attorney General Eric Holder withdrew the decision made by the Bush Administration’s Attorney General, Michael Mukasey, to remove the right to counsel to immigrants in deportation proceedings. This law dictated that individuals facing deportation did not have a legal or constitutional right to legal representation. Therefore, immigrants who had incompetent representation could not complain or seek help if their case failed because of unfit representation. Mr. Holder has initiated procedures to reenact the previous law where individuals can reopen their cases if they were misrepresented and lost their case.