One of the elementary schools in Chelsea has a quieter cafeteria than it did a year ago. Not overtly so—not the kind of emptiness that makes its presence known. A few more coat hooks that remain bare in the morning, a few more open seats during lunch. Almi Abeyta, the superintendent of Chelsea Public Schools, observed it. It was observed by the teachers. The remaining kids observed that their classmates had left their desks. Although statistics don’t always tell the whole story, 350 missing students in a district that is located within a two-mile radius of one of Massachusetts’s most immigrant communities tells you a lot.
This past school year, Chelsea lost 350 students, representing a 5.7% decline in enrollment. 223 of them were learning English. Approximately 25% of the students who officially left the district informed the school that they were self-deporting to another nation. One of the communities that bore the full brunt of Massachusetts’s 2025 immigration enforcement surge was Chelsea, where about 44% of the predominately Latino population was born outside the country. An ICE agent was seen in a parking lot outside one of the district’s elementary schools in October. The ICE raid in Chelsea in March 2025 was short-lived. However, budget spreadsheets and enrollment statistics are still being used to gauge its impact.
| Category | Details |
|---|---|
| Core Legal Precedent | Plyler v. Doe, 441 U.S. 202 (1982) — Supreme Court ruled 5-4 that states cannot deny undocumented children K-12 public education |
| Legal Basis | Equal Protection Clause, 14th Amendment |
| Current Threat | Coordinated state legislation designed to challenge and potentially overturn Plyler |
| States Introducing Legislation | Tennessee (House passed bill), Idaho, Ohio, Oklahoma |
| Heritage Foundation Role | Openly advocating for states to pass laws contrary to Plyler to trigger Supreme Court review |
| Prior Challenge | Alabama HB56 (2011) — 11th Circuit confirmed “chilling effect” on immigrant child enrollment; Supreme Court declined to rehear |
| Undocumented Children in U.S. Schools | Estimated 600,000 – 850,000 enrolled in K-12 |
| Massachusetts Enrollment Loss | 15,000 students lost, fall 2024 to fall 2025 (lowest enrollment in 30+ years) |
| English Learner Drop (MA) | ~7,000 fewer English learners enrolled in 2025 |
| Chelsea, MA | 350-student drop (5.7%); 223 English learners; $11M budget shortfall; $6.7M loss from enrollment alone |
| Lynn, MA | 487-student drop (3%+); $9M budget shortfall; ~150 students unaccounted for |
| Revere, MA | 4.5% enrollment drop; ELL departure rate jumped from 30-35% to 43% |
| Chelsea Superintendent | Almi Abeyta |
| Lynn Superintendent | Molly Cohen |
| New Bedford Superintendent | Andrew O’Leary |
| Undocumented Immigrant Tax Contribution (2022) | Nearly $100 billion in federal, state, and local tax revenues |
| State Funding Per Student (MA) | ~$19,000 per student |
Behind all of this, like a baseline fact that hasn’t quite settled in, are the state statistics. Between fall 2024 and fall 2025, Massachusetts public schools lost over 15,000 students, resulting in the lowest overall enrollment in more than thirty years. Since schools do not directly monitor immigration status, districts use English language learners as a rough proxy for immigrant families, which contributed significantly to that decline. Lynn’s enrollment fell by 487 students, resulting in a $9 million budget deficit. There was no forwarding district, no transfer form, and no explanation for nearly 150 of those students who just disappeared from the records. Molly Cohen, the superintendent of Lynn, stated bluntly, “We don’t know where all those students are.” She claimed that those who are still there bring their anxiety into the classroom.
Since 1982, the legal foundation for all of this has been established. The Supreme Court ruled in Plyler v. Doe, a 5-4 ruling, that states are not allowed to deny undocumented children free public K–12 education. The Equal Protection Clause of the Fourteenth Amendment serves as the foundation for the decision, which is based on a fairly straightforward moral argument: children should not be denied the fundamental opportunity to learn due to circumstances that are completely beyond their control. The Court also made a useful observation that has not faded: denying education to a sizable portion of the population would result in a permanent underclass that would be less capable of engaging in civic or economic life, at a cost to society far greater than the savings on any one school budget.
For forty-four years, that precedent has been in place. However, it is currently the target of a planned, coordinated assault. Legislation mandating that schools verify students’ immigration status at enrollment has already been passed by the Tennessee House. Oklahoma, Ohio, and Idaho are all heading in the same direction. The Heritage Foundation has made it clear that it wants states to enact legislation that contradicts Plyler in order to spark legal action that might go all the way to the current Supreme Court and set the stage for the decision to be overturned. This is clear-cut. It is a tactic that those who are pursuing it explain in simple terms.
As you watch this happen, you get the impression that something is being disassembled with unusual patience. A 44-year-old education precedent is currently being subjected to the same methodical approach that preceded Dobbs: years of state-level legislation intended to invite a specific constitutional confrontation. Plyler was decided 5–4. Such margins are not long-term safeguards, as this Court has demonstrated. In ways that would have seemed implausible five years ago, legal experts from a wide range of ideologies have identified Plyler as vulnerable following the reproductive rights ruling.
The math of finance is not abstract. When a district loses a student, the state funds associated with that student are also lost. That amounts to about $19,000 per child annually in Massachusetts. The district lost $6.7 million in state aid alone as a result of Chelsea’s 350-student enrollment decline; the superintendent estimated the overall budget deficit to be $11 million. Lynn has to deal with a $9 million shortfall. These aren’t rounding mistakes. These are the kinds of figures that force districts into structural instability that takes years to recover from, if they do at all, and eliminate teaching positions and programs.
According to New Bedford Superintendent Andrew O’Leary, the majority of Massachusetts’s economic growth over the previous 20 years can be attributed to the expansion of the state’s immigrant population. This frame is worth considering for anyone considering the implications of these enrollment figures for the long arc of the state’s economy. This expansion has directly benefited school systems. He said that disrupting it would have serious detrimental effects. That’s a composed statement from a man who carefully selects his words. Additionally, it is a fairly conservative estimate of what is already occurring when you consider the empty desks, the budget deficits, and the families who have quietly departed without telling anyone where they were going.
