The Dilley Pro Bono Project (DPBP) — a collaboration between the American Immigration Council (Council), the American Immigration Lawyers Association (AILA), the Catholic Legal Immigration Network, Inc. (CLINIC), and the Texas Rio Grande Legal Aid, Inc. — files this complaint on behalf of immigrant children currently and formerly detained in the custody of U.S. Customs and Border Protection (CBP) at the U.S.-Mexico border. This complaint documents the government’s systematic failure to provide adequate medical care to children in CBP custody in violation of CBP’s own internal guidance and extensive medical guidelines.