'Deporter-in-chief' Obama surpassed deportations under Trump's first term

"That is more than Trump, so why the resistance this time?" Smith asked.

From 2009 to 2012, Obama's DHS carried out approximately 3,175,696 returns and removals in his first term alone.

The Trump administration, meanwhile, carried out approximately 1,795,888 returns and removals during his first term, 1 million less than Obama's first term.

Jessica Vaughan, director of policy studies at the Center for Immigration Studies, said that there were more deportations under Obama because illegal immigration was higher.

"Why were returns and removals higher under Obama? The short answer is because there was a lot more illegal immigration under Obama and also because interior enforcement was very strong in Obama's first term," she said. "The peak of interior enforcement was the last year of Bush and the first year of Obama. And then under Obama, he's making a decision, and you can track this through certain policies that were issued, to reduce interior enforcement."

However, Vaughan also cautioned against reading too much into the DHS returns and removal numbers without understanding the context. She said that in 2012, the Obama administration started counting removals by Border Patrol the same as interior removals by ICE, further blurring the lines on what is considered a deportation.

She said there was a "certain amount of book-cooking that went on under Obama," because he "wanted to be able to tell people that enforcement was very robust, without having it actually be very robust."

"In the past, removals were typically done from the interior and returns were done by Border Patrol. But under Obama, they changed policies, and they started having the Border Patrol do some removals as a way of imposing more consequences on illegal border crossers," she said. "That spikes Obama's removal numbers. Under Bush, a third of removals were border cases and two-thirds were interior. Under Obama, it became two-thirds were border cases and only one-third were interior. So, these numbers are interesting, but they masked some important policy differences between the administrations."