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Fifth Circuit Finds that Equitable Tolling does not Apply to Numerical Limitations on Motions to Reopen


October 3, 2025
by Sabrina Damast

The Fifth Circuit has rejected the proposition that number bars are subject to equitable tolling. The Court did concede that the numerical bar is a claims processing rule and not a jurisdictional bar.

The full text of Garcia Morin v. Bondi can be found here: https://www.ca5.uscourts.gov/opinions/pub/24/24-60590-CV0.pdf

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Posted in New Case Law
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tagged with Fifth Circuit, motion to reopen, numerical limitation, equitable tolling
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