The Ninth Circuit has determined that DHS is not constitutionally required to translate a Notice to Appear into a respondent's native language in order to advise the respondent of the obligation to update her address. The petitioner argued that her in absentia removal order should be reopened because the English-language notice did not adequately advise her, in Spanish, that she had to update her address with the immigration court.
The Court rejected that argument, finding that English-language written notice can satisfy due process when it is reasonably calculated to inform the respondent of her obligations. Because the petitioner moved without updating her address, the later hearing notice mailed to her last known address was sufficient.
The full text of Urquia-Yanez v. Blanche can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/05/08/25-1136.pdf