These summaries are not intended as legal advice. Please contact a licensed attorney to discuss the specifics of your case.
The Board of Immigration Appeals has determined that a non-citizen who cooperated with United States law enforcement against a cartel did not demonstrate a clear probability of torture because his fear was based on unsubstantiated statements from a coconspirator and generalized evidence of cartel violence.
The full text of Matter of J-C-A-G- can be found here: https://www.justice.gov/eoir/media/1420746/dl?inline
The Board of Immigration Appeals has reversed a grant of protection under the Convention Against Torture to a Haitian applicant, finding that “anecdotal reports” (i.e., expert testimony) of Haitian prison guards taking bribes to withhold torture is not sufficient to show that it is more likely than not that the respondent himself will be tortured.
The full text of Matter of W-F- can be found here: https://www.justice.gov/eoir/media/1420631/dl?inline
The Board of Immigration Appeals has determined that the statutory provision permitting the Attorney General to waive the 1-year time limitation on one motion to reopen pursuant to VAWA does not provide for a waiver of the numerical limitation on a second motion to reopen pursuant to VAWA.
The full text of Matter of B-S-H- can be found here: https://www.justice.gov/eoir/media/1418881/dl?inline
The Board of Immigration Appeals has determined that a single attempt to report an incident of harm by private actors to local police, without further harm from the police themselves or evidence of their widespread collusion with alleged persecutors, does not establish that the government, as a whole, is unable or unwilling to protect a respondent from persecution.
The full text of Matter of K-S-H- can be found here: https://www.justice.gov/eoir/media/1417811/dl?inline
The Tenth Circuit has upheld the agency’s negative good moral character determination for an individual convicted of a recidivist DUI offense within the 10 year good moral character, even though the three prior convictions that made him a recidivist were from 20 years prior. “The BIA and IJ treated Petitioner’s 2017 DUI conviction so seriously because it was his fourth such conviction. In doing so, the BIA and IJ were not reflecting on what Petitioner’s moral character had been back in 1995 or 1996. Rather, they were saying that his moral character was bad in 2017 because he was unable to keep himself from repeating serious misconduct for which he had been convicted.”
The full text of Luna-Corona v. Bondi can be found here: https://www.ca10.uscourts.gov/sites/ca10/files/opinions/010111337652.pdf
The Ninth Circuit has denied the Department of Justice’s motion to dismiss a pro se petition for review that misstated the date of the agency decision and failed to include the decision with the petition. “Here, the imperfections in Kazarian’s petition did not deprive the government of sufficient notice of his claim or prejudice the government. Even though Kazarian misstated the date of the challenged order as ‘07/16/25’ rather than ‘06/17/25,’ and he did not attach a copy of that order, as § 1252(c) requires, his petition and accompanying stay motion make clear that he seeks review of the BIA’s June 17, 2025, decision upholding his removal order. The government had no trouble finding that ruling and filing it on the docket.”
The full text of Kazarian v. Bondi can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2025/11/18/25-4427.pdf
The Ninth Circuit has reaffirmed that it has jurisdiction to review whether changed circumstances excuse the late filing of an asylum application. The Court also affirmed the denial of an administrative closure motion because the applicant had multiple DUI convictions, which weighed against a grant of discretion.
The full text of Ruiz v. Bondi can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2025/12/22/23-1095.pdf
The Seventh Circuit appears to have rejected the agency’s determination that any individual who entered without inspection is subject to mandatory detention under 8 USC 1225.
“The question is whether § 1225(b)(2)(A) covers any noncitizen who is unlawfully already in the United States as well as those who present themselves at its borders. For their part, Plaintiffs highlight a host of cases where courts have held that ICE’s authority to detain a noncitizen discovered within the country derives from § 1226(a) and not from § 1225(b). Based upon the text and structure of the two provisions, we believe that Plaintiffs have the better argument on the current record.”
The court did note that its decision was based on a preliminary record, leaving open the possibility that the government could better develop the record to support its argument.
The full text of Castanon-Nava v. Department of Homeland Security can be found here: https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2025/D12-11/C:25-3050:J:Lee:aut:T:op:N:3465102:S:0
The Sixth Circuit has determined that a Kentucky conviction for first-degree burglary is not a crime of violence because it encompasses flight from a scene while armed, which does not necessarily involve the threat of physical force against others.
The full text of United States v. Reed can be found here: https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0357p-06.pdf
The Sixth Circuit has determined that even with the demise of Chevron deference and the extension of federal court jurisdiction as laid out in Wilikinson, it still does not have jurisdiction to review the denial of a sua sponte motion to reopen.
The full text of Herrera v. Bondi can be found here: https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0338p-06.pdf
The Sixth Circuit has determined that it lacks jurisdiction to review if an asylum applicant has demonstrated extraordinary circumstances related to the delay in filing his asylum application.
The full text of Osabas-Rivera v. Bondi can be found here: https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0332p-06.pdf
The Sixth Circuit has reversed the denial of an appeal for failure to file a brief, when the non-citizen did timely file a brief, but it contained an address for her attorney that was different than was provided on the Notice of Appearance. “[N]othing in the BIA Practice Manual, notice of appeal form, or regulations say that this address needed to match the address provided on the attorney’s notice of appearance or that failing to do so might result in rejection of the brief.”
The full text of Pineda-Guerra v. Bondi can be found here: https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0329p-06.pdf
The Sixth Circuit has rejected “Salvadoran women” as a cognizable particular social group for asylum and withholding of removal purposes, finding the group because it encompasses “women across varied social, economic, religious, and cultural backgrounds.”
The full text of Cristales-de Linares v. Bondi can be found here:
https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0326p-06.pdf
The Sixth Circuit has determined that it has jurisdiction to review whether a VAWA self-petitioner has established extraordinary circumstances or extreme hardship to the applicant’s child, as required for a motion to reopen.
The full text of Sarkisov v. Bondi can be found here: https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0316p-06.pdf
The Sixth Circuit has determined that when a child is under 21 at the time an Immigration Judge grants cancellation of removal for nonlawful permanent residents, but ages out during the pendency on appeal filed by DHS, the child’s age remains the same as it was on the date of the judge’s decision. It appears this applicant was detained at the time of the cancellation grant, and thus, was not subject to the visa backlog for most cancellation applicants. As such, it is unclear what would happen if the child was under 21 on the day of the merits hearing, and the judge put the applicant in the queue for a cancellation number, and the child aged out before the number was issued.
The full text of Perez-Perez v. Bondi can be found here:
https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0315p-06.pdf
The Fifth Circuit has concluded that the certification requirements in 8 U.S.C. § 1229a(c)(3)(C) are not mandatory and has also determined that a Texas Conviction for indecency with a child - sexual contact is a crime of child abuse.
The full text of Campuzano v. Bondi can be found here: https://www.ca5.uscourts.gov/opinions/pub/24/24-60575-CV0.pdf
The Fifth Circuit dismissed an untimely petition for review finding that the government did not waive the claims processing rule violation because it filed a motion to dismiss one week after the petition was filed.
The full text of Liao v. Bondi can be found here: https://www.ca5.uscourts.gov/opinions/pub/25/25-60427-CV0.pdf
The Fifth Circuit has determined that a New Mexico conviction for child endangerment is a crime of child abuse, rejecting the petitioner’s argument that the statute encompasses permitting a child to be briefly exposed to inclement weather.
The full text of Silva de Santiago v. Bondi can be found here: https://www.ca5.uscourts.gov/opinions/pub/25/25-60064-CV0.pdf
The Fifth Circuit has determined that a federal conviction for influencing a federal official by threatening assault is a crime of violence because it involves threats of physical force.
The full text of McLean v. Bondi can be found here: https://www.ca5.uscourts.gov/opinions/pub/20/20-61098-CV0.pdf
The Fourth Circuit has remanded a Honduran applicant’s asylum claim, finding that the agency erroneously relied on evidence of token actions by law enforcement to find that the government was willing to control the persecutors.
The full text of Ramos Marquez v. Bondi can be found here: https://www.govinfo.gov/content/pkg/USCOURTS-ca4-24-01842/pdf/USCOURTS-ca4-24-01842-0.pdf
