JEFF SESSIONS WON’T LIKE THIS: 11th Cir. Says It Won’t “Rubber Stamp” BIA (Unfortunately Unpublished)!

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ALFREDO MARQUEZ-MARTINEZ v. U.S. ATTORNEY GENERAL, 11th Cir., 10-17-18, Per Curiam, Unpublished

KEY QUOTE:

When reviewing an agency decision for abuse of discretion, we evaluate whether the agency’s exercise of its discretion was arbitrary or capricious. Abdi v. U.S. Att’y Gen., 430 F.3d 1148, 1149 (11th Cir. 2005), overruled on other grounds by Avila-Santoyo v. U.S. Att’y Gen., 713 F.3d 1357 (11th Cir. 2013). The arbitrary- and-capricious standard is “exceedingly deferential”—we are not authorized to substitute our judgment for an agency’s so long as its conclusions are rational. Miccosukee Tribe of Indians v. United States, 566 F.3d 1257, 1264 (11th Cir. 2009) (citations omitted).

That being said, we may nonetheless find an agency action arbitrary and capricious where an agency has “relied on factors which Congress has not intended it to consider, entirely failed to consider an important aspect of the problem, offered an explanation for its decision that runs counter to the evidence before the agency, or is so implausible that it could not be ascribed to a difference in view or the product of agency expertise.” Id. (citing Ala.–Tombigbee Rivers Coal. v. Kempthorne, 477 F.3d 1250, 1254 (11th Cir. 2007)).

Here, Marquez-Martinez has demonstrated that the denial of his motion to reopen was arbitrary and capricious. As indicated by the BIA, the IJ’s decision rested solely on two “negative” grounds: (1) Marquez-Martinez’s delay in filing the motion to reopen and (2) Marquez-Martinez’s prior relationships. Neither the IJ nor the BIA, however, provided any reason why these factors counted against Marquez-Martinez—indeed, the IJ explicitly discounted the only reason for which either factor could support a denial of Marquez-Martinez’s motion.
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Recently, Jeff Sessions has made it clear that he wants everyone to know just how deeply, deeply offended and totally outraged he is that Federal Judges (unlike his captive “Immigration Judges”) have, on some occasions, had the absolute audacity to insist that he and the Trump Administration comply with the law. Normally, the 11th Circuit is pretty willing to “go along to get along” with whatever the Government wants to do to migrants. So, you know that the BIA and Sessions were totally out of control for the court to assert itself in this manner, even in an unpublished case.
Obviously, Trump and his GOP buddies like McConnell are counting on appointing lots of wimpy right-wing judges who will be loath to intervene to stop the Government from pillaging the individual rights of ordinary Americans for the benefit of rich GOP “fat cats” and religious and social extremists. It will be interesting to see what these judges do if and when the Government again becomes controlled by Democrats who want to act in the overall public interest, rather than just protecting White privilege.
Stay tuned!
PWS
10-18-18