Judge Michelle Friedland – immigrationcourtside.com

☠️ DERELICTION OF DUTY! — 9TH CIRCUIT JUDGES RIP BIA’S TOXIC “DEPORT AT ANY COST” CULTURE — “The Government’s duty should be to seek justice, not to deport people at any cost. In my view, it lost sight of that duty here.”

Kangaroos — Some Article III Judges recognize that “deport at any cost” at EOIR is a “bad look” for American justice!
https://www.flickr.com/photos/rasputin243/
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In this case, involving a woman and her two children, EOIR engaged in “Aimless Docket Reshuffling” by unilaterally moving the respondents hearing to an earlier date — arguably a due process denial in and of itself given the coordination and preparation necessary to competently present merits cases in Immigration Court. Then, EOIR failed to give legally sufficient notice of the arbitrarily accelerated hearing — a common occurrence in this dysfunctional and poorly administered system, as most practitioners would tell you.

Indeed, the defective notice was returned to EOIR, so the IJ knew that the respondent was never properly notified of the hearing. Nevertheless, ICE improperly moved for an in absentia order and the the IJ erroneously granted it.

Upon learning of the illegal “in absentia” order entered against her, the respondent promptly moved to reopen, providing unrebutted evidence of non-receipt of notice. The IJ erroneously denied the motion.

On appeal, the BIA compounded this farce by wrongfully affirming the IJ’s clearly wrong decision. Instead of confessing error, OIL advanced frivolous arguments for dismissal, falsely claiming dilatory action by the respondent, even though there is no “time bar” on a motion to reopen for defective notice.

The Ninth Circuit summarily reversed in an (unfortunately) unpublished decision. Circuit Judges Friedland and Paez, obviously and justifiably upset by this totally preventable travesty, were motivated to enter a separate concurring opinion commenting on the unprofessional “clown show” 🤡 operating at EOIR:

FRIEDLAND, Circuit Judge, with whom Circuit Judge PAEZ joins, concurring:

When the date of a removal hearing changes, the Government is required to provide a Notice of Hearing (“NOH”) containing the new date and time. 8 U.S.C. § 1229(a)(2)(A). If a person fails to appear for her hearing, she shall be removed in absentia only “if the Service establishes by clear, unequivocal, and convincing evidence that the written notice [of the hearing] was so provided.” Id. § 1229a(b)(5)(A).

Here, when Ontiveros Lozano’s removal hearing date was moved up, the Government mailed her an NOH, but it was returned as undeliverable over a month before her scheduled hearing. Ontiveros Lozano therefore indisputably did not receive the required notice, and the Government knew this. Yet the Government requested and received an in absentia removal order against Ontiveros Lozano when she did not appear for her scheduled hearing. In doing so, the Government violated the explicit statutory requirement in § 1229a(b)(5)(A).

The Government now argues that Ontiveros Lozano’s removal proceedings should not be reopened because she was not diligent in discovering the Government’s conduct and because she has forfeited her challenge to the entry of the in absentia removal order.

The Government’s duty should be to seek justice, not to deport people at any cost. In my view, it lost sight of that duty here.

Read the full opinion here:

9th Cir Absentia set aside

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The full ugliness and dysfunction of EOIR and the DOJ are on display here:

Aimless Docket Reshuffling in action;
Defective notice;
Violation of statutory requirements;
Defective administration of justice;
Unethical actions by ICE counsel in requesting an in absentia order knowing full well that the respondent had never received notice;
Stunningly poor trial judging (2X);
Horrible appellate judging;
Frivolous defense of an unjust decision by OIL.

This system is broken! It’s promoting injustice and clogging the Article III Courts with poor quality work product by USG “judges” and attorneys who aren’t up to or well-qualified for their jobs. The focus on “removal at any cost” rather than due process and justice is unconstitutional and unethical. It comes from poor leadership from the Attorney General on down! The only question is why isn’t anybody in charge motivated to fix it!

A quarter century ago, the “EOIR vision” was a noble one: “Through teamwork and innovation be the world’s best administrative tribunals, guaranteeing fairness and due process for all!” It was even posted on the website! Not only has that noble vision disappeared, both literally and figuratively, but over the last two decades Administrations of both parties have degraded justice and functionality at EOIR — some intentionally, some negligently, sometimes a toxic combination of the two.

In the absence of Article I legislation, what EOIR and the DOJ immigration bureaucracy need is a thorough housecleaning, new dynamic, due-process-focused expert leadership, and better judges at both levels. Letting EOIR continue its “death spiral,” as the Biden Administration has done, is totally unacceptable!🤯

Many thanks and appreciation to one of our newest Round Table 🛡️ members, Judge Sandy Hom, recently retired from the New York Immigration Court, for spotting this unpublished opinion and forwarding it! It’s the kind of common purpose, collegiality, and teamwork that is largely absent from today’s dysfunctional EOIR!

🇺🇸 Due Process Forever!

PWS

12-07-23

🛡⚔️ THE LEGEND OF THE ROUND TABLE CONTINUES TO GROW! — Making A Difference Even When The Results Are Not What We Wished For! — PLUS, “BONUS COVERAGE” OF THE “SUPER MOON,” COURTESY OF “SIR JEFFREY!”

Hon. Jeffrey S. Chase
Jeffrey S. Chase Blog
Coordinator & Chief Spokesperson, Round Table of Former Immigration Judges

“Sir Jeffrey” Chase reports:

9th Circuit Decision in U.S. v. Bastide-Hernandez

Hi all:Attached please find the published, en banc decision of the 9th Circuit issued yesterday in U.S. v. Bastide-Hernandez.As expected, the court held that the absence of a date and time of hearing does not deprive the Immigration Court of jurisdiction.

However, please note the concurring opinion of Judge Friedland, stating that although the court held that the issue is not jurisdictional, “there are strong argument for the contrary position,” adding that the Supreme Court may reach a different conclusion.

Judge Friedland also quoted our Round Table’s amicus brief at length, as follows:

“An amicus brief filed by former immigration judges elaborates on why it better serves clarity, efficiency, and due process to include the time and location of the hearing in an NTA in the first instance. As amici explain, incomplete initial notice documents create uncertainty both for noncitizens, who are left in the dark as to when and where a potentially life-changing proceeding will be held, and for immigration judges, who cannot be sure if a case can proceed. Amici also note that the Government’s notice-by- installment practice creates additional fact-finding obligations for immigration judges, who may need to look to multiple documents to determine whether informational gaps in the initial notice have been filled. And amici caution that, because immigration judges are already overburdened and face pressure to complete cases, ambiguities about notice may lead immigration judges to order noncitizens removed when they fail to show up at their hearings, even if the noncitizens never received notice of those hearings at all.”

I think that this lengthy reference demonstrates the importance of our work.

Best, Jeff

US v. Bastide-Hernandez

*******************

In the words of Ninth Circuit Judge Michelle Friedland (Obama appointee): “[I]t better serves clarity, efficiency, and due process to include the time and location of the hearing in an NTA in the first instance.”

What if we had an EOIR where all judges at the trial and appellate levels and all senior administrators were unswervingly committed to due process, fundamental fairness, and best practices?

Instead, we have a dysfunctional organization where DHS’s wishes, perceived expediency, and keeping the “political bosses” happy (thus providing “job security”) triumphs over the public interest and the cause of justice. Currently, we’re “saddled” with a broken system that sees Immigration Court as a “soft deterrent” rather than a dispenser of justice could actually make our immigration, human rights, and justice system run more smoothly by applying fair procedures and “best interpretations.” That would facilitate the legal admission of many more migrants, while starting to “disempower smugglers,” cut backlog, discourage poor practices at DHS Enforcement, promote consistency, and keep many disputes that should be resolved in favor of respondents out of the Article IIIs!

Better, more reasonable administrative precedents that adhered to the proper interpretations of asylum and protection laws and provided positive guidance on how to apply them to recurring situations would also “leverage” the Asylum Office by allowing many more cases to be granted at the first level. As long as the current lousy BIA precedents prevail, far too many cases will just be denied at the AO level and referred to Immigration Court — making it a colossal waste of time. “So-called streamlining” will only work if it results in significantly more AO grants of protection!

We “win some, lose some.” But, our Round Table’s cause is justice; we’re not going to give up until this system makes the long overdue, radical personnel, procedural, attitude, and “cultural” changes necessary to become the “best that it can be!”

That means fulfilling the Immigration Courts’ once and future vision of “through teamwork and innovation become the world’s best tribunals guaranteeing fairness and due process for all.”

Bonus Coverage:

“Sir Jeffrey’s” skills aren’t confined to the legal arena. Here are some pictures he took from his balcony of last night’s “Super Moon:”

🇺🇸 Due Process Forever!

PWS

07-14-22

SPLIT 9TH STUFFS TRUMP’S SCHEME TO MISAPPROPRIATE MILITARY FUNDS FOR WALL: Kids Are In Crisis in Trump’s “Kiddie Gulag,” But Administration Scofflaws Defend Wasting Money On Political Boondoggle That Congress Properly Refused To Fund!

https://www.latimes.com/local/lanow/la-me-ln-trump-border-wall-military-funds-9th-circuit-20190703-story.html

Maura Dolan reports for the LA Times:

Trump may not use military money for border wall, federal appeals court decides

MAURA DOLAN
REPORTING FROM SAN FRANCISCO

July 3 at 7:50 PM ET

A federal appeals court Wednesday upheld an injunction barring the Trump administration from using military funds to pay for a wall along the southern border.

In a 2-1 decision, a panel of the U.S. 9th Circuit Court of Appeals said Trump was likely to lose his appeal and the injunction by a district judge should remain in place.

After failing to win funding for the wall from Congress, Trump announced in February that he planned to divert $8.1 billion for the border wall from funds slated for military construction and other Department of Defense operations.

The Sierra Club and the Southern Border Communities Coalition sued, winning an injunction in late May. The Trump administration asked the 9th Circuit to block that order while the case is on appeal.

In rejecting the administration’s request, the 9th Circuit said using the military funds “violates the constitutional requirement that the executive branch not spend money absent an appropriation from Congress.

The public interest is “best served by respecting the Constitution’s assignment of the power of the purse to Congress,” the 9th Circuit said.

The order was signed by Judges Richard Clifton, appointed by President George W. Bush, and Michelle Friedland, an Obama appointee.

Ninth Circuit Judge N. Randy Smith, appointed by President George W. Bush, dissented.

Copyright © 2019, The Los Angeles Times

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Basically, Trump tried to steal money Congress refused to give him and use it for a bogus political stunt — building a wall for political show that could have no real effect on legitimate law enforcement other than to enrich smugglers and kill some more innocent asylum seekers by forcing them to use smugglers to take them over a more dangerous spot or to tunnel, scale, or break through the wall.

For the record, Judge Randy N. Smith “tanked” on his oath of office and his Constitutional responsibilities to stop such nonsense. Fortunately, Judge Richard Clifton and Judge Michelle Friedland stood up for the Constitution and our right to have a Government that follows its own laws.

Undoubtedly, there will be an appeal, so stay tuned. The Supremes are much more “marshmallowy” when comes to forcing Trump to operate within the Constitution.

PWS

07-03-19

BIA WRONG AGAIN – 9TH CIR. VACATES MATTER OF G-G-S-, 26 I&N DEC. 339 (BIA 2014) (“PARTICULARLY SERIOUS CRIME”) — GOMEZ-SANCHEZ V. SESSIONS – As Jeff Sessions Plans To Speed Up The System, Rig Law Against Individuals, & Undermine Due Process, The “REAL” Courts Continue To Highlight Serious Substantive Flaws In Immigration Court System That Sessions Is Attempting To Cover Up!

GGS,9TH14-72506

Gomez-Sanchez v. Sessions, 9th Cir., 04-06-18, Published, vacating Matter of G-G-S-, 26 I&N Dec. 339 (BIA 2014)

COURT STAFF SUMMARY:

The panel granted Guillermo Gomez-Sanchez’s petition for review of the published decision of the Board of Immigration Appeals, Matter of G-G-S-, 26 I. & N. Dec. 339 (BIA 2014), which concluded that Gomez-Sanchez was statutorily ineligible for withholding of removal because he was convicted of a “particularly serious crime” under 8 U.S.C. § 1231(b)(3)(B), and vacated and remanded.

Gomez-Sanchez was convicted of assault with a non- deadly firearm weapon in violation of California Penal Code § 245(a)(1), which the BIA concluded constituted a particularly serious crime that prevented Gomez-Sanchez from being eligible for withholding of removal. In reaching this decision, the BIA held that a petitioner’s mental health could not be considered when addressing whether he had committed a particularly serious crime.

The panel held that Matter of G-G-S- was not entitled to deference under Chevron U.S.A., Inc. v. N.R.D.C., Inc., 467 U.S. 837 (1984). Under step one of Chevron, the panel concluded that Matter of G-G-S-’s blanket rule against considering mental health is contrary to Congress’s clearly expressed intent that the particularly serious crime determination, in cases where a conviction falls outside the only statutorily enumerated per se category of particularly serious crimes, requires a case-by-case analysis. The panel also concluded that, even if Matter of G-G-S- were to survive step one of Chevron, it would fail at step two because the BIA’s interpretation is not reasonable in that the BIA’s two rationales for its broad rule – 1) that the Agency could not reassess a criminal court’s findings, and 2) that mental health is never relevant to the particularly serious crime determination – are unpersuasive and are inconsistent with the law of this Circuit and the BIA’s own decisions.

*** This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.

PANEL:

Before: Kim McLane Wardlaw* and Michelle T. Friedland, Circuit Judges, and Janet Bond Arterton,**District Judge.

* This case was submitted to a panel that included Judge Kozinski, who recently retired. Following Judge Kozinski’s retirement, Judge Wardlaw was drawn by lot to replace him. Ninth Circuit General Order 3.2.h. Judge Wardlaw has read the briefs, reviewed the record, and listened to oral argument.

** The Honorable Janet Bond Arterton, United States District Judge for the District of Connecticut, sitting by designation.

OPINION BY:

Judge Janet Bond Arterton

KEY QUOTES:

Against this backdrop, the BIA here announced and applied a blanket rule against considering an individual’s mental health as a factor when deciding whether his or her crime of conviction is particularly serious. Matter of G-G-S-, 26 I. & N. Dec. at 339, 347.4 This decision is contrary to Congress’s clearly expressed intent that the analysis of whether a crime is particularly serious “requires the agency to conduct a case-by-case analysis of convictions falling outside the category established by Congress,” Blandino- Medina, 712 F.3d at 1345, because such categorical rules undermine the ability of the agency to conduct a case-by- case analysis in each case, see Konou, 650 F.3d at 1128; see also Arteaga De Alvarez, 704 F.3d at 740.

. . . .

Here, the Board cited In re N-A-M- approvingly, as if applying it. See Matter of G-G-S-, 26 I. & N. Dec. at 343. However, in reality, its decision to constrain the evidence IJs may consider when making a particularly serious crime determination is at least inconsistent with, if not directly in contradiction with its earlier holding permitting consideration of “all reliable information.” See In Re N-A- M-, 24 I. & N. Dec. at 338, 342. Petitioner’s case makes this inconsistency clear—despite not disputing the reliability of the information Petitioner submitted concerning his mental illness, the Board entirely precluded consideration of that evidence. Given that the Board made no attempt to address the apparent inconsistencies between its earlier rule and the rule at issue here, we find its current interpretation to be unreasonable and thus decline to afford it deference. See Encino Motorcars, LLC v. Navarro, 136 S. Ct. 2117, 2126 (2016) (“[A]n ‘[u]nexplained inconsistency’ in agency policy is ‘a reason for holding an interpretation to be an arbitrary and capricious change from agency practice,’” and thus finding that the interpretation is not entitled to Chevron deference. (quoting Nat’l Cable & Telecommunications Ass’n v. Brand X Internet Servs., 545 U.S. 967, 981 (2005)));see also Marmolejo-Campos v. Holder, 558 F.3d 903, 920 n.2 (9th Cir. 2009) (en banc).

Given the severe repercussions of being found to have committed a particularly serious crime, the risk of precluding relevant evidence that might alter that determination is unreasonable. Furthermore, this risk is readily avoided by permitting the IJ to use his or her discretion in weighing relevant, reliable evidence of mental health rather than categorically barring this evidence in all cases.

For all of these reasons the Board’s interpretation of the INA does not warrant deference under Chevron.

. . . .

We find the Board’s conclusion to be unreasonable because it is inconsistent with its own precedent recognizing the relevance of motivation and intent to the particularly serious crime determination. See Alphonsus, 705 F.3d at 1048 (“The BIA acts arbitrarily when it disregards its own precedents and policies without giving a reasoned explanation for doing so.” (quoting Israel v. I.N.S., 785 F.2d 738, 740 (9th Cir. 1986))). In Matter of L-S-, the Board found significant that an individual convicted of alien smuggling did not intend to harm the victim. 22 I. & N. Dec. 645, 655–56 (BIA 1999). Indeed, the Government concedes that a particularly serious crime analysis permits consideration of an individual’s motivation. See Alphonsus, 705 F.3d at 1048 (finding no intent to harm either the arresting officer or members of the public).

********************************************

The BIA got it wrong in just about every conceivable way, including ignoring and misapplying its own precedents, in trying to reach a result unfavorable to the respondent. Against this backdrop of serious substantive problems (and, frankly, anti-respondent bias) permeating the entire U.S. Immigration Court System, from top to bottom, Sessions outrageously is trying to speed up the system without regard to quality or due process.

Suppose you inherited a factory that was producing defective cars. Would you solve the problem by speeding up the assembly line, forbidding the workers to think about their job functions, and denying them necessary training and equipment. No, that would produce even more defective cars, likely putting your company out of business. So, how is Session’s “just pedal faster” approach to assembly line justice acceptable? Obviously, it isn’t!

Sometimes, it doesn’t take a Government Accountability Office study to ferret out waste, fraud, and abuse. In this case, Jeff Sessions is right out there in public view intentionally and maliciously destroying a key part of the U.S. justice system. Why is Congress standing by and letting him get away with it? Why is the taxpayers’ money being wasted on illegal, illogical, and totally counterproductive actions? Whatever happened to effective oversight?

PWS

04-06-18

BREAKING: En Banc Request From 9th Circuit Judge In State Of Washington v. Trump

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

FILED

FEB 10 2017

MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS

STATE OF WASHINGTON and STATE OF MINNESOTA,

Plaintiffs-Appellees,

DONALD J. TRUMP, President of the United States; et al.,

Defendants-Appellants.

No. 17-35105

D.C. No. 2:17-cv-00141 Western District of Washington, Seattle

ORDER

THOMAS, Chief Judge and En Banc Coordinator:
A judge on this Court has made a sua sponte request that a vote be taken as

to whether the order issued by the three judge motions panel on February 9, 2017, should be reconsidered en banc. A sua sponte en banc call having been made, the parties are instructed to file simultaneous briefs setting forth their respective positions on whether this matter should be reconsidered en banc. The briefs should be filed on or before 11:00 a.m., Pacific time, on Thursday, February 16. The supplemental briefs shall be filed electronically and consist of no more than 14,000 words. See General Order 5.4(c)(3).

********************************

What does this mean? Well, having spent eight years on a “collegial appellate court” I can think of three possibilities.

First, a Judge may request en banc consideration when he or she thinks the panel decision went against the views of the majority of 9th Circuit Judges and wants the full Court to reverse it. Given that the panel that heard Washington v. Trump was fairly representative of the composition of the 9th Circuit, that seems unlikely here.

A second possibility is that a Judge wants the full Court to “put its weight” behind the panel decision, given the importance of the issue. But, because the 9th Circuit has a somewhat diverse makeup, with Judges often disagreeing, it seems unlikely that a majority of Judges would see an advantage to the court in having a potentially “split” en banc ruling in place of the unanimous panel ruling.

A third possibility, and the one that I think is most likely, is that one or more Judges disagree with the panel decision and want to go on record with that disagreement. While there seems to be little chance that a majority of the 9th Circuit Judges will vote to hear the case en banc, the denial of the en banc request would give those Judges who disagree with the panel a chance to write a public dissent from the decision to deny rehearing en banc.

We might or might not find out. Often, en banc reconsideration is simply denied without any reasons being given.

PWS

02/10/17

Matt Zapotsky in WashPost: “7 key take-aways from the court’s ruling on Trump’s immigration order”

https://www.washingtonpost.com/news/post-nation/wp/2017/02/09/7-key-takeaways-from-the-courts-ruling-on-trumps-immigration-order/?hpid=hp_rhp-top-table-main_trumpban-takeaways-930pm%3Ahomepage%2Fstory&utm_term=.64ae82747f5

PWS

02/10/17

BREAKING: 9th Circuit Panel Unanimously Reject’s Administration’s Request For Stay Of Travel Ban — Read The Complete Decision Here!

Read-the-9th-Circuit-s-opinion-on-the-travel-ban

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I think it will be hard for the Administration to prevail at this stage. I’d be surprised if either the full (“en banc”) 9th Circuit or the Supreme Court want to get involved at the TRO stage.

President Trump Tweets “See You In Court.” (Hasn’t that line been used before?) But, as indicated above, I’m not sure that the Supreme Court (particularly with only 8 Justices) will want to intervene at this point. The Supremes did take the Obama Immigration Executive Order case at a preliminary stage; but they were unable to resolve it on the merits, affirming the lower court’s injunction by an evenly divided Court. Not clear why the Court would be in a better position to resolve this one. But, we’ll find out shortly.

PWS

02/09/17

Summaries Of 9th Cir. Travel Ban OA & Judicial Bios From WSJ

https://www.wsj.com/articles/donald-trumps-immigration-action-in-courts-hands-1486491207

DEVLIN BARRETT, BRENT KENDALL and ARUNA VISWANATHA report in today’s WSJ:

“An appeals court pressed a Justice Department lawyer Tuesday on whether President Donald Trump’s executive order on immigration is discriminatory, while also pushing an attorney for the two states fighting the order to explain how it could be unconstitutional to bar entry of people from terror-prone countries, the Justice Department lawyer arguing on behalf of the administration, urged the appeals court to remove a lower-court injunction on the order, arguing that the court shouldn’t second-guess the president’s judgment when it came to a question of national security.

The executive order, Mr. Flentje told a three-judge panel of the San Francisco-based Ninth U.S. Circuit Court of Appeals, struck a balance between security concerns and the practice of allowing people to enter the country.

“The president struck that balance, and the district court’s order has upset that balance,” he said. “This is a traditional national security judgment that is assigned to the political branches and the president and the court’s order immediately altered that.’’

The oral arguments on whether to reinstate some, all, or none of President Donald Trump’s executive order on immigration represented a crucial test in the fast-moving legal battle over White House efforts to restrict entry into the U.S. The Jan. 27 order suspended U.S. entry for visitors from seven predominantly Muslim countries for at least 90 days, froze the entire U.S. refugee program for four months and indefinitely banned refugees from Syria. The administration argues the action was needed to keep terrorists from domestic soil.

The president weighed in on Twitter on Wednesday morning: “If the U.S. does not win this case as it so obviously should, we can never have the security and safety to which we are entitled. Politics!”

The legal clash, which is also playing out in other courts around the country, represents a remarkable test of the powers of a new president determined to act quickly and aggressively to follow up on his campaign promises. Mr. Trump, who promised repeatedly on the campaign trail to tighten what he called lax immigration policies, issued his executive order a week after taking office, generating widespread protests as well as plaudits and setting off an immediate debate over the extent of executive branch authority.”

. . . .

The court isn’t making a final determination on the legality of Mr. Trump’s order for now. Instead, it must decide what immigration rules will be in effect during the coming months while court proceedings on the substance of the president’s restrictions continue.”

Read the WSJ’s bios of the three U.S. Court of Appeals Judges on the panel: Judge William C. Canby Jr., Judge Richard Clifton, Judge Michelle Friedland:

https://www.wsj.com/articles/three-federal-judges-will-decide-on-donald-trump-travel-ban-1486488393

****************************************

This one still seems “too close to call.” There are substantial arguments on both sides. Courts generally do not like to interfere with the authority of the President in the fields of immigration, national security and foreign policy. On the other hand, appellate courts are usually very reluctant to interfere with trial court proceedings at the very preliminary TRO stage. While this might eventually end up in the Supreme Court, as most commentators assume, I’m skeptical it will go there any time soon, given the Supreme’s current short-handed configuration.

PWS

02/08/17

🇺🇸 Due Process Forever!

Related posts:

“Sir Jeffrey” Chase reports:

9th Circuit Decision in U.S. v. Bastide-Hernandez

Bonus Coverage:

🇺🇸 Due Process Forever!

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