Aniche v. Jaddou

CourtDistrict Court, E.D. California
DecidedDecember 4, 2024
Docket2:24-cv-01532
StatusUnknown

This text of Aniche v. Jaddou (Aniche v. Jaddou) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aniche v. Jaddou, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 OBIOMA ANICHE, No. 2:24-cv-01532-CKD 12 Plaintiff, 13 v. ORDER 14 UR MENDOZA JADDOU, et al.,

15 Defendants. 16 17 Plaintiff Obioma Aniche filed a complaint for declaratory and injunctive relief against 18 United States Citizenship and Immigration Services (“USCIS”), and individual defendants, 19 arising from the denial of plaintiff’s I-360 petition. (ECF No. 1.) Pursuant to the parties’ consent 20 and the court’s order of September 20, 2024, this matter was before the undersigned for all 21 purposes including trial and entry of judgment. (ECF Nos. 12, 13, 14.) The defendants seek to 22 dismiss the complaint under Rule 12(b)(1) of the Federal Rules of Civil Procedure for lack of 23 jurisdiction and their motion is fully briefed. (ECF Nos. 8, 11, 18.) The court previously found 24 this matter to be appropriate for decision without oral argument under Local Rule 302(g). (ECF 25 No. 19.) For the reasons set forth below, the motion to dismiss is granted. 26 I. Allegations in the Complaint 27 Under the complaint’s allegations, plaintiff, a Nigerian citizen and native, was previously 28 married in Nigeria and the marriage was dissolved in Nigeria. (ECF No. 1, ¶ 22.) In 2017, 1 plaintiff entered the United States with a valid B-2 visa and married her second husband, Johnnie 2 Moore, a U.S. Citizen, on May 22, 2017. (Id., ¶¶ 23-24.) On March 1, 2021, plaintiff filed an I- 3 360 self-petition under the Violence Against Women Act (“VAWA”) based on abuse suffered 4 from her U.S. citizen spouse. (Id., ¶¶ 16, 25.) 5 Following submission of the original divorce decree from plaintiff’s first marriage in 6 Nigeria in response to a Notice of Intent to Deny (“NOID”), USCIS denied the I-360 petition on 7 November 3, 2022, finding the divorce could not be verified to establish the validity of plaintiff’s 8 subsequent marriage. (ECF No. 1, ¶¶ 27-28.) Plaintiff filed an I-290B motion to reopen with 9 additional evidence authenticating the divorce decree, and USCIS reopened the case. (Id., ¶¶ 29, 10 30.) In response to another NOID, plaintiff submitted further additional evidence from Nigerian 11 legal authority corroborating the divorce decree. (Id., ¶ 30.) 12 On July 21, 2023, USCIS dismissed the I-360 petition on the basis that the legal document 13 was “fraudulent.” (ECF No. 1, ¶ 31.) USCIS alleged the judicial signature from the Assistant 14 Chief Registrar was invalid based on their Consulate exemplars but failed to articulate their proof 15 or acknowledge the evidence plaintiff acquired from the Nigerian Courts stating otherwise. (Id.) 16 Plaintiff filed an appeal with the Administrative Appeals Office (“AAO”). (Id., ¶ 33.) The AAO 17 dismissed the appeal and declined to provide discovery or explanation of USCIS’s allegations 18 despite plaintiff’s overwhelming evidence meeting her burden of proof that her divorce in Nigeria 19 was valid. (Id., ¶¶ 33, 35.) Plaintiff filed a second I-290B motion to reopen which was dismissed. 20 (Id., ¶¶ 33-34.) 21 Plaintiff filed the complaint on May 31, 2024. (ECF No. 1.) The complaint asserts a cause 22 of action under the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(2)(A)1, and seeks to 23 compel defendants to produce evidence leading to the denial and for this court to review the 24 record in its entirety to rule on the issue of plaintiff’s divorce validity. (Id., ¶¶ 42-45.) 25

1 The complaint cites 5 U.S.C. § 706(2)(C), which permits a reviewing court to review agency 26 action alleged to be in excess of statutory jurisdiction, authority, or limitations, or short of 27 statutory right. However, the complaint does not allege agency action in excess of jurisdiction; instead, it alleges the agency action was “arbitrary, capricious and an abuse of discretion, 28 otherwise not in accordance with the law” which corresponds to 5 U.S.C. § 706(1)(A). 1 II. Legal Standard for Rule 12(b)(1) 2 “A motion to dismiss for lack of subject matter jurisdiction under Rule 12(b)(1) may 3 attack either the allegations of the complaint as insufficient to confer upon the court subject 4 matter jurisdiction, or the existence of subject matter jurisdiction in fact.” Renteria v. United 5 States, 452 F. Supp. 2d 910, 919 (D. Ariz. 2006) (citing Thornhill Publ’g Co. v. Gen. Tel. & 6 Elecs. Corp., 594 F.2d 730, 733 (9th Cir. 1979)). “When the motion to dismiss attacks the 7 allegations of the complaint as insufficient to confer subject matter jurisdiction, all allegations of 8 material fact are taken as true and construed in the light most favorable to the nonmoving party.” 9 Renteria, 452 F. Supp. 2d at 919. 10 III. Discussion 11 To obtain the relief she sought under the VAWA, plaintiff had to demonstrate, among 12 other things, that her “marriage or the intent to marry the United States citizen was entered into in 13 good faith” and that during the marriage she had been “battered or [subjected to] extreme cruelty” 14 perpetrated by her spouse. 8 U.S.C. § 1154(a)(1)(A)(iii)(I)(aa)-(bb); see also 8 C.F.R. § 204.2(c) 15 (regulation listing requirements for VAWA petitions). Here, the USCIS denied plaintiff’s 16 application for VAWA status upon a determination that plaintiff’s divorce in Nigeria could not be 17 verified to establish the good faith intent of her subsequent marriage. (ECF No. 1, ¶¶ 27-28.) 18 Plaintiff alleges the court has jurisdiction under the APA and specifically cites 5 U.S.C. § 19 702. (ECF No. 1, ¶ 13.) Defendants counter that the APA provides no basis for jurisdiction where 20 “statue precludes judicial review” or “agency action is committed to agency discretion by law.” 21 See 5 U.S.C. § 701(a). (ECF No. 18 at 2.) Relevant here, defendants argue, the Immigration and 22 Nationality Act (“INA”) expressly prohibits judicial review of any “decision or action . . . the 23 authority for which is specified under this subchapter to be in the discretion of the Attorney 24 General or the Secretary of Homeland Security” other than the granting of asylum relief. 8 U.S.C. 25 § 1252(a)(2)(B)(ii). (ECF No. 8 at 7.) In addition, defendants argue, the INA provision governing 26 petitions for immigrant status specifically provides that in assessing a VAWA self-petition, “the 27 determination of what evidence is credible and the weight to be given that evidence” falls within 28 the sole discretion of the Attorney General.” 8 U.S.C. § 1154(a)(1)(J). 1 Plaintiff does not dispute that 8 U.S.C. § 1252(a)(2)(B)(ii) precludes judicial review of 2 some discretionary decisions.

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Kucana v. Holder
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Bluebook (online)
Aniche v. Jaddou, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aniche-v-jaddou-caed-2024.