Artiga Minera v. Bondi

CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 6, 2025
Docket24-60455
StatusUnpublished

This text of Artiga Minera v. Bondi (Artiga Minera v. Bondi) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Artiga Minera v. Bondi, (5th Cir. 2025).

Opinion

Case: 24-60455 Document: 66-1 Page: 1 Date Filed: 08/06/2025

United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit

No. 24-60455 FILED August 6, 2025 ____________ Lyle W. Cayce Freddy Ernesto Artiga Minera, Clerk

Petitioner,

versus

Pamela Bondi, U.S. Attorney General,

Respondent. ______________________________

Appeal from the Board of Immigration Appeals Agency No. A090 895 169 ______________________________

Before Stewart, Clement, and Wilson, Circuit Judges. Per Curiam: * Freddy Ernesto Artiga Minera, a native and citizen of El Salvador, became a lawful permanent resident of the United States in 1989. In 2000, Artiga Minera was convicted of aggravated assault in Texas, and an Immigration Judge ordered his removal. Artiga Minera illegally re-entered the country in 2003, and authorities detained him in 2024. After being detained, he filed a motion to reconsider his removal order. The Board of Immigration Appeals (“BIA”) denied his motion, and Artiga Minera

_____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5. Case: 24-60455 Document: 66-1 Page: 2 Date Filed: 08/06/2025

No. 24-60455

petitioned this court for review. Because the BIA did not abuse its discretion, and because we lack jurisdiction to consider the BIA’s decision not to reconsider Artiga Minera’s removal sua sponte, the petition for review is DENIED IN PART and DISMISSED IN PART. Respondent’s motion for judicial notice is DENIED AS MOOT. 1 I. Artiga Minera is a native and citizen of El Salvador who became a legal permanent resident in 1989. Roughly ten years later, Artiga Minera pleaded guilty to aggravated assault in violation of Texas Penal Code section 22.02. The criminal complaint charged Artiga Minera with “intentionally and knowingly threaten[ing] [the victim] with imminent bodily injury by using and exhibiting a deadly weapon, namely, a FIREARM.” The Department of Homeland Security issued Artiga Minera a Notice to Appear based on his conviction. The Notice to Appear charged Artiga Minera with being removable under 8 U.S.C. § 1227(a)(2)(A)(iii) because his conviction qualified as an aggravated felony and crime of violence under 8 U.S.C. § 1101(a)(43)(F). Artiga Minera appeared before an Immigration Judge (“IJ”) and conceded that he was removable as charged. The IJ then ordered Artiga Minera removed. Artiga Minera appealed this decision, but the BIA dismissed his appeal for failure to file a brief. Artiga Minera was subsequently removed from the United States. Artiga Minera unlawfully re-entered the country in 2003. In May 2024, Immigration and Customs Enforcement detained Artiga Minera. The next month, he filed a motion for the BIA to reconsider the IJ’s order from

_____________________ 1 Respondent asked the court to take judicial notice of the Department of Homeland Security’s decision to reinstate Artiga Minera’s removal order, but our decision rests on other grounds supported by the record.

2 Case: 24-60455 Document: 66-1 Page: 3 Date Filed: 08/06/2025

September 2000 deeming him removable. Artiga Minera argued that the U.S. Supreme Court’s decision in Borden v. United States, 593 U.S. 420 (2021) dictates that his conviction should not have qualified as a crime of violence. The BIA denied the motion as untimely, finding that Artiga Minera failed to demonstrate that he pursued his rights with reasonable diligence in the three- year period between Borden and the motion to reconsider. The BIA also declined to reconsider the removal order sua sponte. Additionally, the BIA noted that even after Borden, this court held that aggravated assault by threat of imminent bodily injury under sections 22.01(a)(2) and 22.02(a)(2) of the Texas Penal Code is a crime of violence under 18 U.S.C. § 16, which is the same definition of “crime of violence” under the Immigration and Nationality Act, 8 U.S.C. § 1101(a)(43)(F). Artiga Minera now petitions this court for review. II. “We review the Board’s denial of both a motion to reopen and a motion for reconsideration under a highly deferential abuse-of-discretion standard.” Singh v. Gonzalez, 436 F.3d 484, 487 (5th Cir. 2006) (quotations omitted). “We uphold the decision if it ‘is not capricious, racially invidious, utterly without foundation in the evidence, or otherwise so irrational that it is arbitrary rather than the result of any perceptible rational approach.’” Lowe v. Sessions, 872 F.3d 713, 715 (5th Cir. 2017) (quoting Singh, 436 F.3d at 487). III. First, we consider whether the BIA abused its discretion in finding that Artiga Minera did not demonstrate a diligent pursuit of his rights. A motion to reconsider “must be filed within 30 days of the date of entry of a final administrative order of removal.” 8 U.S.C. § 1229a(c)(6)(B). Artiga Minera’s removal order became final when the BIA dismissed his

3 Case: 24-60455 Document: 66-1 Page: 4 Date Filed: 08/06/2025

appeal in September 2000, and the motion to reconsider was filed in June 2024. However, the thirty-day deadline for filing a motion to reconsider is subject to equitable tolling. See Gonzalez Hernandez v. Garland, 9 F.4th 278, 284 (5th Cir. 2021). A movant is entitled to equitable tolling “only if: (1) he has been pursuing his rights diligently and (2) some extraordinary circumstance has stood in his way and prevented timely filing.” Id. The diligence element “requires the litigant to establish that he pursued his rights with reasonable diligence, not maximum feasible diligence.” Flores-Moreno v. Barr, 971 F.3d 541, 545 (5th Cir. 2020) (quotations omitted). Generally, the party seeking equitable tolling bears the burden of proof. See Mejia v. Barr, 952 F.3d 255, 258 (5th Cir. 2020). Artiga Minera contends that he diligently pursued his rights because he first learned of the Borden case in late May 2024, after his wife consulted with an attorney, learned of the case, and informed Artiga Minera. The motion to reconsider followed shortly thereafter, in early June 2024. Artiga Minera argues that the deadline to file his motion was equitably tolled until he learned of Borden, and he cites the case of Gonzalez-Cantu v. Sessions, 866 F.3d 302 (5th Cir. 2017) in support of this argument. But Gonzalez-Cantu did not hold that tolling applies until a petitioner learns of a change in the law. 866 F.3d at 305. Instead, the court reasoned that even if tolling had applied until that date, the petitioner would not have proven that her motion was timely, so there was no reason to examine her efforts to discover the new law. Id. at 305 & n.4.

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Related

Singh v. Gonzales
436 F.3d 484 (Fifth Circuit, 2006)
Angelica Gonzalez-Cantu v. Jefferson Sessions, III
866 F.3d 302 (Fifth Circuit, 2017)
Maria Lowe v. Jefferson Sessions, III
872 F.3d 713 (Fifth Circuit, 2017)
Abdifatah Gaas Qorane v. William Barr, U. S. Atty
919 F.3d 904 (Fifth Circuit, 2019)
United States v. Albin Torres
923 F.3d 420 (Fifth Circuit, 2019)
Denis Mejia v. William Barr, U. S. Atty Gen
952 F.3d 255 (Fifth Circuit, 2020)
Borden v. United States
593 U.S. 420 (Supreme Court, 2021)
Gonzalez Hernandez v. Garland
9 F.4th 278 (Fifth Circuit, 2021)

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Artiga Minera v. Bondi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/artiga-minera-v-bondi-ca5-2025.