Castillo, O. v. Guerra, M.

2024 Pa. Super. 42, 312 A.3d 341
CourtSuperior Court of Pennsylvania
DecidedMarch 8, 2024
Docket1579 EDA 2023
StatusPublished
Cited by3 cases

This text of 2024 Pa. Super. 42 (Castillo, O. v. Guerra, M.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Castillo, O. v. Guerra, M., 2024 Pa. Super. 42, 312 A.3d 341 (Pa. Ct. App. 2024).

Opinion

J-A24024-23

2024 PA Super 42

OSCAR AMILCAR CASTILLO : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : MARIA CANDELARIA GUERRA : No. 1579 EDA 2023

Appeal from the Order Entered May 18, 2023 In the Court of Common Pleas of Delaware County Civil Division at No(s): 2023-1210

BEFORE: STABILE, J., DUBOW, J., and SULLIVAN, J.

OPINION BY DUBOW, J.: FILED MARCH 8, 2024

Appellant, Oscar Amilcar Castillo (“Uncle”), appeals from the May 18,

2023 Order entered in the Court of Common Pleas of Delaware County that

denied his petition seeking the issuance of an order containing specific factual

findings regarding his nephew, now-19-year-old A.J.P.A. (“Nephew”),

necessary to petition the U.S. Citizenship and Immigration Services (“USCIS”)

for special immigration juvenile status (“SIJS”) pursuant to 8 U.S.C. §

1101(a)(27)(J) and 8 C.F.R. § 204.11. Upon review, we affirm.

In September 2022, then-17-year-old Nephew left his home country of

Honduras and hitchhiked to the U.S. Upon arrival, Nephew was taken into

custody of the U.S. Department of Health and Human Services Office of

Refugee Resettlement (“ORR”). On November 12, 2022, ORR released

Nephew into Uncle’s custody. J-A24024-23

On February 13, 2023, Uncle filed an emergency complaint for custody

of Nephew and a request for special relief in the form of factual findings as a

requisite predicate to Nephew’s federal SIJS petition. On April 5, 2023, the

trial court issued an Order adopting a written custody agreement between

Uncle and Mother, who lives in Honduras, which granted Uncle legal and

physical custody of Nephew. On April 7, 2023, Nephew turned 18 years old.

On April 13, 2023, the trial court held a hearing on Uncle’s petitions and heard

testimony from Uncle, Nephew, and Mother.

On May 18, 2023, the trial court denied Uncle’s emergency request for

custody as moot,1 denied Uncle’s request for a SIJS predicate order, and

issued findings of fact and conclusions of law. The trial court found that Uncle

and Nephew sought the custody order for the sole purpose of requesting SIJS,

in contradiction to the federal government’s directive condoning such actions.

Trial Ct. Op., 5/12/23, at 18. The trial court further found that the record did

not definitively support a conclusion that it was in Nephew’s best interest to

stay in the U.S. rather than return to Honduras, absent credible and unbiased

evidence regarding the “overall demographics of Honduras.” Id.

Uncle timely appealed. Both Uncle and the trial court complied with

Pa.R.A.P. 1925.

Uncle raises the following issues for our review:

____________________________________________

1 The trial court denied Uncle’s emergency custody request as moot because

Nephew had turned 18 years old, and the court had previously accepted a custody agreement concerning Nephew.

-2- J-A24024-23

I. In light of the trial court’s finding that the testimony presented was credible, did the [t]rial court abuse its discretion or commit and error of law when it denied [Uncle]’s request for a finding that reunification of [Nephew] with [Nephew]’s mother is not viable due to serious physical neglect where, inter alia, the testimony established that [Nephew] often when hungry in his mother’s care and started working in agriculture at the age of seven to help support himself.

II. Did the [t]rial [c]ourt abuse its discretion when it denied [Uncle]’s request for a finding that reunification of [Nephew] with [Nephew]’s father is not viable due to abandonment where, inter alia, the credible testimony established that [Nephew]’s father left when Child was too young to remember, never provided support, and no one has seen him since?

III. Did the [t]rial court abuse its discretion when it denied [Uncle]’s request for a finding that it is not in [Nephew]’s best interest to return to Honduras, where his basic physical and educational needs were not being met?

Uncle’s Br. at 5-6.

A.

Underlying each of Appellant’s issues is the federal immigration statute

noted above. We, thus, begin our analysis mindful that, when interpreting a

federal statute, this Court applies the following principles:

The construction of a federal statute is a matter of federal law. Under federal rules of statutory construction, in determining the meaning of a federal statute, the courts look not only to particular statutory language, but also to the design of the statute as a whole and to its purposes. Furthermore, when the courts confront circumstances not plainly covered by the terms of a statute, suggesting that Congress did not contemplate the issue, they endeavor to give statutory language the meaning that advances the policies underlying the legislation.

-3- J-A24024-23

Velasquez v. Miranda, 297 A.3d 837, 843 (Pa. Super. 2023), appeal

granted, ____ Pa. ____, 2023 WL 8181188 (Pa. Nov. 27, 2023) (citations

omitted).

The relevant federal statute provides that SIJS is available to foreign

children in the United States who have been “declared dependent on a juvenile

court located in the United States or whom such a court has legally committed

to, or placed under the custody of, an agency or department of a State, or an

individual or entity appointed by a State or juvenile court located in the United

States, and whose reunification with 1 or both of the immigrant's parents is

not viable due to abuse, neglect, [or] abandonment[.]” 8 U.S.C. §

1101(a)(27)(J)(i). Moreover, a court must determine that “it would not be in

the alien’s best interest to be returned to the alien’s or parent’s previous

country of nationality or country of last habitual residence.” Id. at

1101(a)(27)(J)(ii). “To obtain SIJS, a child must first apply to a state court

for an order finding that he or she meets the statutory and regulatory

requirements.” Velasquez, 297 A.3d at 845.

To qualify for SIJS, applicants must be physically present in the United

States, unmarried, under the age of twenty-one, and must be the subject of

a juvenile court order. 8 C.F.R. § 204.11(b)(1-4). As it relates to this appeal,

the state juvenile court order must have (1) “placed the petitioner under the

custody of . . . an individual or entity appointed by a State or juvenile court[,]”

(2) “made a judicial determination that parental reunification with one or both

parents is not viable to due abuse, neglect, abandonment, or a similar basis

-4- J-A24024-23

under State law[,]” (3) made a judicial determination that “it would not be in

petitioner’s best interest to be returned to the petitioner’s or their parent’s

country of nationality or last habitual residence.” Id. at § 204.11(c)(1-2).

“With that order in hand, applicants must then file an application with

USCIS, along with sufficient evidence to establish eligibility and the associated

filing fee. The Secretary of Homeland Security must also consent to the grant

of SIJ status, which functions as an acknowledgement that the request for SIJ

classification is bona fide—that is, that the benefit is sought primarily for the

purpose of obtaining relief from abuse or neglect or abandonment.” Osorio-

Martinez v. Attorney Gen.

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Related

Castillo, O. v. Guerra, M.
Supreme Court of Pennsylvania, 2024
Velasquez, L., Aplt v. Miranda, L.
Supreme Court of Pennsylvania, 2024
Castillo, O. v. Guerra, M.
2024 Pa. Super. 42 (Superior Court of Pennsylvania, 2024)

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Bluebook (online)
2024 Pa. Super. 42, 312 A.3d 341, Counsel Stack Legal Research, https://law.counselstack.com/opinion/castillo-o-v-guerra-m-pasuperct-2024.