Galvez v. Jaddou

CourtDistrict Court, W.D. Washington
DecidedOctober 5, 2020
Docket2:19-cv-00321
StatusUnknown

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

Bluebook
Galvez v. Jaddou, (W.D. Wash. 2020).

Opinion

7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE 9 LEOBARDO MORENO GALVEZ, et al., Case No. C19-0321RSL 10 Plaintiffs, ORDER GRANTING PLAINTIFFS’ 11 MOTION FOR SUMMARY JUDGMENT v. AND PERMANENT INJUNCTION 12

13 KENNETH T. CUCCINELLI,1 et al.,

14 Defendants. 15 16

17 This matter comes before the Court on the parties’ cross-motions for summary 18 judgment. Dkt. #64 and #66. The named plaintiffs represent a class of young immigrants who 19 were determined by the courts of the State of Washington to have been abused, neglected, or 20 abandoned by one or both of their parents. They sought classification as Special Immigrant 21 Juveniles (“SIJ”) as a pathway to lawful permanent residency in the United States. On July 17, 22 2019, the Court issued a preliminary injunction enjoining defendants - the United States 23 Department of Homeland Security (“DHS”), the United States Citizenship and Immigration 24 Services (“USCIS”), the individuals in charge of DHS and USCIS, and the director of the 25 National Benefits Center – from enforcing a 2018 change in policy that, plaintiffs argued, 26 1 Kenneth T. Cuccinelli became the acting director of the United States Citizenship and Immigration Services on 27 June 10, 2019, replacing Lee Francis Cissna, the originally-named defendant. 1 unlawfully denied them SIJ status. The Court also required USCIS to promptly adjudicate or 2 readjudicate all class members’ SIJ petitions. Plaintiffs now seek summary judgment on their 3 various challenges to USCIS’ actions and the entry of an injunction permanently enjoining the 4 agency from unreasonably delaying the adjudication of SIJ petitions in the State of 5 Washington. Defendants seek judgment in their favor, arguing that the matter is moot and/or 6 that the 2018 policy was lawful and lawfully implemented. Defendants also argue that they are 7 not obligated to comply with the statutory deadline for adjudicating SIJ petitions and that 8 plaintiffs have failed to show that a permanent injunction is warranted. 9 Having reviewed the memoranda, declarations, and exhibits submitted by the parties,2 10 the Court finds as follows: 11 I. BACKGROUND 12 Congress created the SIJ status in 1990 as a means of alleviating “hardships 13 experienced by some dependents of United States juvenile courts by providing qualified aliens 14 with the opportunity to apply for special immigrant classification and lawful permanent 15 resident status, with possibility of becoming citizens of the United States in the future.” 58 Fed. 16 Reg. 42843, 42844 (Aug. 12, 1993). SIJ status is available if: 17 (i) [the juvenile immigrant] has been declared dependent on a juvenile court 18 located in the United States or whom such a court has legally committed to, or 19 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 20 whose reunification with 1 or both of the immigrant’s parents is not viable due to abuse, neglect, abandonment, or a similar basis found under State law; 21 (ii) [it] has been determined in administrative or judicial proceedings that it 22 would not be in the alien’s best interest to be returned to the alien’s or parent's 23 previous country of nationality or country of last habitual residence; and

24 (iii) … the Secretary of Homeland Security consents to the grant of special immigrant juvenile status .... 25 26

27 2 This matter can be determined on the papers submitted. Plaintiffs’ request for oral argument is DENIED. 1 8 U.S.C. §1101(a)(27)(J). If granted, SIJ status provides a pathway to lawful permanent 2 residency and, ultimately, citizenship. See 8 U.S.C. §§1255, 1427. When an immigrant applies 3 for SIJ status, USCIS must grant or deny the application within 180 days. 8 U.S.C. 4 §1232(d)(2). 5 When SIJ status was first recognized as a form of immigration relief, the applicant had 6 to be “eligible for long-term foster care,” which the agency interpreted as requiring a 7 determination “by the juvenile court that family reunification is no longer a viable option.” 8 8 9 C.F.R. §204.11(a). Agency regulations clarified that eligible juveniles were aliens “under 10 twenty-one years of age.” 8 C.F.R. §204.11(c)(1). 11 In 2008, Congress passed the William Wilberforce Trafficking Victims Protection 12 Reauthorization Act (“TVPRA”), amending the SIJ statute in three significant ways. Pub. L. 13 No. 110-457 §235(d), 122 Stat. 5044 (2008). First, the TVPRA expanded the universe of 14 immigrants would could obtain SIJ status. It removed the requirement that applicants be 15 eligible for long-term foster care, broadening the statute to apply instead to juveniles for whom 16 17 “reunification with 1 or both of the immigrant’s parents is not viable due to abuse, neglect, 18 abandonment, or a similar basis found under state law.” Id. §235(d)(1)(B) (amending 8 U.S.C. 19 §1101(a)(27)(J)). It also made SIJ status available to juveniles who had been “legally 20 committed to, or placed under the custody of, an agency or department of a State, or an 21 individual or entity appointed by a State or juvenile court” in addition to those who had been 22 “declared dependent on a juvenile court.” Second, the TVPRA clarified that an applicant’s 23 24 eligibility for SIJ status is dependent on the juvenile’s age at the time he or she applied for SIJ 25 status rather than at the time the application was processed. Id. §235(d)(6). Finally, the 26 amendments removed the requirement that the agency “expressly consent” to the state court’s 27 1 dependency order, instead requiring “consent[] to the grant of special immigration juvenile 2 status.” Id. §235(d)(1)(B). USCIS exercises its “consent” authority by verifying whether the SIJ 3 petition is bona fide, “meaning that the juvenile court order was not sought primarily to obtain 4 the status of an alien lawfully admitted for permanent residence” but “rather to obtain relief 5 from abuse or neglect.” Dkt. #25 at 15. 6 Following enactment of the TVPRA, a petitioner for SIJ status must be (a) under 7 twenty-one years of age, (b) unmarried, (c) declared dependent on a juvenile court or placed in 8 9 the custody of a state agency or individual appointed by the court, and (d) the subject of state 10 court findings that (i) reunification with one or both parents is not viable because of abuse, 11 abandonment, neglect, or similar basis under state law and (ii) it is not in the juvenile’s best 12 interests to be returned to his or her country of origin. USCIS’ review of SIJ petitions was 13 generally guided by the statutory elements. 14 In the summer of 2017, however, USCIS began holding SIJ applications for individuals 15 between the ages of 18 and 21. USCIS had centralized adjudication of SIJ applications in 16 17 November 2016 and was awaiting legal guidance from the USCIS Office of Chief Counsel 18 (“OCC”) regarding a new policy that would affect SIJ adjudications for that age group. The 19 new guidance was issued in February 2018 and specifies that, in order for a state court to be 20 one of “competent jurisdiction” to make the necessary SIJ findings, the court must have the 21 power not only to determine whether reunification with a parent is appropriate or viable, but 22 also “to order reunification, if warranted.” Dkt.

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Bluebook (online)
Galvez v. Jaddou, Counsel Stack Legal Research, https://law.counselstack.com/opinion/galvez-v-jaddou-wawd-2020.