Gerardo Guzman-Gutierrez v. Todd Blanche

CourtCourt of Appeals for the Ninth Circuit
DecidedJune 18, 2026
Docket20-71979
StatusUnpublished

This text of Gerardo Guzman-Gutierrez v. Todd Blanche (Gerardo Guzman-Gutierrez v. Todd Blanche) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gerardo Guzman-Gutierrez v. Todd Blanche, (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUN 18 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

GERARDO GUZMAN-GUTIERREZ, No. 20-71979

Petitioner, Agency No. A205-699-392

v. MEMORANDUM* TODD BLANCHE, Acting Attorney General,

Respondent.

On Petition for Review of an Order of the Board of Immigration Appeals

Submitted June 12, 2026** Seattle, Washington

Before: W. FLETCHER and M. SMITH, Circuit Judges, and HINDERAKER,*** District Judge.

Gerardo Guzman-Gutierrez petitions for review of the Board of Immigration

Appeals’ (“BIA”) order dismissing his appeal from an immigration judge’s (“IJ”)

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). *** The Honorable John Charles Hinderaker, United States District Judge for the District of Arizona, sitting by designation. decision denying his application for cancelation of removal under 8 U.S.C.

§ 1229b(b). We have jurisdiction under 8 U.S.C. § 1252. We review de novo the

BIA’s determination of legal questions and due process challenges to final orders

of removal. Padilla-Martinez v. Holder, 770 F.3d 825, 830 (9th Cir. 2014)

(citations omitted). We review whether the BIA erred in applying the exceptional

and extremely unusual hardship standard for substantial evidence. Gonzalez-Juarez

v. Bondi, 137 F.4th 996, 1003 (9th Cir. 2025). We deny the petition.

1. During a removal proceeding, “the alien shall have a reasonable

opportunity to examine the evidence against the alien, to present evidence on the

alien’s own behalf, and to cross-examine witnesses presented by the Government.”

8 U.S.C. § 1229a(b)(4)(B). Noncitizens in removal proceedings have a due process

right to a full and fair proceeding, Colmenar v. INS, 210 F.3d 967, 971 (9th Cir.

2000), but to proceed on a procedural due process claim, a noncitizen must show

the violation caused him prejudice. Gomez-Velazco v. Sessions, 879 F.3d 989, 993

(9th Cir. 2018).

Petitioner has not established that the IJ’s conduct prejudiced him. To

demonstrate prejudice in a removal proceeding, a petitioner must show “that the

outcome of the proceeding may have been affected by the alleged violation.”

Zamorano v. Garland, 2 F.4th 1213, 1226 (9th Cir. 2021) (quoting Pangilinan v.

Holder, 568 F.3d 708, 709 (9th Cir. 2009) (per curiam)). The IJ did not allow

2 Petitioner’s ten-year-old son, A.G., to testify because the IJ thought it would have

been too traumatic. The IJ did allow Petitioner and Petitioner’s lawful permanent

resident (“LPR”) parents to testify, however. These three witnesses testified about

Petitioner’s relationship with A.G., A.G.’s health conditions, and the difficulties

A.G. would face in adjusting to life in Mexico were he to go with his father. These

are the same subjects Petitioner’s counsel proffered A.G. would have testified

about. See AR 471 (A.G. would “testify about how he suffers from asthma and

how he is excelling in school . . . [and] as to all the things his father does for him

and most importantly how he feels safe with his father”). Nothing in the record

indicates that any additional testimony A.G. would have offered about his

relationship with his father, the difficulty he would face moving to Mexico, or his

medical conditions—which were not causing any notable impairments at the time

of the hearing—could have changed the IJ’s decision when the IJ had already

heard testimony and reviewed evidence concerning each of these topics. And, in

view of the tenuous nature of Petitioner’s claim for cancelation of removal, there is

no reasonable possibility that the testimony would have carried such emotional

sway as to potentially affect the proceeding’s outcome. See Zamorano, 2 F.4th at

1226.

2. In evaluating whether a petitioner has met the exceptional and extremely

unusual hardship standard, an IJ considers “the ages, health, and circumstances of

3 qualifying lawful permanent resident and United States citizen relatives.” In re

Monreal, 23 I. & N. Dec. 56, 63 (BIA 2001). To constitute exceptional and

extremely unusual hardship, “the hardship must be out of the ordinary and

exceedingly uncommon. It must deviate, in the extreme, from the norm. The

agency must compare the hardship in a given case to the hardship that results in the

usual, ordinary course when an alien is removed.” Gonzalez-Juarez v. Bondi,

137 F.4th 996, 1006 (9th Cir. 2025). “[A]ll hardship factors should be considered

in the aggregate when assessing exceptional and extremely unusual hardship.” In

re Monreal, 23 I. & N. Dec. at 63.1

Petitioner has not met this “very demanding” standard. de Garcia v. Holder,

621 F.3d 906, 913 (9th Cir. 2010). Though Petitioner’s son and parents will

undoubtably experience hardship resulting from Petitioner’s removal, A.G. does

1 Though Petitioner contends the IJ applied the wrong legal standard by failing to consider the harm to all Petitioner’s qualifying family members in the aggregate, he is mistaken. The IJ’s decision recited the requirement that “[a]ll hardship factors should be considered in the aggregate” and found “the circumstances described by [Petitioner were] not exceptional and extremely unusual.” AR 74, 80. The BIA adopted the IJ’s reasoning and found that, “[c]onsidering the evidence individually and cumulatively,” Petitioner had not shown his qualifying relatives would suffer exceptional and extremely unusual hardship. AR 3. Both the IJ and the BIA cited the Monreal decision that Petitioner invokes for his argument in applying the hardship standard. See Mendez-Castro v. Mukasey, 552 F.3d 975, 980 (9th Cir. 2009) (“[T]he IJ expressly cited and applied Monreal in rendering its decision, which is all our review requires.”), abrogated on other grounds by Wilkinson v. Garland, 601 U.S. 209 (2024).

4 not have “very serious health issues, or compelling needs in school,” and

Petitioner’s parents are not “solely dependent upon him for support.” In re

Monreal, 23 I. & N. Dec. at 63–64 (giving examples of applicants who would

likely have a strong case). The evidence does not show that the hardship to

Petitioner’s parents and son would be “‘substantially’ beyond the ordinary

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Related

De Garcia v. Holder
621 F.3d 906 (Ninth Circuit, 2010)
Mendez-Castro v. Mukasey
552 F.3d 975 (Ninth Circuit, 2009)
Lacsina Pangilinan v. Holder
568 F.3d 708 (Ninth Circuit, 2009)
Jesus Padilla-Martinez v. Eric Holder, Jr.
770 F.3d 825 (Ninth Circuit, 2014)
Eladio Gomez-Velazco v. Jefferson Sessions
879 F.3d 989 (Ninth Circuit, 2018)
Bistermu Mora Salgado v. Jefferson Sessions
889 F.3d 982 (Ninth Circuit, 2018)
Victor Angeles Zamorano v. Merrick Garland
2 F.4th 1213 (Ninth Circuit, 2021)
MONREAL
23 I. & N. Dec. 56 (Board of Immigration Appeals, 2001)
Wilkinson v. Garland
601 U.S. 209 (Supreme Court, 2024)
Gonzalez-Juarez v. Bondi
137 F.4th 996 (Ninth Circuit, 2025)

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Gerardo Guzman-Gutierrez v. Todd Blanche, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gerardo-guzman-gutierrez-v-todd-blanche-ca9-2026.