Hanan v. United States Citizenship and Immigration Services

CourtCourt of Appeals for the Ninth Circuit
DecidedApril 27, 2026
Docket24-6193
StatusPublished

This text of Hanan v. United States Citizenship and Immigration Services (Hanan v. United States Citizenship and Immigration Services) 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
Hanan v. United States Citizenship and Immigration Services, (9th Cir. 2026).

Opinion

FOR PUBLICATION

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

OFIR HANAN; MELANIE No. 24-6193 GILLUM, D.C. No. 4:23-cv-02414- Plaintiffs - Appellants, HSG v.

UNITED STATES CITIZENSHIP OPINION AND IMMIGRATION SERVICES; MARKWAYNE MULLIN, Secretary, U.S. Department of Homeland Security; JOSEPH B. EDLOW, Director, U.S. Citizenship and Immigration Services; RICHARD VALEIKA, San Francisco Field Office Director, U.S. Citizenship and Immigration Services; TODD BLANCHE, Acting Attorney General; BOARD OF IMMIGRATION APPEALS,

Defendants - Appellees.

Appeal from the United States District Court for the Northern District of California Haywood S. Gilliam, Jr., District Judge, Presiding 2 HANAN V. U.S. CITIZENSHIP AND IMMIGRATION SERVICES

Argued and Submitted February 10, 2026 San Francisco, California

Filed April 27, 2026

Before: N. Randy Smith, Jacqueline H. Nguyen, and Gabriel P. Sanchez, Circuit Judges.

Opinion by Judge Nguyen

SUMMARY*

Immigration

The panel affirmed the district court’s grant of summary judgment to the government in an action in which Ofir Hanan, a citizen of Israel, and Melanie Gillum, his U.S. citizen wife, challenged the denial by U.S. Citizenship and Immigration Services (“USCIS”) of Gillum’s petition for Hanan to be classified as an immediate relative. Hanan, who had entered the United States on a tourist visa and overstayed, married Gillum in 2014. Based on the marriage, Gillum petitioned for Hanan’s immediate relative classification by filing an I-130 petition, which is a precursor to permanent residence. USCIS concluded that Hanan’s prior marriage to a different U.S. citizen was a sham, entered into for the sole purpose of obtaining benefits. USCIS thus denied Gillum’s I-130 petition under the marriage fraud bar,

* This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader. HANAN V. U.S. CITIZENSHIP AND IMMIGRATION SERVICES 3

which precludes approval of an I-130 petition if the alien had previously “attempted . . . to enter into a marriage for the purpose of evading the immigration laws.” 8 U.S.C. § 1154(c)(2). After the Board of Immigration Appeals dismissed Gillum’s appeal of the denial of the petition, Gillum and Hanan (together, “plaintiffs”) sought review of the agency’s decision in the district court, claiming violations of the Administrative Procedure Act and procedural due process. Plaintiffs contended that the marriage fraud bar in 8 U.S.C. § 1154(c) did not apply to Hanan’s first marriage because no one sought any immigration benefit for him based on that marriage. The panel held, based on the statute’s plain meaning, that the marriage fraud bar does not require that the noncitizen apply for an immigration benefit. Rather, under the statute’s unambiguous meaning, if a noncitizen attempts or conspires “to enter into a marriage for the purpose of evading the immigration laws,” then the marriage fraud bar applies. Whether the noncitizen takes any further actions, such as marrying and filing for immigration benefits, is immaterial. Plaintiffs alternatively contended that USCIS violated their procedural due process rights by relying on Hanan’s ex- wife’s statement without making her available for cross- examination. To determine whether the procedures provided to protect a liberty or property interest were constitutionally sufficient, the panel balanced the three factors set forth in Mathews v. Eldridge, 424 U.S. 319 (1976): 1) the private interest affected by the official action; 2) the risk of an erroneous deprivation of such interest through the procedures used, and the probable value of additional or substitute procedural safeguards; and 3) the 4 HANAN V. U.S. CITIZENSHIP AND IMMIGRATION SERVICES

government’s interest, including the burdens that additional or substitute procedural requirements would entail. The panel clarified the exact liberty or property interest at issue by explaining that this court held, in Ching v. Mayorkas, 725 F.3d 1149 (9th Cir. 2013), that a U.S. citizen who meets the I-130 criteria has a protected property interest in the petition’s approval because § 1154(b)’s mandatory language makes the agency’s decision nondiscretionary. Next, weighing the three Mathews factors, the panel concluded that plaintiffs received adequate process. While their property interest in having USCIS reach a correct decision on Gillum’s I-130 petition was substantial, requiring cross-examination of the ex-wife would not materially advance that interest and would impose unnecessary burdens on the agency. Lastly, the panel concluded that substantial evidence supported the agency’s decision to apply the marriage fraud bar, noting the ex-wife’s sworn statement that she made a “deal” to marry Hanan in exchange for payments, Hanan’s admission to state investigators that he paid her to marry him “in order to get a green card,” and the fact that plaintiffs’ own evidence offered very little support to their claim that the prior marriage was bona fide. HANAN V. U.S. CITIZENSHIP AND IMMIGRATION SERVICES 5

COUNSEL

Stacy Tolchin (argued) and Megan A. Brewer, Law Offices of Stacy Tolchin, Pasadena, California, for Plaintiffs- Appellants. Kelsey J. Helland (argued) and Elizabeth D. Kurlan, Assistant United States Attorneys; Pamela T. Johann, Chief, Civil Division; Patrick D. Robbins, Acting United States Attorney; Office of the United States Attorney, United States Department of Justice, San Francisco, California; for Defendants-Appellees.

OPINION

NGUYEN, Circuit Judge:

Ofir Hanan, a native and citizen of Israel, and Melanie Gillum, his U.S. citizen wife, have a bona fide marriage. But U.S. Citizenship and Immigration Services (“USCIS”) denied Gillum’s petition for Hanan to be classified as an immediate relative, the precursor to permanent residence. USCIS determined that Hanan’s prior marriage was a sham, entered into for the sole purpose of obtaining immigration benefits. Gillum and Hanan sued, arguing that the marriage fraud bar does not apply because, regardless of Hanan’s intent, neither he nor his first wife ever sought any immigration benefits based on that previous marriage. The district court granted summary judgment in favor of the government. We affirm. Hanan’s conduct fits squarely within the plain statutory language of the marriage fraud bar because he previously “attempted . . . to enter into a marriage for the 6 HANAN V. U.S. CITIZENSHIP AND IMMIGRATION SERVICES

purpose of evading the immigration laws.” 8 U.S.C. § 1154(c)(2). We also reject Hanan’s remaining arguments. Hanan received all the process he was due, and substantial evidence supports the agency’s fraud finding. The district court therefore properly granted summary judgment for the government. I. Hanan entered the United States on a tourist visa in April 2008 and stayed after his visa expired. In May 2010, he married Margarita Jaimes, his first wife. They divorced less than two years later. Although Jaimes is a U.S. citizen, neither she nor anyone else ever filed for an immigration benefit for Hanan based on that marriage. In January 2014, Hanan married Gillum, his present wife with whom he has a U.S.-citizen child. Gillum petitioned for Hanan’s immediate relative classification by filing form I-130 with USCIS, and Hanan applied to adjust his status to permanent resident.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Securities & Exchange Commission v. Chenery Corp.
318 U.S. 80 (Supreme Court, 1943)
Skidmore v. Swift & Co.
323 U.S. 134 (Supreme Court, 1944)
Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
Rubin v. United States
449 U.S. 424 (Supreme Court, 1981)
Russello v. United States
464 U.S. 16 (Supreme Court, 1983)
Connecticut National Bank v. Germain
503 U.S. 249 (Supreme Court, 1992)
United States v. Wilson
503 U.S. 329 (Supreme Court, 1992)
District of Columbia v. Heller
554 U.S. 570 (Supreme Court, 2008)
PADILLA-ROMERO v. Holder
611 F.3d 1011 (Ninth Circuit, 2010)
Campbell v. PRICEWATERHOUSECOOPERS, LLP
642 F.3d 820 (Ninth Circuit, 2011)
Teresita Ching v. Alejandro Mayorkas
725 F.3d 1149 (Ninth Circuit, 2013)
Karen Dexter v. Carolyn W. Colvin
731 F.3d 977 (Ninth Circuit, 2013)
Jose Gonzalez-Caraveo v. Jefferson Sessions
882 F.3d 885 (Ninth Circuit, 2018)
Faisal Nabin Kashem v. William Barr
941 F.3d 358 (Ninth Circuit, 2019)
P. SINGH
27 I. & N. Dec. 598 (Board of Immigration Appeals, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Hanan v. United States Citizenship and Immigration Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hanan-v-united-states-citizenship-and-immigration-services-ca9-2026.