Lopez-Avila v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedAugust 1, 2025
Docket23-6810
StatusUnpublished

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

Bluebook
Lopez-Avila v. Bondi, (2d Cir. 2025).

Opinion

23-6810 Lopez-Avila v. Bondi BIA Auh, IJ A098 122 506

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 1st day of August, two thousand twenty-five.

PRESENT: DEBRA ANN LIVINGSTON, Chief Judge, EUNICE C. LEE, ALISON J. NATHAN, Circuit Judges. _____________________________________

FRANCISCO ISAIAS LOPEZ-AVILA, Petitioner,

v. 23-6810 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. _____________________________________

FOR PETITIONER: Bruno J. Bembi, Hempstead, NY. FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant Attorney General; Cindy S. Ferrier, Assistant Director; Brendan P. Hogan, Attorney, Office of Immigration Litigation, United States Department of Justice, Washington, DC.

UPON DUE CONSIDERATION of this petition for review of a Board of

Immigration Appeals (“BIA”) decision, it is hereby ORDERED, ADJUDGED, AND

DECREED that the petition for review is DENIED.

Petitioner Francisco Isaias Lopez-Avila, a native and citizen of El Salvador,

seeks review of a July 10, 2023, decision of the BIA affirming a December 8, 2022,

decision of an Immigration Judge (“IJ”) denying both his motion to terminate

proceedings and his application for relief under the Convention Against Torture

(“CAT”). In re Francisco Isaias Lopez-Avila, No. A098 122 506 (B.I.A. July 10, 2023),

aff’g No. A098 122 506 (Immigr. Ct. Napanoch Dec. 8, 2022). We assume the

parties’ familiarity with the underlying facts, procedural history, and issues on

appeal to which we refer only as necessary to explain our decision.

We have reviewed the IJ’s decision as modified by the BIA. See Xue Hong

Yang v. U.S. Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005). Where, as here, a

petitioner was ordered removed for crimes involving moral turpitude and for

separate offenses for which the aggregate sentence exceeded five years’

imprisonment, our jurisdiction is generally limited to constitutional claims and

2 questions of law. See 8 U.S.C. 1252(a)(2)(C)–(D). However, this limitation does

not apply to the review of CAT claims. See Nasrallah v. Barr, 590 U.S. 573, 581

(2020).

I. Federal Rule of Appellate Procedure 28

As an initial matter, we note that Lopez-Avila’s operative brief does not

comply with Federal Rule of Appellate Procedure 28 or this Court’s February 26,

2024, order directing counsel to re-file his brief with adequate citations. Although

a failure to comply with Rule 28 may result in dismissal of an appeal or petition

without review of the merits, we address the merits here so as not to unfairly

penalize Lopez-Avila for his counsel’s deficient performance. See Taylor v.

Harbour Pointe Homeowners Ass’n, 690 F.3d 44, 48 (2d Cir. 2012). Counsel is

cautioned that future briefing deficiencies will be grounds for dismissal without

consideration of the merits and may result in discipline. 1

II. Motion to Terminate

Lopez-Avila first argues that the agency erred in denying his motion to

terminate proceedings on the ground that he was improperly served with the

notice to appear (“NTA”) when he was a minor. We disagree.

Counsel is also cautioned that a brief in this Court must do more than simply repeat the arguments raised 1

before the BIA. See Shunfu Li v. Mukasey, 529 F.3d 141, 146 (2d Cir. 2008) (“[F]iling of such an inadequate submission will be grounds not only for rejection of the brief but for formal reprimand or other sanction.”). 3 Under 8 U.S.C. § 1229(a)(1), an NTA must specify, inter alia, the “nature of

the proceedings,” the “time and place at which the proceedings will be held,” the

“acts or conduct alleged to be in violation of law,” and “the charges . . . and the

statutory provisions alleged to have been violated.” “[I]f an alien receives notice

of this information and a meaningful opportunity to participate in h[is] removal

proceedings, due process is satisfied.” Nolasco v. Holder, 637 F.3d 159, 163 (2d Cir.

2011).

We discern no error with the agency’s determination that Lopez-Avila

received adequate notice. Lopez-Avila—who entered the United States as an

unaccompanied minor—received an NTA while in the care of a conservator. A

copy was then provided to his father shortly thereafter. Additionally, an I-770

“Notice of Rights and Dispositions” for unaccompanied minors was read to

Lopez-Avila in Spanish. But even assuming arguendo that there was an error in

informing Lopez-Avila of his rights, he has not established a due process violation.

Lopez-Avila attended his hearings, he was represented by counsel, he had the

opportunity to testify and present evidence, and his application for relief was

addressed on the merits.

We are not persuaded by Lopez-Avila’s argument that the agency failed to

consider his mental illness in determining whether the notice was sufficient. 4 Lopez-Avila’s removal proceedings were initiated in 2004, long before the onset

of his mental health issues in 2015. And once notified of Lopez-Avila’s mental

health condition, the IJ ruled on competency and adopted safeguards suggested

by the parties.

III. CAT Relief

Lopez-Avila has also not established error in the agency’s denial of his CAT

claim. We review the agency’s factual findings for substantial evidence, and

questions of law and application of law to undisputed fact de novo. See Yanqin

Weng v. Holder, 562 F.3d 510, 513 (2d Cir. 2009). “A determination of what will

occur in the future and the degree of likelihood of the occurrence has been

regularly regarded as fact-finding,” Hui Lin Huang v. Holder, 677 F.3d 130, 134 (2d

Cir. 2012), and “administrative findings of fact are conclusive unless any

reasonable adjudicator would be compelled to conclude to the contrary,” 8 U.S.C.

§ 1252(b)(4)(B).

A CAT applicant has the burden to establish that he will “more likely than

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Related

Shunfu Li v. Mukasey
529 F.3d 141 (Second Circuit, 2008)
Hui Lin Huang v. Holder
677 F.3d 130 (Second Circuit, 2012)
Suzanne Taylor v. Harbour Pointe Homeowners Ass’n
690 F.3d 44 (Second Circuit, 2012)
Weng v. Holder
562 F.3d 510 (Second Circuit, 2009)
Savchuck v. Mukasey
518 F.3d 119 (Second Circuit, 2008)
Nolasco v. Holder
637 F.3d 159 (Second Circuit, 2011)
Nasrallah v. Barr
590 U.S. 573 (Supreme Court, 2020)
Zelaya-Moreno v. Wilkinson
989 F.3d 190 (Second Circuit, 2021)
J-F-F
23 I. & N. Dec. 912 (Board of Immigration Appeals, 2006)
Suzhen Meng v. Holder
770 F.3d 1071 (Second Circuit, 2014)

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