Md Uddin v. Todd Blanche

CourtCourt of Appeals for the Fourth Circuit
DecidedJune 5, 2026
Docket24-1067
StatusPublished

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

Bluebook
Md Uddin v. Todd Blanche, (4th Cir. 2026).

Opinion

USCA4 Appeal: 24-1067 Doc: 83 Filed: 06/05/2026 Pg: 1 of 14

PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-1067

MD FARID UDDIN,

Petitioner,

v.

TODD BLANCHE, Acting Attorney General,

Respondent.

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

Argued: March 19, 2026 Decided: June 5, 2026

Before WILKINSON, RICHARDSON, and HEYTENS, Circuit Judges.

Petition denied in part and dismissed in part by published opinion. Judge Richardson wrote the opinion, in which Judges Wilkinson and Heytens joined.

ARGUED: Jackson Erpenbach, HECKER FINK LLP, Washington, D.C., for Petitioner. Imran Raza Zaidi, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Respondent. ON BRIEF: Joshua A. Matz, HECKER FINK LLP, Washington, D.C., for Petitioner. Brett A. Shumate, Assistant Attorney General, Lindsay B. Glauner, Melissa K. Lott, Office of Immigration Litigation, Civil Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Respondent. USCA4 Appeal: 24-1067 Doc: 83 Filed: 06/05/2026 Pg: 2 of 14

RICHARDSON, Circuit Judge:

New Jersey criminalizes knowingly storing or maintaining child sexual abuse

material on a file-sharing program that makes the material available for searching or

copying by other computers. That conduct creates a reasonable probability that the

material will circulate and injure the children depicted. So the offense categorically

qualifies as a crime of child abuse under the Immigration and Nationality Act.

I. BACKGROUND

Md Farid Uddin, a Bangladeshi native and Canadian citizen, was a lawful

permanent resident living in New Jersey. In 2018, he was indicted for distributing, storing,

and possessing sexually explicit images of children in violation of New Jersey law. In

2019, he pleaded guilty to one count under N.J. Stat. Ann. § 2C:24-4(b)(5)(a)(iii): Between

August 1, 2017, and November 2, 2017, he “knowingly store[d] or

maintain[ed] . . . twenty-five (25) or more items depicting the sexual exploitation or abuse

of a child . . . using a file-sharing program which was designated as available for searching

by or copying to one or more other computers.” J.A. 303. Uddin was sentenced and

required to register as a sex offender.

After Uddin served his sentence, U.S. Immigration and Customs Enforcement

detained him in Pennsylvania, and the Department of Homeland Security initiated removal

proceedings. The government charged Uddin with removability under the Immigration

2 USCA4 Appeal: 24-1067 Doc: 83 Filed: 06/05/2026 Pg: 3 of 14

and Nationality Act for (1) an “aggravated felony,” specifically the “sexual abuse of a

minor,” 1 and (2) “a crime of child abuse, child neglect, or child abandonment.” 2

An immigration judge in Richmond, Virginia, found him removable because his

statute of conviction categorically matched a crime of child abuse. The IJ also denied

Uddin’s applications for cancellation of removal 3 and adjustment of status with a waiver

of inadmissibility 4 “as a matter of discretion.” J.A. 56. Uddin appealed, contesting the IJ’s

removability finding and the IJ’s discretionary denials of his applications. The Board of

Immigration Appeals issued its own opinion affirming removability and adopted the IJ’s

discretionary rulings. Uddin petitioned for review in this Court. 5

II. UDDIN’S CONVICTION QUALIFIES AS A CRIME OF CHILD ABUSE

We review de novo whether Uddin’s conviction qualifies as a crime of child abuse.

Herrera-Alcala v. Garland, 39 F.4th 233, 244 (4th Cir. 2022). 6

1 8 U.S.C. §§ 1227(a)(2)(A)(iii), 1101(a)(43)(A). 2 8 U.S.C. § 1227(a)(2)(E)(i). 3 8 U.S.C. § 1229b(a). 4 8 U.S.C. §§ 1255(a), 1182(h). 5 The IJ’s physical location controls venue. Herrera-Alcala v. Garland, 39 F.4th 233, 242–43 (4th Cir. 2022) (citing 8 U.S.C. § 1252(b)(2)). As the IJ sat in Virginia, venue is proper in this Court, and we apply Fourth Circuit law. Id. 6 Because the Board affirmed the IJ’s decision with its own opinion, we review both decisions, considering the IJ’s only to the extent the Board adopted or incorporated it. Herrera-Alcala, 39 F.4th at 244; Garcia Hernandez v. Garland, 27 F.4th 263, 266 n.* (4th Cir. 2022). The Board did not adopt the IJ’s reasoning on whether the conviction categorically qualifies. So our review focuses on the Board’s decision. 3 USCA4 Appeal: 24-1067 Doc: 83 Filed: 06/05/2026 Pg: 4 of 14

Under the INA, removability turns on the “nature” of a conviction, not the “actual

conduct.” Esquivel-Quintana v. Sessions, 581 U.S. 385, 389 (2017). The categorical

approach therefore asks whether the minimum conduct criminalized by the statute qualifies

as a crime of child abuse under the INA. Cruz v. Garland, 101 F.4th 361, 364 (4th Cir.

2024). This inquiry is not an exercise in “legal imagination.” Thompson v. Barr, 922 F.3d

528, 531 (4th Cir. 2019) (quoting Gonzales v. Duenas-Alvarez, 549 U.S. 183, 193 (2007)).

To show the New Jersey statute is not a categorical match, there must be a “realistic

probability, not a theoretical possibility, that the State would apply its statute to” the

asserted minimum conduct. Duenas-Alvarez, 549 U.S. at 193.

A. The Categorical Approach Applies To The State Statute As It Stood At The Time Of The Criminal Conduct

We must first answer a threshold question: Which version of state law governs

when the statute at the time of the conduct differs from the statute at the time of the

conviction? The difference matters because a 2018 amendment added material later held

overbroad. Uddin was indicted for and convicted of conduct that occurred between August

1, 2017, and November 2, 2017. At that time, New Jersey narrowly defined the prohibited

That does not mean, however, that we must remand if the Board’s legal reasoning differs from ours. Whether a conviction categorically matches a removable offense is a legal question that we review de novo. Cucalon v. Barr, 958 F.3d 245, 252 n.3 (4th Cir. 2020). And where the only question is one of law, Chenery does not require a pointless remand. Id.; see also NLRB v. Wyman-Gordon Co., 394 U.S. 759, 766 n.6 (1969) (plurality). We thus may sustain the Board’s result on the correct legal rationale—including a rationale also given by the IJ—so long as doing so does not require us to make factual findings, exercise discretion, or supply a policy judgment committed to the agency. See SEC v. Chenery Corp., 318 U.S. 80, 88 (1943); Calcutt v. FDIC, 598 U.S. 623, 629–30 (2023); Morgan Stanley Cap. Grp. Inc. v. Pub. Util. Dist. No. 1, 554 U.S. 527, 544–45 (2008); FDA v. Wages & White Lion Invs., LLC, 604 U.S. 542, 589 (2025).

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)
National Labor Relations Board v. Wyman-Gordon Co.
394 U.S. 759 (Supreme Court, 1969)
New York v. Ferber
458 U.S. 747 (Supreme Court, 1982)
Carmell v. Texas
529 U.S. 513 (Supreme Court, 2000)
Ashcroft v. Free Speech Coalition
535 U.S. 234 (Supreme Court, 2002)
Gonzales v. Duenas-Alvarez
549 U.S. 183 (Supreme Court, 2007)
United States v. Hotaling
634 F.3d 725 (Second Circuit, 2011)
Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd.
545 U.S. 913 (Supreme Court, 2005)
Gomis v. Holder
571 F.3d 353 (Fourth Circuit, 2009)
Stephen Shoemaker v. Robert Taylor
730 F.3d 778 (Ninth Circuit, 2013)
State v. May
829 A.2d 1106 (New Jersey Superior Court App Division, 2003)
State v. Lyons
9 A.3d 596 (New Jersey Superior Court App Division, 2010)
Paroline v. United States
134 S. Ct. 1710 (Supreme Court, 2014)
United States v. Jeffrey Anderson
759 F.3d 891 (Eighth Circuit, 2014)
Cesar Munoz-Ruvalcaba v. Eric Holder, Jr.
585 F. App'x 387 (Ninth Circuit, 2014)
State v. Richard Perez (072624)
106 A.3d 1212 (Supreme Court of New Jersey, 2015)
United States v. Gregory McLeod
808 F.3d 972 (Fourth Circuit, 2015)
United States v. Christopher Weast
811 F.3d 743 (Fifth Circuit, 2016)
United States v. Titties
852 F.3d 1257 (Tenth Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Md Uddin v. Todd Blanche, Counsel Stack Legal Research, https://law.counselstack.com/opinion/md-uddin-v-todd-blanche-ca4-2026.