Sahin v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedSeptember 11, 2025
Docket23-8043
StatusUnpublished

This text of Sahin v. Bondi (Sahin 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
Sahin v. Bondi, (2d Cir. 2025).

Opinion

23-8043-ag Sahin v. Bondi 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.

1 At a stated term of the United States Court of Appeals for the Second Circuit, held at the 2 Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 3 11th day of September, two thousand twenty-five. 4 5 Present: 6 DEBRA ANN LIVINGSTON, 7 Chief Judge, 8 JOSÉ A. CABRANES, 9 BARRINGTON D. PARKER, 10 Circuit Judges. 11 _____________________________________ 12 13 DERVIS ERDEM SAHIN, 14 15 Petitioner, 16 17 v. 23-8043-ag 18 19 PAMELA BONDI, UNITED STATES ATTORNEY 20 GENERAL, 21 22 Respondent. 23 _____________________________________ 24 25 For Petitioner: ADAM SEIGEL (Estelle M. McKee, Yubin Oh, on the 26 brief), Cornell Law School, Ithaca, NY; Jillian Nowak, 27 Prisoners’ Legal Services of New York, Buffalo, NY. 28 29 For Respondent: JESSICA D. STROKUS, Office of Immigration Litigation 30 (Anthony C. Payne, Assistant Director, on the brief), for 31 Brian M. Boynton, Principal Deputy Assistant Attorney 32 General, Civil Division, United States Department of 33 Justice, Washington, D.C.

1 1 UPON DUE CONSIDERATION of this petition for review of a Board of Immigration

2 Appeals (“BIA”) decision, it is hereby ORDERED, ADJUDGED, AND DECREED that the

3 petition for review is DENIED.

4 Petitioner Dervis Erdem Sahin seeks review of a November 28, 2023, decision of the BIA

5 affirming a July 14, 2023, decision of an Immigration Judge (“IJ”) denying asylum, withholding

6 of removal, and relief under the Convention Against Torture. In re Dervis Erdem Sahin, No.

7 A 246 915 301 (B.I.A. Nov. 28, 2023), aff’g No. A 246 915 301 (Immig. Ct. Buffalo July 14,

8 2023). On appeal, Sahin charges that the IJ failed to comply with the agency’s regulations when

9 the IJ denied him a reasonable opportunity to review a State Department Country Report, Montilla

10 v. INS, 926 F.2d 162 (2d Cir. 1991), and that the IJ failed to investigate his competency, Matter of

11 M-A-M-, 25 I. & N. Dec. 474 (B.I.A. 2011). We assume the parties’ familiarity with the

12 underlying facts, the procedural history of the case, and the issues on appeal, which we reference

13 only as necessary to explain our decision to DENY the petition for review.

14 A. Failure to Comply with Regulations

15 We review Sahin’s challenge to the IJ’s failure to comply with the agency’s regulations de

16 novo. See Gjerjaj v. Holder, 691 F.3d 288, 292 (2d Cir. 2012). The Fifth Amendment “protects

17 aliens in deportation proceedings from procedures that transgress the fundamental notions of ‘fair

18 play’” inherent to due process. Rajah v. Mukasey, 544 F.3d 427, 441 (2d Cir. 2008) (citing

19 Montilla, 926 F.2d at 164). Ordinarily, to show a due process violation, a noncitizen must

20 demonstrate prejudice. Garcia-Villeda v. Mukasey, 531 F.3d 141, 149 (2d Cir. 2008); Montilla,

21 926 F.2d at 167. However, a petitioner is not required to “make a showing of prejudice before

22 he is entitled to relief” upon showing that 1) the agency failed to follow its own regulation, and 2)

23 that regulation concerned fundamental rights derived from the Constitution or federal statute. See

2 1 Montilla, 926 F.2d at 166–170; Rajah, 544 F.3d at 446; Waldron v. INS, 17 F.3d 511, 518 (2d Cir.

2 1993).

3 Here, Sahin claims remand is warranted under Montilla because the IJ violated 8 C.F.R.

4 § 1240.10(a)(4) when it gave him only five minutes to review a State Department Country Report

5 after he informed the IJ that he had not received it. We disagree. The regulation Sahin points

6 to requires an IJ to “advise” an individual in removal proceedings that he “will have a reasonable

7 opportunity to examine and object to the evidence against him.” 8 C.F.R. § 1240.10(a)(4). The

8 IJ did precisely that on April 5, 2023. Because the IJ did not violate this regulation, Sahin’s

9 Montilla challenge fails. See Aquino v. Att'y Gen., 53 F.4th 761, 767 (3d Cir. 2022).

10 Montilla does not compel a different result. In Montilla, the IJ informed the noncitizen

11 of his right to an attorney but did not comply with the part of the regulation that required the IJ to

12 elicit an answer from him on the spot. 8 C.F.R. § 1240.10(a)(1) (requiring an IJ to advise the

13 noncitizen of their right to representation and requiring the noncitizen to state on the record “then

14 and there” whether he or she desires it); Montilla, 926 F.2d at 169; see also Picca v. Mukasey, 512

15 F.3d 75, 79 (2d Cir. 2008). But 8 C.F.R. § 1240.10(a)(4) has no language imposing a similar

16 requirement that the IJ affirmatively verify whether a respondent wishes to invoke their right of

17 reasonable review or to enforce that right on the respondent’s behalf. We therefore reject Sahin’s

18 attempts to argue that 8 C.F.R. § 1240.10(a)(4) encompasses an obligation for the IJ either to

19 determine whether a respondent wishes to invoke the right to have a reasonable opportunity to

20 examine and object to the evidence against him or to enforce that right on behalf of the respondent.

21 The onus is instead on a respondent to invoke and enforce that right. A respondent’s failure to

22 do so does not constitute a violation of the regulation by the IJ.

3 1 B. Failure to Investigate Competency

2 A noncitizen is “presumed to be competent to participate in removal proceedings.” M-A-

3 M-, 25 I. & N. Dec. at 477. “Absent indicia of mental incompetency,” an IJ has no obligation to

4 analyze a noncitizen’s competency. Id. A noncitizen is competent to participate in immigration

5 proceedings where “he or she has a rational and factual understanding of the nature and object of

6 the proceedings, can consult with the attorney or representative if there is one, and has a reasonable

7 opportunity to examine and present evidence and cross-examine witnesses.” Id. at 479. “When

8 there are indicia of incompetency, an [IJ] must take measures to determine whether a respondent

9 is competent to participate in proceedings.” Id. at 480–81.

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Related

Rajah v. Mukasey
544 F.3d 427 (Second Circuit, 2008)
United States v. Larry Joe Ramacci
15 F.3d 75 (Seventh Circuit, 1994)
Gjerjaj v. Holder
691 F.3d 288 (Second Circuit, 2012)
Garcia-Villeda v. Mukasey
531 F.3d 141 (Second Circuit, 2008)
M-A-M
25 I. & N. Dec. 474 (Board of Immigration Appeals, 2011)

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