Salazar-Asencio v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedJune 9, 2025
Docket24-1230
StatusUnpublished

This text of Salazar-Asencio v. Bondi (Salazar-Asencio 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
Salazar-Asencio v. Bondi, (2d Cir. 2025).

Opinion

24-1230 Salazar-Asencio v. Bondi BIA Drucker, IJ A220 321 020/021/028/029

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 9th day of June, two thousand twenty- five.

PRESENT: JON O. NEWMAN, RICHARD J. SULLIVAN, SARAH A. L. MERRIAM, Circuit Judges. _____________________________________

DIEGO SALAZAR-ASENCIO, ERMINIA MADAI HENRIQUEZ-SALAZAR, DIEGO SALAZAR-HENRIQUEZ, HAZEL SALAZAR-HENRIQUEZ,

Petitioners,

v. 24-1230 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL,

Respondent. _____________________________________

FOR PETITIONER: Rosemarie A. Barnett, Law Office of Rosemarie Barnett, PLLC, Freeport, NY.

FOR RESPONDENT: Brian M. Boynton, Principal Deputy Assistant Attorney General; Erica B. Miles, Assistant Director; Vanessa M. Otero, Senior Litigation Counsel, 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.

Petitioners Diego Salazar-Asencio, Erminia Madai Henriquez-Salazar, and

two of their minor children, natives and citizens of El Salvador, seek review of a

decision of the BIA denying their motion to reopen their removal proceedings. See

In re Salazar-Asencio, Nos. A220 321 020/021/028/029 (B.I.A. Apr. 5, 2024).

Petitioners also move for a stay of removal pending adjudication of this petition.

We assume the parties’ familiarity with the underlying facts and procedural

2 history.

We review the BIA’s denial of a motion to reopen for abuse of discretion,

Jian Hui Shao v. Mukasey, 546 F.3d 138, 168–69 (2d Cir. 2008), and we review a

petitioner’s constitutional claims and questions of law, including claims of

ineffective assistance of counsel, de novo, see Luna v. Holder, 637 F.3d 85, 102 (2d Cir.

2011).

A “motion to reopen shall state the new facts that will be proven at a hearing

to be held if the motion is granted, and shall be supported by affidavits or other

evidentiary material.” 8 U.S.C. § 1229a(c)(7)(B). In this case, the motion to reopen

was based on an assertion of ineffective assistance of counsel. A movant raising

an ineffective assistance of counsel claim must first comply with specific

procedural requirements set forth in Matter of Lozada, 19 I. & N. Dec. 637 (B.I.A.

1988). See Jian Yun Zheng v. U.S. Dep’t of Just., 409 F. 3d 43, 45 (2d Cir. 2005) (“[A]n

alien who has failed to comply substantially with the Lozada requirements in her

motion to reopen before the BIA forfeits her ineffective assistance of counsel claim

in this Court.”). Then, “[t]o demonstrate ineffective assistance of counsel, [a

movant] must show that counsel’s performance fell below an objective standard

3 of reasonableness and that he was prejudiced as a result of such deficient

performance.” Paucar v. Garland, 84 F.4th 71, 80 (2d Cir. 2023) (internal quotation

marks omitted).

Salazar-Asencio alleged that his former counsel failed to (1) keep in contact

with him or explain the strength of his case, (2) prepare him for his merits hearing

or explain why he would not be testifying, (3) submit updated country conditions

that would show El Salvador is still dangerous, (4) apply to the Department of

Homeland Security for prosecutorial discretion despite stating he would and

despite having Salazar-Asencio provide all documents to support such a request,

(5) file a brief to the BIA even though he was retained to do so, and (6) file a motion

to reopen as he had promised after the BIA dismissed Salazar-Asencio’s petition

for failure to file a brief.

The BIA did not err in finding that Salazar-Asencio fulfilled the Lozado

requirements only as to his claim regarding the failure to file a brief. He was

required to submit proof that “former counsel [was] informed of the allegations

and allowed the opportunity to respond.” Lozada 19 I. & N. Dec. at 639. Here,

Salazar-Asencio provided an affidavit stating that he filed a complaint with a New

4 York attorney grievance committee, see Cert. Admin. R. at 52, and that complaint

listed all six of his allegations of ineffective assistance, see id. at 126–28. However,

Salazar-Asencio did not attest that he served that complaint on former counsel, or

that counsel had an opportunity to respond to the allegations. Cf. Avendano Bonilla

v. McHenry, No. 23-7487, 2025 WL 313863, at *2 (2d Cir. Jan. 28, 2025) (Petitioner

“did not comply with the Lozada requirements because, while he filed a grievance

in New York with the Third Department’s Attorney Grievance Committee, he did

not inform his former counsel of his allegations or give her the opportunity to

respond.”).

Furthermore, the email from Salazar-Asencio’s current counsel to his former

counsel purporting to summarize their conversation discussing the claim of

ineffective assistance mentions only that they discussed the failure to file a brief

with the BIA. Salazar-Asencio’s argument that the BIA should have allowed him

to file an affirmation that his current counsel discussed all claims of ineffectiveness

with his former counsel is unpersuasive as there is no such affirmation in the

record or evidence that one exists. See 8 U.S.C. § 1252(b)(4)(A) (“[T]he court of

appeals shall decide the petition only on the administrative record on which the

5 order of removal is based.”). In sum, because there is no evidence that former

counsel knew of any allegations of ineffective assistance of counsel except his

failure to file a brief to the BIA, the BIA did not err in declining to consider the

other allegations. See Lozada 19 I. & N. Dec. at 639; see also Jian Yun Zheng, 409 F.3d

at 45.

We find no error in the BIA’s conclusion that Salazar-Asencio failed to

establish prejudice from former counsel’s failure to file a brief on appeal to the

BIA. In order to establish ineffective assistance on the part of his former attorney,

Salazar-Asencio had to “show that, but for counsel’s unprofessional errors, there

is a reasonable probability the [agency] would have granted the relief [he]

requested.” Paucar, 84 F.4th at 80 (internal quotation marks omitted). A

reasonable probability “is demonstrated where a movant makes a prima facie

showing that, but for counsel’s ineffectiveness, he would have been eligible for

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Related

Jian Hui Shao v. Mukasey
546 F.3d 138 (Second Circuit, 2008)
Luna v. Holder
637 F.3d 85 (Second Circuit, 2011)
Rashid v. Mukasey
533 F.3d 127 (Second Circuit, 2008)
LOZADA
19 I. & N. Dec. 637 (Board of Immigration Appeals, 1988)
Paucar v. Garland
84 F.4th 71 (Second Circuit, 2023)

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