Vikas Patel v. Jefferson Sessions, III

CourtCourt of Appeals for the Sixth Circuit
DecidedOctober 24, 2018
Docket18-3123
StatusUnpublished

This text of Vikas Patel v. Jefferson Sessions, III (Vikas Patel v. Jefferson Sessions, III) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vikas Patel v. Jefferson Sessions, III, (6th Cir. 2018).

Opinion

NOT RECOMMENDED FOR FULL-TEXT PUBLICATION File Name: 18a0532n.06

No. 18-3123

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Oct 24, 2018 VIKAS MANUBHAI PATEL, ) DEBORAH S. HUNT, Clerk ) Petitioner, ) ) ON PETITION FOR REVIEW v. ) FROM THE UNITED STATES ) BOARD OF IMMIGRATION JEFFERSON B. SESSIONS, III, Attorney General, ) APPEALS ) Respondent. )

Before: KEITH, COOK, and LARSEN, Circuit Judges.

LARSEN, Circuit Judge. Vikas Manubhai Patel, a native and citizen of India, sought to

reopen his removal proceeding twelve years after an Immigration Judge (IJ) ordered him removed

from the United States. Patel argued that he never received notice of his removal hearing and that

changed conditions in India justified reopening the proceeding and allowing him to apply for relief

from removal. The IJ denied Patel’s motion to reopen, and the Board of Immigration Appeals

(BIA) dismissed Patel’s appeal from that decision. When Patel moved the BIA to reconsider its

dismissal, the BIA adhered. Patel now petitions this court for review of the BIA’s denial of his

motion to reconsider. Finding that the BIA did not abuse its discretion, we DENY the petition for

review.

I.

Patel entered the United States without proper documentation in July 2000. On August 18,

2004, agents of the Department of Homeland Security (DHS), acting on a report from police in

Dearborn, Michigan, apprehended Patel and one other alien at a Dearborn hotel. Patel claimed to No. 18-3123, Patel v. Sessions

be visiting from New Jersey and said he was without a passport. The DHS agents arrested Patel

and transported him to a Border Patrol station for processing. At the station, DHS agents found

Patel’s passport in the belongings of an Iraqi national who was in custody on suspicion of

document fraud and other crimes. Patel was then lodged at the Monroe County jail.

That same day, DHS agents personally served Patel with a Notice to Appear (NTA). The

NTA contains Patel’s signature and fingerprint and states that he received oral warnings in English

regarding the consequences of failing to appear at his removal hearing. DHS then commenced

removal proceedings against Patel by filing the NTA with the Detroit Immigration Court. This

filing noted that Patel was released from custody after posting a $25,000 bond and that he reported

his address as 1440 N. Dixie Hwy, Monroe, MI 48618.

On October 21, 2004, the Immigration Court sent notice by regular mail to this address,

informing Patel that his removal hearing was scheduled for November 5, 2004. Patel did not attend

the hearing, and the IJ ordered him removed in absentia. Notice of the IJ’s November 5 decision

was mailed to Patel’s only known address, but the letter was returned to the Immigration Court,

marked, “Attempted Not Known,” with the handwritten notation, “No longer here. Return to

sender. Moved.” Patel was then sent a certified letter with a copy of his removal order, but this

was also sent back, marked, “Return to sender. Refused.”

Twelve years later, in December 2016, Patel filed a motion with the Immigration Court to

reopen his removal proceeding. The motion claimed that Patel had never received notice of his

removal hearing and that changed political conditions in India warranted reopening his proceeding

so he could apply for asylum and withholding of removal. The IJ denied Patel’s motion after

determining that (1) the government had given proper notice by personally serving Patel with the

NTA and sending notice of his removal hearing to the address Patel provided; (2) Patel had failed

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to demonstrate that conditions in India had materially changed since his 2004 removal order; and

(3) Patel had failed to establish prima facie eligibility for asylum or withholding of removal. Patel

appealed this ruling to the BIA. But the BIA found that the IJ had correctly denied reopening, and

so dismissed Patel’s appeal on June 21, 2017.

Patel did not petition this court for review of the BIA’s June 2017 order. Instead, Patel

filed a motion to reconsider with the BIA, arguing, again, that he had not received adequate notice

of his removal hearing. On January 5, 2018, the BIA denied Patel’s motion. Patel timely

petitioned this court for review of the BIA’s decision.

II.

As a threshold matter, this court lacks jurisdiction to review the BIA’s June 2017 order

dismissing Patel’s appeal. To preserve appellate review of the BIA’s June 2017 order, Patel

needed to file a petition for review in this court within thirty days of that decision. See Wajda v.

Holder, 727 F.3d 457, 461 (6th Cir. 2013); 8 U.S.C. § 1252(b)(1). Patel failed to do this, and his

pursuit of further review with the agency via a motion to reconsider did not toll the thirty-day

period for seeking review of the June 2017 order. See Gor v. Holder, 607 F.3d 180, 185 (6th Cir.

2010). Therefore, the only decision properly before this court is the BIA’s January 2018 order

denying Patel’s motion to reconsider.1

We review the BIA’s denial of a motion to reconsider for an abuse of discretion. Wajda,

727 F.3d at 462. “The BIA abuses its discretion when it acts arbitrarily, irrationally or contrary to

law.” Id. (quoting Sswajje v. Ashcroft, 350 F.3d 528, 532 (6th Cir. 2003) (citation omitted)). We

have explained that “an abuse of discretion occurs if the denial ‘was made without a rational

1 The limited scope of our review means that we lack jurisdiction to review Patel’s arguments concerning changed country conditions; Patel failed to raise these arguments in his motion to reconsider, and we cannot review the BIA’s June 2017 order addressing and rejecting them.

-3- No. 18-3123, Patel v. Sessions

explanation, inexplicably departed from established policies, or rested on an impermissible basis

such as invidious discrimination against a particular race or group.’” Id. (quoting Allabani v.

Gonzales, 402 F.3d 668, 675 (6th Cir. 2005)).

The government asserts that Patel forfeited any challenge to the BIA’s denial of the motion

to reconsider because his petition for review never challenges the BIA’s rationale for its decision—

namely, that Patel’s motion did not satisfy the statutory requirements for a motion to reconsider.

A motion to reconsider “shall specify the errors of law or fact” in the BIA’s subject decision, and

it must support its claims with relevant authority. 8 U.S.C. § 1229a(c)(6)(C); 8 C.F.R.

§ 1003.2(b)(1). The BIA denied Patel’s motion because it “largely raises the same or similar

arguments . . . as were raised in his prior appeal brief.” And the BIA explained that it had “fully

considered those arguments and found them unpersuasive when [it] dismissed the respondent’s

appeal.” See also Matter of O-S-G-, 24 I. & N. Dec. 56, 58 (B.I.A. 2006) (stating that a motion to

reconsider “is not a process by which a party may submit, in essence, the same brief presented on

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Related

Gor v. Holder
607 F.3d 180 (Sixth Circuit, 2010)
Sanchez v. Holder
627 F.3d 226 (Sixth Circuit, 2010)
Aragon-Munoz v. Mukasey
520 F.3d 82 (First Circuit, 2008)
Gerald Sswajje v. John Ashcroft, Attorney General
350 F.3d 528 (Sixth Circuit, 2003)
Ahmed Abdullah Allabani v. Alberto Gonzales
402 F.3d 668 (Sixth Circuit, 2005)
Mark Wajda v. Eric Holder, Jr.
727 F.3d 457 (Sixth Circuit, 2013)
O-S-G
24 I. & N. Dec. 56 (Board of Immigration Appeals, 2006)
M-S
22 I. & N. Dec. 349 (Board of Immigration Appeals, 1998)
Singh v. Holder
749 F.3d 622 (Seventh Circuit, 2014)

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