Zhang v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 29, 2026
Docket24-2711
StatusUnpublished

This text of Zhang v. Bondi (Zhang 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
Zhang v. Bondi, (2d Cir. 2026).

Opinion

24-2711 Zhang v. Bondi BIA A073 558 141

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 29th day of January, two thousand twenty-six.

PRESENT: RAYMOND J. LOHIER, JR., WILLIAM J. NARDINI, EUNICE C. LEE, Circuit Judges. _____________________________________

YING ZHANG, Petitioner,

v. 24-2711 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. _____________________________________ FOR PETITIONER: Margaret W. Wong, Margaret W. Wong & Associates, Cleveland, OH.

FOR RESPONDENT: Brett A. Shumate, Assistant Attorney General; Colin J. Tucker, Senior Litigation Counsel; Nancy D. Pham, Trial 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 Ying Zhang, a native and citizen of the People’s Republic of

China, seeks review of a September 20, 2024 decision of the BIA denying her

motion for reconsideration of the denial of her third motion to reopen. In re Ying

Zhang, No. A 073 558 141 (B.I.A. Sept. 20, 2024). We assume the parties’ familiarity

with the underlying facts and procedural history.

Our review is limited to the BIA’s denial of reconsideration. See Kaur v. BIA,

413 F.3d 232, 233 (2d Cir. 2005). A motion for reconsideration “shall specify the

errors of law or fact in the previous order.” 8 U.S.C. § 1229a(c)(6)(A); see Jin Ming

Liu v. Gonzales, 439 F.3d 109, 111 (2d Cir. 2006) (“A motion for reconsideration is a

request that the Board reexamine its decision in light of additional legal

2 arguments, a change of law, or perhaps an argument or aspect of the case which

was overlooked.” (internal quotation marks omitted)). We review the denial of

such a motion for abuse of discretion. Jian Hui Shao v. Mukasey, 546 F.3d 138, 173

(2d Cir. 2008). The agency “abuses this discretion if it acts in an arbitrary or

capricious manner, or if its decision provides no rational explanation, inexplicably

departs from established policies, is devoid of any reasoning, or contains only

summary or conclusory statements.” Poradisova v. Gonzales, 420 F.3d 70, 77 (2d Cir.

2005) (internal quotation marks omitted).

Zhang sought reconsideration of the denial of her 2018 motion to reopen to

apply for cancellation of removal as a nonpermanent resident. 1 As the BIA found,

and Zhang does not dispute, her 2018 motion was untimely and number-barred

because it was her third motion and she filed it more than a decade after her

1Zhang’s reconsideration motion also argued that she should have an opportunity to apply for adjustment of status or cancellation of removal for permanent residents, or that the proceedings should be terminated for lack of jurisdiction; she does not raise those claims here. Thus, we consider those claims abandoned. See Debique v. Garland, 58 F.4th 676, 684 (2d Cir. 2023). In addition, the jurisdictional argument she pressed before the agency is foreclosed. See Cupete v. Garland, 29 F.4th 53, 57 (2d Cir. 2022) (holding that a notice to appear that omits hearing information is sufficient to vest jurisdiction in the immigration court if the omitted information is later provided).

3 removal order became final in October 2006. See 8 U.S.C. §§ 1101(a)(47)(B)(ii)

(order of removal becomes final upon the expiration of the time to appeal to the

BIA), 1229a(c)(7)(A), (C)(i) (permitting one motion to reopen filed within 90 days

of final order of removal). A motion to reopen to apply for cancellation of removal

does not fall into a statutory or regulatory exception to the time limitation. See id.

§ 1229a(c)(7)(C) (listing exceptions); 8 C.F.R. § 1003.2(c)(3) (same).

Equitable tolling may excuse these requirements, but only if the movant

demonstrates that an “extraordinary circumstance,” Doe v. United States, 76 F.4th

64, 71 (2d Cir. 2023) (internal quotation marks omitted), such as ineffective

assistance of counsel or “fraud or concealment of the existence of a claim

prevent[ed the movant] from timely filing,” Iavorski v. INS, 232 F.3d 124, 133–34

(2d Cir. 2000). 2 Zhang did not show error in the BIA’s denial of equitable tolling.

To be eligible to apply for cancellation of removal, a non-permanent

resident, like Zhang, must have 10 years of continuous physical presence in the

United States and demonstrate that her removal would result in “exceptional and

2 To the extent that Zhang argues that she is entitled to equitable tolling of the 30- day period to move for reconsideration of the BIA’s 2018 decision, her argument is misplaced because the BIA did not deny her reconsideration motion as untimely. 4 extremely unusual hardship” to a qualifying relative such as a U.S.-citizen spouse

or child. 8 U.S.C. § 1229b(b)(1)(A), (D). In Pereira v. Sessions, the Supreme Court

held that a notice to appear must include the hearing time and place to trigger the

“stop-time rule,” 585 U.S. 198, 208–19 (2018), which cuts off the accrual of physical

presence, see 8 U.S.C. § 1229b(b), (d)(1). Then, in Niz-Chavez v. Garland, the

Supreme Court held that, for purposes of this “stop-time” rule for calculating

presence, a subsequent hearing notice is insufficient to cure the defect in the notice

to appear. 593 U.S. 155, 160–71 (2021).

Accordingly, because Zhang’s notice to appear omitted the initial hearing

information, it did not stop her accrual of presence. However, as the BIA found

and Zhang does not dispute, she was ineligible for cancellation of removal during

her 2006 removal proceedings or the 90-day period for reopening thereafter

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Related

Jian Hui Shao v. Mukasey
546 F.3d 138 (Second Circuit, 2008)
Sukhraj Kaur v. Board of Immigration Appeals
413 F.3d 232 (Second Circuit, 2005)
Jin Ming Liu v. Alberto R. Gonzales, 1
439 F.3d 109 (Second Circuit, 2006)
Pereira v. Sessions
585 U.S. 198 (Supreme Court, 2018)
Cupete v. Garland
29 F.4th 53 (Second Circuit, 2022)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)
Doe v. United States
76 F.4th 64 (Second Circuit, 2023)

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