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The Third Circuit released its decision in Zengkui Li v. Att'y Gen. et al., No. 20-1817 (3d Cir. 2021) on February 17, 2021. On appeal from the District of New Jersey where Li sought habeas corpus relief, DHS released Li from detention while the appeal was pending. On account of his release, the Third Circuit reasoned that his petition was moot and vacated the District Court's order denying relief and remanded to that court with instructions to dismiss.
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The Third Circuit released two immigration decisions today, as far as I can tell: Paul v. Att'y Gen., No-20-1979, (3d Cir. 2021) (unpublished) and Patel v. Att'y Gen., No. 20-2018 (3d Cir. 2021) (unpublished). Focusing on Paul, a panel of Greenaway, Krause, and Bibas denied, per curiam, Paul's petition for review. The opinion reasons that Immigration Judge John B. Carle did not err in finding that Paul's proposed particular social group, "Haitian homeless," did not meet the "particularity requirement to be a cognizable social group because it was vast, diffuse, and amorphous." Id. at 4. Further, the panel found that the IJ Carle did not err in finding that Paul's experiences in Haiti did not amount to torture where he had once been involved in a violent robbery." Id. at 5.
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AuthorBrock Bevan Archives
May 2022
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