Galvez v. Jaddou

"To determine whether the district court abused its discretion in entering the injunction, look to whether the trial court identified and applied the correct legal rule to the relief requested.” United States v. Hinkson, 585 F.3d 1247, 1263 (9th Cir. 2009).

Respondents, a class of SIJ petitioners, brought suit against Petitioners, seeking injunctive and declaratory relief for unlawfully delaying SIJ petitioners’ cases. The district court granted a permanent injunction, which held USCIS to a strict 180 day deadline, but allowed SIJ petitioners to extend Congress’s deadline to adjudicate SIJ cases. Petitioners appealed, arguing that the district court abused discretion by entering the permanent injunction and determining its terms and scope. The Court held that the district court did not abuse discretion by issuing the preliminary injunction as the Court reasoned that the district court found that the class of SIJ petitioners would suffer irreparable harm as there would be a continued delay of adjudicating their cases. However, the Court held that the district court did abuse discretion based on the terms of the permanent injunction order as to the provision that allows SIJ petitioners to toll the statutory deadline. The Court reasoned that the record does not support the reasonableness of the order as it is too broad and is not narrowly tailored to avoiding irreparable harm that the district court had previously found. The Court affirmed the district court’s issuance of injunctive relief, but vacated the SIJ petitioner tolling provision and remanded.