Figueroa Ochoa v. Garland

“[N]o court shall have jurisdiction to review . . . any judgment regarding the granting of relief under” immigration laws governing the cancellation of removal and adjustment of status. 8 U.S.C. § 1252(a)(2)(B)(i). “Judgment,” interpreted as “any authoritative decision,” “is the only [interpretation] that fits § 1252(a)(2)(B)(i)’s text and context.” Patel v. Garland, 142 S. Ct. 1614, 1622 (2022).

Figueroa Ochoa was denied cancellation of removal and adjustment of status based on the immigration judge’s factual findings regarding his criminal history. He contended that because his conviction in 1999 actually belonged to his brother, and because he asked the state court to vacate his 2000 conviction, he was eligible for relief. Figueroa Ochoa appealed the BIA’s affirming decision, arguing that the agency erred by attributing the 1999 conviction to him in denying his relief. “[N]o court shall have jurisdiction to review . . . any judgment regarding the granting of relief under” immigration laws governing the cancellation of removal and adjustment of status. 8 U.S.C. § 1252(a)(2)(B)(i). “Judgment,” interpreted as “any authoritative decision,” “is the only [interpretation] that fits § 1252(a)(2)(B)(i)’s text and context.” Patel v. Garland, 142 S. Ct. 1614, 1622 (2022). The Court found that the immigration judge answered a factual inquiry as to whether Figueroa Ochoa was convicted in 1999 without conducting any legal analysis, therefore this decision was a “judgment” within the meaning of the statute. The Court thus lacked jurisdiction to review the decision as Figueroa Ochoa requested under § 1252(a)(2)(B)(i). Petition dismissed.