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Hui Chen v. Holder

Citation: 340 F. App'x 716Docket: No. 08-0370-ag

Court: Court of Appeals for the Second Circuit; August 6, 2009; Federal Appellate Court

Narrative Opinion Summary

Petitioner Hui Chen, a citizen of China, sought review of a December 20, 2007 order from the Board of Immigration Appeals (BIA) that denied his motion to reopen his case. The review is conducted under an abuse of discretion standard, with factual findings evaluated under the substantial evidence standard. The court found no error in the BIA's decision to deny Chen’s untimely motion, which was based on his failure to demonstrate materially changed country conditions or establish prima facie eligibility for relief. Chen's arguments were deemed insufficient, as the court referenced prior cases where similar evidence had been reviewed and found inadequate. The BIA is permitted to summarize evidence without presuming an abuse of discretion. Consequently, the court denied Chen’s petition for review, vacated any previously granted stay of removal, dismissed any pending motion for a stay as moot, and denied a request for oral argument.

Legal Issues Addressed

Denial of Petitions for Review in Immigration Cases

Application: The court can deny a petition for review if the petitioner fails to meet the necessary legal standards, vacate any stays of removal, and dismiss pending motions related to the case.

Reasoning: Consequently, the court denied Chen’s petition for review, vacated any previously granted stay of removal, dismissed any pending motion for a stay as moot, and denied a request for oral argument.

Evaluation of Evidence in Immigration Proceedings

Application: The BIA is permitted to summarize evidence without being presumed to have abused its discretion, and similar evidence in prior cases was found inadequate.

Reasoning: Chen's arguments were deemed insufficient, as the court referenced prior cases where similar evidence had been reviewed and found inadequate. The BIA is permitted to summarize evidence without presuming an abuse of discretion.

Requirements for Reopening Immigration Cases

Application: A motion to reopen an immigration case must demonstrate materially changed country conditions or establish prima facie eligibility for relief to be considered timely.

Reasoning: The court found no error in the BIA's decision to deny Chen’s untimely motion, which was based on his failure to demonstrate materially changed country conditions or establish prima facie eligibility for relief.

Standard of Review for Board of Immigration Appeals Orders

Application: The order from the Board of Immigration Appeals is reviewed under an abuse of discretion standard, and factual findings are evaluated under the substantial evidence standard.

Reasoning: The review is conducted under an abuse of discretion standard, with factual findings evaluated under the substantial evidence standard.