Villa-Loja v. Bondi

── Villa-Loja v. Bondi ── Case No.: 24-4 Court: Court of Appeals for the Second Circuit Date: March 20, 2026 Category: General 24-4 Villa-Loja v. Bondi BIA Drucker, IJ A220 234 217/218 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 20th day of March, two thousand twenty-six. PRESENT: MICHAEL H. PARK, STEVEN J. MENASHI, SARAH A. L. MERRIAM, Circuit Judges. _____________________________________ DORIS MICHELLE VILLA-LOJA, J. A. E.- V., Petitioners, v. 24-4 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. * * The Clerk of Court is respectfully directed to amend the caption to reflect the abbreviation of the minor Petitioner’s name. FOR PETITIONERS: Reuben S. Kerben, Kerben Law Firm, P.C., Kew Gardens, NY. FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant Attorney General, Civil Division; Sabatino F. Leo, Assistant Director, Office of Immigration Litigation; Jaclyn G. Hagner, 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. Petitioners Doris Michelle Villa-Loja and her minor child, natives and citizens of Ecuador, seek review of a December 12, 2023, decision of the BIA affirming a June 28, 2023, decision of an Immigration Judge (“IJ”) denying Villa- Loja’s application for asylum, withholding of removal, and relief under the Convention Against Torture (“CAT”). 1 In re Villa-Loja, Nos. A 220 234 217/218 1 We principally refer to Villa-Loja because her child did not file an independent application. We do not discuss the CAT claim further because Villa-Loja does not challenge the BIA’s finding that she had waived it. See Debique v. Garland, 58 F.4th 676, 684 (2d Cir. 2023) (“We consider abandoned any claims not adequately presented in an appellant’s brief.” (quotation marks omitted)); Prabhudial v. Holder, 780 F.3d 553, 555–56 (2d Cir. 2015) (when the BIA deems an issue waived and declines to consider it, our review is limited to the waiver finding). 2 (B.I.A. Dec. 12, 2023), aff’g Nos. A 220 234 217/218 (Immig. Ct. N.Y. City June 28, 2023). We assume the parties’ familiarity with the underlying facts and procedural history. We have reviewed the IJ’s decision “as modified by” the BIA, that is, as limited to the