Patel v. Bondi

── Patel v. Bondi ── Case No.: 23-8095 Court: Court of Appeals for the Second Circuit Date: March 18, 2026 Category: General 23-8095 Patel v. Bondi BIA Perl, IJ A220 730 988/989/990/991 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 18th day of March, two thousand twenty-six. PRESENT: GERARD E. LYNCH, ALISON J. NATHAN, SARAH A. L. MERRIAM, Circuit Judges. _____________________________________ GHANSHYAMBHAI PATEL, USHABEN PATEL, T.P., S.P., Petitioners, v. 23-8095 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL, Respondent. * *The Clerk of Court is respectfully directed to amend the official case caption to conform to the caption above. We use only initials to refer to the minor petitioners _____________________________________ FOR PETITIONERS: Elliot A. Rahimi, Rahimi Law Firm P.C., Great Neck, NY. FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant Attorney General; Leslie McKay, Assistant Director; William C. Minick, Senior 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 Ghanshyambhai Patel, Ushaben Patel, and their children, 1 natives and citizens of India, seek review of a November 27, 2023, decision of the BIA affirming a February 15, 2023, decision of an Immigration Judge (“IJ” and, together with the “BIA,” “the agency”) denying asylum, withholding of removal, and relief under the Convention Against Torture (“CAT”). In re Patel, et al., Nos. in this publicly accessible order, consistent with Federal Rule of Civil Procedure 5.2(a)(3) and Federal Rule of Appellate Procedure 25(a)(5). 1References to “Patel” in the remainder of this order are to lead petitioner Ghanshyambhai Patel. 2 A 220 730 988/989/990/991 (B.I.A. Nov. 27, 2023), aff’g Nos. A 220 730 988/989/990/991 (Immig. Ct. N.Y. City Feb. 15, 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. See Xue Hong Yang v. U.S. Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005). “We review de novo questions of law and the application of law to fact” and “[w]e review the agency’s factual findings . . . under the substantial evidence standard.” Hong Fei Gao v. Sessions, 891 F.3d 67, 76 (2d Cir. 2018). “[T]he admini