Cosquillo-Maiza v. Bondi

── Cosquillo-Maiza v. Bondi ── Case No.: 24-63 Court: Court of Appeals for the Second Circuit Date: March 17, 2026 Category: General 24-63 Cosquillo-Maiza v. Bondi BIA Reid, IJ A220 228 857/858/859/860 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 17th day of March, two thousand twenty-six. PRESENT: DEBRA ANN LIVINGSTON, Chief Judge, BETH ROBINSON, MYRNA PÉREZ, Circuit Judges. _____________________________________________ JUAN DANIEL COSQUILLO-MAIZA, MARIA ANGELA MUNCHA-COSQUILLO, D. G. C.-M., Y. S. C.-M., Petitioners, v. 24-63 NAC PAMELA BONDI, UNITED STATES ATTORNEY GENERAL,  Respondent.* _____________________________________________ FOR PETITIONERS: Thomas V. Massucci, New York, NY. FOR RESPONDENT: Brian Boynton, Principal Deputy Assistant Attorney General; John S. Hogan, Assistant Director; Deitz P. Lefort, 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, Juan Daniel Cosquillo-Maiza, Maria Angela Muncha-Cosquillo, and their minor children, natives and citizens of Ecuador, seek review of a December 14, 2023, decision of the BIA affirming a June 2, 2023, decision of an Immigration Judge (“IJ”) denying asylum, withholding of removal, and relief under the Convention Against Torture (“CAT”). In re Juan Daniel Cosquillo-Maiza, et al., Nos. A220 228 857/858/859/860 (B.I.A. Dec. 14, 2023), aff’g Nos. A220 228 857/858/859/860 (Immig. Ct. N.Y. City June 2, 2023). We assume the parties’ familiarity with the underlying facts and procedural history. * The Clerk of Court is respectfully directed to amend the case caption accordingly. 2  We have considered the IJ’s decision as supplemented and modified by the BIA. See Xue Hong Yang v. U.S. Dep’t of Just., 426 F.3d 520, 522 (2d Cir. 2005); Yan Chen v. Gonzales, 417 F.3d 268, 271 (2d Cir. 2005). We review factual findings for substantial evidence and questions of law de novo. See Hong Fei Gao v. Sessions, 891 F.3d 67, 76 (2d Cir. 2018). “[T]he administrative findings of fact are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252(b)(4)(B). Petitioners primarily argue that the IJ denied them due process b