Sanaullah Mohammed v. Todd W. Blanche

── Sanaullah Mohammed v. Todd W. Blanche ── Court: Court of Appeals for the Seventh Circuit Date: May 05, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 25-1901 SANAULLAH KHAN MOHAMMED, Petitioner, v. TODD W. BLANCHE, * Acting Attorney General of the United States, Respondent. ____________________ Petition for Review of an Order of the Board of Immigration Appeals. No. A201-643-458 ____________________ ARGUED FEBRUARY 18, 2026 — DECIDED MAY 5, 2026 ____________________ Before SCUDDER, JACKSON-AKIWUMI, and PRYOR, Circuit Judges. SCUDDER, Circuit Judge. Sanaullah Khan Mohammed en- tered the United States on a visitor visa in 2016. He overstayed and did not apply for asylum until a year and a half after the * We have substituted Todd W. Blanche, the current Acting Attorney General of the United States. See Fed. R. App. P. 43(c)(2). 2 No. 25-1901 deadline. An immigration judge found his request for asylum untimely, rejected his other requests for relief, and ordered his removal. After the Board of Immigration Appeals dis- missed his appeal, Mohammed petitioned for our review. His petition does not address our jurisdiction to review the immi- gration judge’s dismissal of his asylum claim as untimely—a question that, in light of recent Supreme Court precedent, has divided other circuits and which we leave for another day. Absent adversarial presentation of this issue, we rely on our own precedent and hold that we lack jurisdiction to review the timeliness of Mohammed’s request for asylum. We other- wise deny his petition, as we see no error in the denial of his request to withhold removal. I A The administrative record supplies the operative facts. Mohammed comes from a Muslim family in India. The family ran a slaughterhouse business that would buy cows, butcher them, and pack and sell the meat. Tension arose with Hindus in the area who both considered cows sacred and claimed affiliation with the Bharatiya Janata Party, a domi- nant political party in India. After Mohammed began running the slaughterhouse in 2014, he witnessed increased attempts to interfere with the business. By Mohammed’s telling, the most serious incident oc- curred around May 2016. It was then that a group confronted him and his mother, threw rocks at him, and then beat him, all the while admonishing them to shutter the slaughterhouse. When Mohammed yelled for help, local police responded and No. 25-1901 3 dispersed everyone. The attack left Mohammed with minor injuries that required little medical attention. About a month later, on June 26, 2016, Mohammed en- tered the United States on a visitor visa. He remained beyond the expiration date of December 25, 2016. He did not apply for asylum until January 28, 2019. B Having received Mohammed’s asylum application well beyond the one-year deadline of June 26, 2017, the U.S. Citi- zenship and Immigration Services denied it. From there Mo- hammed received a notice to appear on a charge of remova- bility. In time an immigration judge held a hearing and con- sidered Mohammed’s claims for asylum, withholding of re- moval, and relief under the Convention Against Torture. Mo- hammed testified as the sole witness at the hearing. Finding no extraordinary circumstances justifying an ex- ception to the one-year deadline to apply for asylum, the im- migration judge denied Mohammed’s application as un- timely. See 8 U.S.C. § 1158(a)(2)(D). The immigration judge also denied his request to withhold removal, finding that