Woff Senatus v. U.S. Attorney General

── Woff Senatus v. U.S. Attorney General ── Court: Court of Appeals for the Eleventh Circuit Date: June 08, 2026 Category: NEW USCA11 Case: 24-10514 Document: 76-1 Date Filed: 06/08/2026 Page: 1 of 12 FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-10514 ____________________ WOFF SENATUS, Petitioner, versus U.S. ATTORNEY GENERAL, Respondent. ____________________ Petition for Review of a Decision of the Board of Immigration Appeals Agency No. A070-798-575 ____________________ Before ROSENBAUM, BRANCH, and GRANT, Circuit Judges. BRANCH, Circuit Judge: Woff Senatus was a lawful permanent resident of the United States, but he was removed to Haiti after he was convicted in Florida of aggravated assault with a deadly weapon. He now petitions this Court to review the Board of Immigration Appeals’s USCA11 Case: 24-10514 Document: 76-1 Date Filed: 06/08/2026 Page: 2 of 12 2 Opinion of the Court 24-10514 decision not to reopen his proceedings, arguing that his Florida conviction does not qualify as a “crime of violence” under the relevant statutory removal provision, so his conviction cannot serve as a predicate for his removal. Our precedent, however, forecloses this argument, and we thus deny Senatus’s petition for review. 1 I. Background The facts relevant to this petition are not in dispute. Woff Senatus was a native and citizen of Haiti who became a lawful permanent resident of the United States in 2002. In 2021, Senatus was convicted of aggravated assault with a firearm in violation of Florida Statute § 784.021(1)(a) and sentenced to 14 months’ imprisonment and three years of probation. Following that conviction, the Department of Homeland Security (DHS) commenced removal proceedings against Senatus due to his conviction for an aggravated felony that was a crime of violence, according to the relevant provisions of the Immigration and Nationality Act (INA).2 Senatus, represented by counsel, conceded 1 The government filed a motion to dismiss the petition as untimely because Senatus filed his petition for review outside the 30-day deadline set forth in 8 U.S.C. § 1252(b)(1). Senatus urged us to equitably toll the 30-day filing deadline and consider his petition on the merits. We carried the motion to dismiss with the case. Because Senatus’s petition fails on the merits, we do not reach the question of whether equitable tolling is available for the 30-day filing deadline in § 1252(b)(1), and we deny the government’s motion to dismiss as moot. 2 “Any alien who is convicted of an aggravated felony at any time after admission is deportable.” 8 U.S.C. § 1227(a)(2)(A)(iii). The definition of an USCA11 Case: 24-10514 Document: 76-1 Date Filed: 06/08/2026 Page: 3 of 12 24-10514 Opinion of the Court 3 his removability at a hearing before an Immigration Judge (IJ), and the IJ designated Haiti as Senatus’s country of removal. Senatus proceeded with an application for asylum and withholding of removal, but his application was denied. He then appealed this denial to the Board of Immigration