Valentin Belevich v. Klavdia Thomas & Tatiana Kuznitsnyna

Summary

The Eleventh Circuit held that equitable defenses—unclean hands, anticipatory breach, and equitable estoppel—cannot terminate a sponsor's financial obligation under an I-864 affidavit of support (8 U.S.C. § 1183a). The court ruled that the statute, regulation, and affidavit provide an exclusive list of terminating events focused on the immigrant's status and financial position, not family relationships or misconduct. Federal law governs the obligation, and allowing non-statutory defenses would undermine the statute's purpose of preventing immigrants from becoming public charges.

Holdings

1. The equitable defenses are foreclosed by the statute, regulation, and affidavit; the list of terminating events is exclusive.

Questions Presented

1. Whether equitable defenses (unclean hands, anticipatory breach, equitable estoppel) may excuse an immigrant's sponsor from her financial obligation under 8 U.S.C. § 1183a.

Disposition

affirmed