Marvin Laguna Rivera v. U.S. Attorney General

130 F.4th 915 · United States Court of Appeals for the Eleventh Circuit · March 5, 2025 · No. 23-12398

Summary

This Eleventh Circuit opinion reviews a Board of Immigration Appeals decision denying an asylum seeker's claims for asylum, withholding of removal, and protection under the Convention Against Torture. The court holds that it lacks jurisdiction to review the agency's determination that the asylum application was untimely, as controlling precedent classifies this as a discretionary judgment call. Regarding the remaining claims, the court finds substantial evidence supports the agency's adverse credibility finding and conclusion that the petitioner failed to establish a well-founded fear of future persecution. Consequently, the petition for review is dismissed in part and denied in part.

Court
United States Court of Appeals for the Eleventh Circuit
Writing for the Court
William Pryor; Jordan; Marcus
Jurisdiction
United States Court of Appeals for the Eleventh Circuit
Decision date
March 5, 2025
Docket number
23-12398
Procedural posture
Petition for Review of a Board of Immigration Appeals decision affirming an Immigration Judge's denial of asylum, withholding of removal, and CAT relief.
Standard of review
Legal conclusions reviewed de novo; factual findings reviewed for substantial evidence.
Precedential value
published
Parties
Marvin Laguna Rivera v. U.S. Attorney General
Disposition
other

Topics

asylumjudicial review of agency actionappellate procedureadministrative lawstatutory interpretationstandard of review

Practice areas

immigration

Questions Presented

  1. Whether the Eleventh Circuit has jurisdiction to review the BIA’s determination that Rivera’s asylum application was untimely.
  2. Whether the BIA’s adverse credibility finding for Rivera’s withholding of removal and CAT claims is supported by substantial evidence.
  3. Whether Rivera exhausted his claims before the BIA, precluding review.

Holdings

  1. The court lacks jurisdiction to review the BIA’s determination that the asylum application was untimely, and therefore dismisses that portion of the petition.
  2. The BIA’s credibility finding is supported by substantial evidence; the petition for review of withholding of removal and CAT relief is denied.

Key quotations

“we review the record evidence in the light most favorable to the agency’s decision and draw all reasonable inferences in favor of that decision.”
“As to credibility determinations, [t]he trier of fact must determine credibility, and this court may not substitute its judgment for that of the BIA and [IJ] with respect to credibility findings.”

Factual background

Marvin Laguna Rivera, a native of Nicaragua, participated in political activities against the Ortega government in the 1990s. He filed his asylum application eight years after arriving in the United States, and the Immigration Judge found his credibility lacking. The BIA affirmed the IJ's denial of asylum, withholding of removal, and protection under the Convention Against Torture.

Procedural history

The Immigration Judge denied Rivera's asylum, withholding of removal, and CAT claims. The Board of Immigration Appeals affirmed that denial. Rivera appealed to the Eleventh Circuit.

Court Document

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