Rojas-Espinoza v. Blanche

No. 24-7536 (9th Cir. June 9, 2026) · United States Court of Appeals for the Ninth Circuit · June 9, 2026 · No. 24-7536

Summary

The Ninth Circuit, sitting en banc, vacated its prior order denying Petitioners’ motion to stay removal and granted the motion pending disposition of the en banc case. The court also invited optional supplemental briefing concerning the nexus element of asylum and withholding claims and whether Rodriguez-Zuniga v. Garland should be overruled. Judge Wardlaw concurred, while Judges Lee, Bade, and Tung dissented from granting the stay.

Court
United States Court of Appeals for the Ninth Circuit
Writing for the Court
Mary H. Murguia; Kim McLane Wardlaw; Ronald M. Gould; Johnnie B. Rawlinson; Morgan B. Christen; Michelle T. Friedland; Eric D. Miller; Bridget S. Bade; Kenneth K. Lee; Holly A. Thomas; Eric C. Tung
Jurisdiction
United States Court of Appeals for the Ninth Circuit
Decision date
June 9, 2026
Docket number
24-7536
Procedural posture
Petitioners sought a stay of removal while pursuing review of the Board of Immigration Appeals' decision in their immigration proceedings. Sitting en banc, the Ninth Circuit vacated its prior order denying the stay and granted the motion to stay removal pending disposition of the en banc case.
Standard of review
The court applied the stay standard under Nken v. Holder, requiring consideration of the stay factors, including whether the petitioner has made a strong showing of likely success on the merits.
Precedential value
Published en banc order
Parties
Maricruz Marisol Rojas-Espinoza, Robert David Salvador-Gomez, David Angel Salvador-Rojas, Korina Salvador-Rojas v. Todd Blanche, Acting Attorney General
Disposition
vacated

Topics

removal proceedingsimmigration detentionappellate procedureimmigrationasylum

Practice areas

ImmigrationAppellate ProcedureRemoval Proceedings

Questions Presented

  1. Whether Petitioners met the standard for a stay of removal under Nken v. Holder.
  2. Whether the court should vacate its prior order denying Petitioners' motion to stay removal and grant the stay pending disposition of the en banc case.

Holdings

  1. After considering the en banc briefing and oral argument, Petitioners met the standard for a stay of removal under Nken v. Holder.
  2. The court vacated its prior order denying Petitioners' motion to stay removal and granted the opposed motion to stay removal pending disposition of the en banc case.

Key quotations

In light of en banc briefing and oral argument, it is now apparent that Petitioners meet the standard for a stay of removal under Nken v. Holder, 556 U.S. 418 (2009).
The Court therefore vacates its prior order denying the motion to stay removal (Dkt. No. 40) and GRANTS Petitioners’ opposed motion to stay removal (Dkt. No. 3) pending disposition of this en banc case.

Factual background

Petitioners are noncitizens subject to removal proceedings whose claims for asylum and withholding of removal were rejected by the Board of Immigration Appeals based in part on failure to establish the required nexus. They sought a stay of removal while the Ninth Circuit considered their petition and related issues concerning the governing asylum-nexus precedent. The court concluded after en banc briefing and oral argument that they met the standard for a stay under Nken v. Holder.

Procedural history

Petitioners initially moved for a stay of removal. An automatic stay was issued, a three-judge panel later denied the stay, and the court granted rehearing en banc and vacated the panel opinion. The en banc court initially denied a stay, then vacated that denial after en banc briefing and oral argument and granted a stay pending disposition of the en banc case.

Remand instructions

No remand was ordered. The court stayed removal pending disposition of the en banc case and permitted optional supplemental briefing within 14 days.

Court Document

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