LAW.coLAW.co

UNITED STATES v. BATRES LANDAVERDE (2021)

United States Court of Appeals, Ninth Circuit.2021-02-22No. No. 19-30160

Summary

Holding. The district court's order denying the motion to dismiss the indictment was affirmed.

Jose Marcelino Batres-Landaverde was charged with illegal reentry after deportation and moved to dismiss the indictment, arguing that the removal order underlying his charge was invalid. He claimed the immigration court lacked jurisdiction because his initial Notice to Appear did not include the date and time of his removal hearing, as he argued was required by statute. The court rejected this argument, finding that precedent established the missing information in the initial notice did not deprive the immigration court of jurisdiction, especially since Batres-Landaverde received a separate notice with the hearing details before his appearance and actually showed up as ordered.

Batres-Landaverde also invoked the rule of lenity, asking the court to interpret an ambiguous statute in his favor by requiring that the Notice to Appear include the time and place of the hearing. The court assumed this rule could apply but found the argument failed anyway because the relevant statute does not control when the immigration court's jurisdiction takes effect; rather, the applicable regulations govern that timing.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a Notice to Appear lacking the date and time of a removal hearing deprives immigration court of jurisdiction
  • When jurisdiction vests in immigration court—whether by statute or regulation
  • Application of the rule of lenity to ambiguous immigration statute

Procedural posture

Batres-Landaverde appealed the district court's denial of his motion to dismiss the indictment charging him with illegal reentry after deportation.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

MEMORANDUM **

Jose Marcelino Batres-Landaverde appeals from the district courts order denying his motion to dismiss the indictment charging him with illegal reentry after deportation, in violation of 8 U.S.C. § 1326. We have jurisdiction under 28 U.S.C. § 1291, and we affirm.

Batres-Landaverde argues that the district court erred in denying his motion to dismiss because the removal order supporting his § 1326 charge is invalid. Specifically, he contends that the immigration court lacked jurisdiction over his removal proceedings because the Notice to Appear (“NTA”) failed to include the date and time of his removal hearing. Although the NTA failed to include this information, Batres-Landaverde was served with a notice before his hearing that included this information, and he appeared as ordered. As Batres-Landaverde concedes, his jurisdictional argument is foreclosed. See Aguilar Fermin v. Barr, 958 F.3d 887, 895 (9th Cir.) (“the lack of time, date, and place in the NTA sent to [petitioner] did not deprive the immigration court of jurisdiction over her case”), cert. denied, ––– U.S. ––––, 141 S. Ct. 664, 208 L.Ed.2d 271 (2020); Karingithi v. Whitaker, 913 F.3d 1158, 1160 (9th Cir. 2019).

Batres-Landaverde also argues that, to the extent 8 U.S.C. § 1229 is ambiguous as to what must be included in an NTA to confer jurisdiction, we must apply the rule of lenity and find that the statute requires that the time and place be included. Even assuming the rule of lenity applied, this argument fails because § 1229(a) does not determine when jurisdiction vests. See Karingithi, 913 F.3d at 1160 (“[T]he regulations, not § 1229(a), define when jurisdiction vests.”).

Because Batres-Landaverdes jurisdictional argument fails, we need not decide whether he was required to exhaust it under § 1326(d)(1).

AFFIRMED.