11th Cir.

WOFF SENATUS v. U.S. ATTORNEY GENERAL

June 8, 2026 ·24-10514 ·Published ·BRANCH · By Raj Patel

The Eleventh Circuit denied Woff Senatus's petition for review of the Board of Immigration Appeals' decision. The court concluded that Senatus's Florida conviction qualifies as a crime of violence, justifying his removal.

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Background

Woff Senatus, a lawful permanent resident, was removed to Haiti following a conviction for aggravated assault in Florida. He sought to reopen his removal proceedings, arguing that his conviction did not qualify as a crime of violence.

The court’s reasoning

The court determined that Senatus’s conviction under Florida law categorically qualifies as a crime of violence under federal law. The court followed precedent that established the necessary mens rea for such a conviction.

The BIA, therefore, did not abuse its discretion when it denied his petition to reopen.

What it means going forward

Senatus remains subject to removal based on his conviction, which the court classified as a crime of violence.