Emmanuel Dwah Tiah v. Todd Blanche, Acting Attorney General of the United States
June 8, 2026·24-2010·Panel Decision·SMITH·By Raj Patel
The Eighth Circuit denied Emmanuel Tiah's petition for review of a Board of Immigration Appeals decision. The court upheld Tiah's removability based on violations of protection orders.
Background
Emmanuel Tiah, a native of Liberia, was found removable due to two North Dakota convictions for violating protection orders. The Board of Immigration Appeals determined he was ineligible for relief from removal.
The court’s reasoning
The court held that the record established Tiah’s removability under Section 1227(a)(2)(E)(ii) by clear and convincing evidence. It concluded that the protection orders were issued to prevent domestic violence and that Tiah’s conduct violated those orders.
We hold that copies of the actual protection orders were not required to determine Tiah’s removability under § 1227(a)(2)(E)(ii).
What it means going forward
The decision affirms Tiah’s removability, impacting his ability to remain in the United States.
