Case Explained: ZAVALZA-URIBE V. BLANCHE

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-15

The Ninth Circuit denied Juan Zavalza-Uribe’s petition for review of a Board of Immigration Appeals (BIA) decision denying his motion to reopen and reconsider an application for cancellation of removal. The court held that the petition was untimely because it was filed more than thirty days after the BIA issued its decision on September 22, 2022, characterizing the filing deadline as a mandatory claim-processing rule that must be enforced if properly raised. Regarding the merits of the motion to reconsider, the court found no abuse of discretion in the BIA’s denial. The court determined that the BIA adequately explained its decision by reiterating that the petitioner was unlikely to establish the requisite level of hardship for cancellation of removal and by considering evidence regarding his daughter’s mental health diagnoses and treatment. Furthermore, the court concluded that the BIA did not arbitrarily evaluate the evidence of potential hardship and that the petitioner failed to exhaust any challenge to the legal standard applied by the BIA because he did not raise it in his opening brief. Consequently, the petition is denied, leaving the BIA’s order denying relief in place.

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