9th Cir.

Paez Montiel v. Blanche

June 1, 2026 ·24-965 ·Unpublished · By Raj Patel

The United States Court of Appeals for the Ninth Circuit denied a petition for review of a Board of Immigration Appeals decision. The court held that the Board did not misunderstand the legal principles governing sua sponte reopening of removal proceedings.

Background

Petitioner Veronica Ivonne Paez Montiel, a native and citizen of Mexico, petitioned for review of a Board of Immigration Appeals order denying her second motion to reopen proceedings. She argued the Board erred by failing to apply the exceptional situations standard and by treating her motion as a request to terminate proceedings under Matter of Coronado Acevedo.

The court’s reasoning

The court noted that judicial review of the Board’s refusal to exercise sua sponte authority is limited to assuring the Board made its decision on the correct understanding of applicable legal principles. The court found that exceptional situations and exceptional circumstances are not judicially manageable standards. The Board did not misunderstand its broad discretion, nor did it misconstrue the Petitioner’s motion which sought reopening and termination for Special Immigrant Juvenile classification.

What it means going forward

The petition for review is denied, and the Board’s order denying the motion to reopen remains in effect.