The Eighth Circuit Court of Appeals reversed a district court ruling Tuesday that had favored a Liberian citizen challenging the denial of his green card application, holding that federal courts lack jurisdiction to review certain immigration decisions.
In *Abrahim Mohamed Fofana v. Kristi Noem*, the appeals court ruled that the U.S. District Court for the District of Minnesota exceeded its authority when it granted summary judgment for Fofana and found the government's denial of his adjustment of status application was arbitrary and capricious.
Chief Judge Raymond Colloton, writing for a three-judge panel that included Circuit Judges Loken and Benton, concluded that the district court "lacked jurisdiction to review the Secretary's decision" and reversed the lower court's judgment.
Fofana, a native and citizen of Liberia, sued DHS Secretary Kristi Noem and several U.S. Citizenship and Immigration Services officials to challenge the denial of his application for adjustment of status to lawful permanent resident. The defendants included Acting USCIS Director Angelica Alfonso-Royals, Associate Director Connie Nolan, and Minneapolis Field Office Director Steven G. Rice.
The case stems from Fofana's attempt to enter the United States with fraudulent documents on Jan. 28, 2001. Court records show that when Fofana later applied for asylum, he disclosed significant information about his political activities in his home country that would prove crucial to his case.
According to the appeals court opinion, Fofana revealed that while he was a student in Saudi Arabia, he had raised money for the United Liberation Movement of Liberia for Democracy, known as ULIMO. He described himself as "an active supporter of the ULIMO fighters," a disclosure that appears to have complicated his immigration status.
Fofana argued that returning to Liberia would expose him to persecution based on his affiliation with ULIMO, though the court record does not detail the specific nature of the threats he claimed to face.
The district court had initially ruled in Fofana's favor, finding that the government's denial of his adjustment application was arbitrary and capricious under administrative law standards. This finding typically indicates that an agency's decision lacked a rational basis or failed to consider relevant factors required by law.
However, the Eighth Circuit's reversal focused not on the merits of Fofana's immigration claim, but on a fundamental question of federal court authority. The appeals court determined that jurisdictional limitations prevent federal courts from reviewing certain types of immigration decisions, particularly those involving adjustment of status applications.
This jurisdictional ruling reflects broader legal restrictions on judicial review of immigration matters. Federal immigration law contains several provisions that limit or eliminate court review of certain administrative decisions, particularly those involving discretionary determinations by immigration officials.
The timing of the case spans multiple administrations, with the initial submission occurring on Oct. 21, 2025, and the final ruling filed on Jan. 9, 2026. The case was heard during a period when Kristi Noem served as DHS Secretary, representing a shift in immigration enforcement policies.
For Fofana, the jurisdictional ruling effectively closes the federal court avenue for challenging his adjustment denial, though other administrative remedies may remain available depending on the specific circumstances of his case and current immigration law.
The decision adds to a body of Eighth Circuit precedent limiting judicial review of immigration matters. The circuit, which covers Minnesota, Iowa, Missouri, Arkansas, North Dakota, South Dakota, and Nebraska, has consistently applied restrictive interpretations of court jurisdiction over immigration cases.
Immigration attorneys note that jurisdictional challenges have become increasingly common defenses in immigration litigation, as government lawyers seek to prevent federal courts from reviewing agency decisions that may be vulnerable on the merits.
The ruling also highlights the complex intersection of immigration law and administrative procedure, where even successful challenges to agency decision-making can be overturned on jurisdictional grounds rather than substantive legal analysis.
For immigration practitioners, the case serves as a reminder of the importance of carefully analyzing jurisdictional requirements before filing federal court challenges to immigration decisions. The availability of judicial review varies significantly depending on the type of immigration benefit sought and the specific grounds for denial.
The reversal leaves Fofana without the favorable district court ruling that had found the government's actions arbitrary and capricious, effectively returning him to his pre-litigation status regarding his adjustment application.