The Ninth Circuit Court of Appeals has denied a petition for review from Blas Guzman-Rodriguez, a Mexican national who sought to avoid removal from the United States based on hardship to his two U.S. citizen children. The court issued its memorandum decision on Jan. 27, 2026, upholding the Board of Immigration Appeals' determination that Guzman-Rodriguez failed to meet the legal standard for cancellation of removal.
The case, *Blas Guzman-Rodriguez v. Pamela Bondi*, centered on whether Guzman-Rodriguez's removal would result in "exceptional and extremely unusual hardship" to his U.S. citizen children, as required under federal immigration law. This standard, codified in 8 U.S.C. § 1229b(b)(1)(D), sets a high bar for immigrants seeking to cancel removal proceedings based on family hardship.
The three-judge panel, consisting of Circuit Judges Gould, Bennett, and Bade, applied what the court described as a "highly deferential" substantial evidence standard when reviewing the agency's hardship determination. This standard requires courts to give significant weight to immigration officials' findings, making it difficult for petitioners to overturn removal orders on appeal.
The court cited *Gonzalez-Juarez v. Bondi*, a 2025 Ninth Circuit case, which established that under the substantial evidence standard, the agency's hardship determination is "conclusive" when supported by the record. This precedent demonstrates the challenging legal landscape facing immigrants who seek to remain in the United States based on family ties and potential hardship to citizen relatives.
Guzman-Rodriguez's case highlights the complex intersection of immigration law and family unity. While his two children are U.S. citizens by birth, their citizenship alone does not automatically prevent their father's removal. Instead, immigration law requires a showing that the hardship they would face upon their father's removal rises to an "exceptional and extremely unusual" level.
The "exceptional and extremely unusual hardship" standard is notably stringent compared to other areas of immigration law. Courts have interpreted this language to require more than the typical hardship that would naturally result from family separation. Factors that immigration judges consider include the children's age, health, family ties in the United States, the ability to relocate to the parent's home country, educational opportunities, and economic circumstances.
The Ninth Circuit's jurisdiction over this case stems from 8 U.S.C. § 1252(a)(2)(D), which grants circuit courts authority to review certain immigration decisions. The court also referenced *Wilkinson v. Garland*, a 2024 Supreme Court case that clarified jurisdictional requirements for immigration appeals.
The case was decided without oral argument, with the panel concluding unanimously that the matter was suitable for resolution based on the written record alone. This procedural decision, authorized under Federal Rule of Appellate Procedure 34(a)(2), reflects the court's assessment that the legal issues were sufficiently clear to decide without additional advocacy.
The court's memorandum disposition carries the notation "NOT FOR PUBLICATION," indicating that while the decision resolves Guzman-Rodriguez's case, it will not serve as binding precedent for future cases. Under Ninth Circuit Rule 36-3, such unpublished decisions have limited precedential value, though they may be cited in certain circumstances.
The timing of the decision, with the case submitted and decided on the same day in January 2026, suggests the court viewed the legal issues as straightforward given existing precedent. The case number 21-70717 indicates the petition was filed in 2021, meaning Guzman-Rodriguez's legal proceedings spanned several years before reaching this final resolution.
This decision reflects broader trends in immigration law enforcement and family separation issues that have remained contentious across multiple presidential administrations. The case demonstrates how immigration courts apply statutory requirements even in cases involving U.S. citizen children, prioritizing adherence to legal standards over family unity considerations.
For immigration practitioners, the decision reinforces the difficulty of meeting the exceptional hardship standard in cancellation of removal cases. The deferential review standard applied by federal courts means that immigration judges' initial determinations are rarely overturned on appeal, placing significant pressure on presenting compelling evidence at the trial level.
The case also illustrates the ongoing challenges faced by mixed-status families, where some members are U.S. citizens while others lack legal immigration status. These families must navigate complex legal requirements that can result in family separation despite strong ties to American communities.
Guzman-Rodriguez's unsuccessful appeal joins thousands of similar cases where parents of U.S. citizen children have been unable to demonstrate the level of hardship required to avoid removal. The decision serves as a reminder of the high legal bar set by federal immigration statutes and the limited discretion available to immigration judges in such cases.