The U.S. Court of Appeals for the Second Circuit granted a petition for review and remanded an immigration case back to the Board of Immigration Appeals on January 13, 2026, in a summary order that carries no precedential effect. The case, *Ahmed v. Bondi*, marks one of the earliest immigration appeals decided under the tenure of Attorney General Pamela Bondi.
The three-judge panel, consisting of Circuit Judges Robert D. Sack, Raymond J. Lohier Jr., and Myrna Pérez, issued the ruling in favor of petitioner Ridoiy Ahmed after reviewing his challenge to a BIA decision. The court's order states that "the petition for review is GRANTED and the case is REMANDED for further proceedings."
Ahmed was represented by Khagendra Gharti-Chhetry of Chhetry & Associates, P.C., based in New York. The government's response was handled by a team from the Department of Justice's Office of Immigration Litigation, including Acting Assistant Attorney General Yaakov M. Roth, Acting Assistant Director Sheri R. Glaser, and Trial Attorney Jenny C. Lee.
The case was heard at the Thurgood Marshall United States Courthouse in Manhattan, located at 40 Foley Square. The proceeding was designated as case number 24-2091 and included the administrative record number A220 718 815.
While the specific details of Ahmed's immigration case and the grounds for the court's decision to remand are not fully disclosed in the available documentation, the ruling suggests that the Second Circuit found issues with the BIA's initial determination that warranted further review at the administrative level.
The timing of this decision is notable as it represents one of the first immigration appeals to be decided with Pamela Bondi serving as Attorney General. Bondi, who previously served as Florida's Attorney General from 2011 to 2019, was confirmed to lead the Department of Justice under the current administration.
Immigration cases frequently come before federal appeals courts when immigrants challenge decisions by the BIA, which serves as the highest administrative tribunal for interpreting and applying immigration laws. The BIA reviews decisions made by immigration judges and can affirm, reverse, or remand cases for further proceedings.
A remand order typically indicates that the appeals court found procedural errors, insufficient consideration of evidence, or other deficiencies in the lower tribunal's decision-making process. When a case is remanded, the BIA must reconsider the matter and issue a new decision that addresses the concerns raised by the appeals court.
The Second Circuit's jurisdiction covers New York, Connecticut, and Vermont, making it a significant venue for immigration appeals given the large immigrant populations in these states, particularly in the New York metropolitan area.
It's important to note that this ruling was issued as a summary order, which under Second Circuit rules does not establish binding precedent. As stated in the court's standard language, "rulings by summary order do not have precedential effect." However, such orders can still be cited in court filings, provided they include proper notation and service requirements.
The procedural requirements for citing summary orders are governed by Federal Rule of Appellate Procedure 32.1 and the Second Circuit's Local Rule 32.1.1. Parties citingsuch orders must use either the Federal Appendix or an electronic database with appropriate notation, and must serve copies on unrepresented parties.
The grant of Ahmed's petition represents a victory for the petitioner, who will now have his case reconsidered by the BIA. However, a remand does not guarantee a favorable outcome, as the BIA could potentially reach the same conclusion after addressing the appeals court's concerns.
This case adds to the substantial caseload of immigration matters that regularly come before federal appeals courts. Immigration law remains one of the most active areas of federal litigation, with thousands of cases appealed to circuit courts annually.
The decision also highlights the continued role of federal courts in reviewing administrative immigration decisions, ensuring that proper procedures are followed and that immigrants receive fair consideration of their cases under applicable law.
As the case returns to the BIA for further proceedings, it will be closely watched for how the administrative tribunal addresses the Second Circuit's concerns. The ultimate resolution of Ahmed's immigration matter will depend on the BIA's subsequent review and decision-making process.
The involvement of experienced immigration counsel on both sides suggests the complexity of the underlying legal issues, though the specific nature of Ahmed's immigration status and the grounds for his appeal remain to be fully disclosed as the case proceeds through the administrative process.