The U.S. Court of Appeals for the Second Circuit issued a summary order on February 3, 2026, in the immigration case *Alarcon v. Bondi*, marking another chapter in ongoing immigration litigation under the current administration. The case, designated as No. 25-713, involves petitioners Jackeline Carol Alarcon, L.E.B., and M.J.B. challenging a decision by the Board of Immigration Appeals.
The three-judge panel consisting of Circuit Judges Susan L. Carney, Michael H. Park, and Alison J. Nathan presided over the matter at the Thurgood Marshall United States Courthouse in New York City. The court issued its ruling as a summary order, which carries specific limitations under federal appellate procedure.
According to the court's procedural notice, summary orders do not have precedential effect, meaning they cannot be cited as binding authority in future cases. The Second Circuit explicitly states that "rulings by summary order do not have precedential effect," though citation to such orders filed on or after January 1, 2007, is permitted under Federal Rule of Appellate Procedure 32.1 and the court's Local Rule 32.1.1.
The case originated from a decision by Immigration Judge Sponzo before the Board of Immigration Appeals. The petitioners were represented by Joshua Bardavid, an attorney from New York. The government's position was argued by a team from the U.S. Department of Justice's Office of Immigration Litigation, including Assistant Attorney General Brett A. Shumate, Senior Litigation Counsel Zoe J. Heller, and Trial Attorney Erik R. Quick.
The respondent in the case is Attorney General Pamela Bondi, who assumed office as the nation's top law enforcement official. Immigration cases frequently name the sitting Attorney General as the respondent, as the Attorney General has ultimate authority over immigration enforcement and policy implementation.
The court document indicates that the Clerk of Court was directed to amend the case caption, suggesting there were procedural adjustments made to properly identify the parties involved. Such amendments are common in immigration cases where multiple family members or individuals may be involved in related proceedings.
The case file shows alien registration numbers A209 134 125/126/127, indicating that multiple individuals were involved in the underlying immigration proceedings. These numbers are assigned by U.S. Citizenship and Immigration Services to track individual cases through the immigration system.
Summary orders like the one issued in *Alarcon* represent a significant portion of the Second Circuit's immigration caseload. These orders allow the court to efficiently resolve cases without creating binding precedent, while still providing reasoned decisions for the parties involved. The Second Circuit handles a substantial volume of immigration appeals, given its jurisdiction over New York, Connecticut, and Vermont.
The timing of this decision comes as immigration enforcement continues to be a priority area for federal authorities. The Board of Immigration Appeals, which issued the initial decision being reviewed, serves as the highest administrative tribunal for interpreting and applying immigration laws. Appeals from BIA decisions go directly to federal courts of appeals like the Second Circuit.
For practitioners in immigration law, the procedural requirements surrounding summary orders are particularly important. Attorneys must follow specific citation rules when referencing these decisions, including notation that the order is non-precedential and service requirements for unrepresented parties.
The Second Circuit's immigration docket reflects the ongoing challenges facing the immigration system, with cases involving removal proceedings, asylum claims, and various forms of relief from removal. While the specific grounds for the *Alarcon* petition are not detailed in the available portion of the order, such cases typically involve challenges to BIA findings on eligibility for relief, credibility determinations, or procedural issues.
The involvement of multiple petitioners with different alien registration numbers suggests this case may involve family members or individuals with related immigration histories. Immigration proceedings often involve complex family situations where the outcome for one individual can affect others in the same family unit.
As the case concludes with the Second Circuit's summary order, the decision represents the final stage of administrative and judicial review available to the petitioners, absent any extraordinary circumstances that might warrant further appellate consideration. The ruling adds to the body of non-precedential decisions that help shape day-to-day immigration practice, even without creating binding legal precedent for future cases.