The U.S. Court of Appeals for the Second Circuit issued a summary order on January 7, 2026, in the immigration case *Ali Abdou Mohamed v. Pamela Bondi*, marking another chapter in the ongoing challenges facing immigration petitioners in federal appellate courts.
The case, designated as case numbers 24-723(L) and 24-1544(Con), involved petitioner Ali Abdou Mohamed challenging a decision by the Board of Immigration Appeals. The BIA decision was originally handled by Immigration Judge Schultz and carried the alien registration number A216 334 856.
The three-judge panel that considered the petition consisted of Circuit Judges Richard J. Sullivan, William J. Nardini, and Eunice C. Lee. The court convened at the Thurgood Marshall United States Courthouse, located at 40 Foley Square in New York City, for the proceeding.
Representing Mohamed was attorney Olivia F. Bensinger from the law firm Shaheen & Gordon, P.A., based in Concord, New Hampshire. The respondent, Attorney General Pamela Bondi, was represented by a team from the U.S. Department of Justice's Office of Immigration Litigation, including Brian M. Boynton, Principal Deputy Assistant Attorney General; Sabatino F. Leo, Assistant Director; and Nancy D. Pham, Trial Attorney, all based in Washington, D.C.
The court's decision was issued as a summary order, a type of ruling that carries specific limitations under federal appellate procedure. According to the court's own notation, summary orders do not have precedential effect, meaning they cannot be used as binding legal authority in future cases before other courts.
However, the citation of summary orders filed on or after January 1, 2007, is permitted under Federal Rule of Appellate Procedure 32.1 and the Second Circuit's Local Rule 32.1.1. When attorneys cite such summary orders in documents filed with the court, they must reference either the Federal Appendix or an electronic database and include the notation "SUMMARY ORDER." Additionally, any party citing a summary order must serve a copy on parties not represented by counsel.
The Second Circuit's use of summary orders reflects the court's approach to managing its substantial caseload while providing resolution to individual petitioners. Immigration cases frequently result in summary orders, particularly when the legal issues involved are well-established or when the case presents primarily factual rather than novel legal questions.
While the complete text of the court's decision was not available in the documentation, the case represents the type of immigration appeal that has become increasingly common in federal appellate courts. The Board of Immigration Appeals, which initially heard Mohamed's case, serves as the highest administrative tribunal for interpreting and applying immigration laws. When petitioners disagree with BIA decisions, they may seek review in the appropriate federal circuit court of appeals.
The Second Circuit Court of Appeals covers New York, Connecticut, and Vermont, handling a significant portion of the nation's immigration appeals due to the high volume of immigration cases originating in New York. The court regularly addresses petitions for review of removal orders, asylum denials, and other immigration-related decisions.
Attorney General Pamela Bondi, who serves as the respondent in this case, oversees the Department of Justice's immigration enforcement efforts. The Office of Immigration Litigation, which represented the government in this matter, specializes in defending immigration decisions before federal courts and handles thousands of such cases annually.
For Mohamed, the summary order represents the conclusion of his appellate challenge to the BIA decision. The specific immigration issues at stake in his case, whether involving removal proceedings, asylum claims, or other immigration relief, were not detailed in the available court documentation.
The timing of the decision, issued in early January 2026, comes as immigration law continues to evolve through both legislative and judicial channels. Federal appellate courts play a crucial role in interpreting immigration statutes and regulations, even when their decisions, like this summary order, do not establish binding precedent.
Immigration attorneys and advocates closely monitor such decisions for trends in how courts approach various types of immigration challenges. While individual summary orders may not set precedent, patterns in appellate court rulings can indicate broader judicial attitudes toward immigration law enforcement and relief.
The case also illustrates the collaborative nature of immigration litigation, with specialized attorneys from both private practice and the federal government bringing their expertise to bear on complex legal questions that affect individuals' abilities to remain in the United States.
As immigration law continues to develop through the federal court system, cases like *Mohamed v. Bondi* contribute to the ongoing dialogue between administrative agencies, federal prosecutors, immigration attorneys, and the judiciary about how immigration laws should be interpreted and applied in individual cases.