The U.S. Court of Appeals for the Tenth Circuit is reviewing a significant immigration case that challenges actions taken by the Department of Homeland Security under Secretary Kristi Noem's leadership. In *Mukantagara v. Noem*, plaintiffs Agnes Mukantagara and her son Ebenezer Shyaka are appealing a lower court decision that dismissed their lawsuit against multiple federal immigration agencies.
The case, filed as No. 24-4071, centers on the termination of Mukantagara's refugee status by U.S. Citizenship and Immigration Services. According to court documents filed Jan. 12, 2026, the plaintiffs initially sued USCIS for ending Mukantagara's protected status, but the U.S. District Court for the District of Utah dismissed their case for lack of subject-matter jurisdiction.
The defendants named in the appeal include Secretary Kristi Noem in her official capacity, the Department of Homeland Security, U.S. Citizenship and Immigration Services, and several regional immigration officials. These officials include Michael Crabtree, USCIS Field Office Director in Salt Lake City; Andrew Lambrecht, USCIS District Office Director in Denver; and Kika Scott, who serves as senior official performing the duties of the Director.
The original lawsuit was filed in the District of Utah under case number 2:20-CV-00897-RJS, indicating the litigation has been ongoing for several years before reaching the appellate level. The case highlights ongoing tensions between immigration advocacy groups and federal agencies over refugee status determinations and the procedural requirements for challenging such decisions in federal court.
Circuit Judge Phillips is writing the opinion for a three-judge panel that includes Chief Judge Tymkovich and Judge McHugh. The Tenth Circuit's decision to publish this opinion suggests the court views the case as establishing important precedent for immigration law within its jurisdiction, which covers Colorado, Kansas, New Mexico, Oklahoma, Utah, and Wyoming.
The plaintiffs are represented by Daniel R. Black and Marti L. Jones of Stowell Crayk, PLLC, based in Millcreek, Utah. The federal government is represented by Department of Justice trial attorney Aneesa Ahmed, along with several other DOJ officials including Acting Assistant Attorney General Yaakov Roth and Acting Director August E. Flentje.
Refugee status termination cases often involve complex questions about changed country conditions, fraud allegations, or procedural violations. When USCIS terminates refugee status, individuals may lose their ability to remain in the United States legally and could face removal proceedings. Such terminations can be challenged through administrative processes or federal court litigation, though courts have limited jurisdiction over immigration matters under federal law.
The district court's dismissal for lack of subject-matter jurisdiction suggests the lower court found it did not have authority to review the immigration agency's decision under applicable statutes. Federal courts have restricted jurisdiction over immigration matters, with many agency decisions subject to review only through the immigration court system or Board of Immigration Appeals rather than federal district courts.
The Tenth Circuit's review will determine whether the district court correctly dismissed the case or whether the plaintiffs have valid claims that federal courts can address. This could affect how similar challenges to refugee status terminations are litigated in the future within the circuit's jurisdiction.
Secretary Noem, who previously served as Governor of South Dakota before being nominated to lead DHS, has taken a hardline approach to immigration enforcement since assuming her role. Her department oversees USCIS, which processes immigration benefits including refugee status determinations.
The case reflects broader debates about immigration policy and the rights of refugees and asylum seekers in the United States. Refugee advocacy groups closely monitor such cases for their potential impact on protection standards and procedural rights.
The timing of the appeal, with documents filed in January 2026, suggests the Tenth Circuit will issue its decision in the coming months. Published circuit court decisions carry precedential weight within the circuit and can influence how lower courts handle similar cases.
For Mukantagara and Shyaka, the appeal represents their final opportunity to challenge the termination decision in federal court. If the Tenth Circuit affirms the dismissal, their legal options would be limited to potential Supreme Court review or return to immigration court proceedings.
The case underscores the complex intersection of immigration law, federal court jurisdiction, and administrative agency authority that characterizes much of contemporary immigration litigation in the United States.