Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-06-29

The fifth-circuit dismissed the petition for review in part for lack of jurisdiction and denied it in part regarding Johanna Briseyda Vasquez Bonilla’s motion to reopen her removal proceedings. The court applied a highly deferential abuse-of-discretion standard to the Board of Immigration Appeals’ decision. Regarding the claim that she lacked notice of her in absentia hearing, the court held the argument was waived because the petitioner failed to brief it, citing *Yohey v. Collins*. On the claim involving changed country conditions in El Salvador, the court declined to consider evidence outside the administrative record pursuant to 8 U.S.C. § 1252(b)(4)(A) and found the petitioner failed to demonstrate a material change in conditions as required by *Garcia v. Garland* and *Nunez v. Sessions*. Furthermore, the court ruled it lacked jurisdiction to review the BIA’s denial of sua sponte regulatory reopening due to its entirely discretionary nature under *Garcia-Gonzalez v. Garland*. As a result, the petition was dismissed for lack of jurisdiction regarding the sua sponte claim and denied on the merits for the other claims.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-06-29

Docket: 1:24-cv-04098-SEG

The eleventh-circuit dismissed the appeal sua sponte as moot because the district court subsequently granted the appellant’s motion for reconsideration, vacated the original dismissal order, and reopened the case. The court applied the doctrine that federal courts lack authority to adjudicate moot controversies, citing *Mobley v. Palm Beach Cnty. Sheriff Dep’t* and *Brooks v. Ga. State Bd. of Elections*, which establish that an appeal becomes moot when the underlying order being challenged is vacated and the case is reinstated. As a result, the appeal was terminated without a decision on the merits, and all pending motions were denied as moot.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-06-29

Docket: 1:24-cv-23477-BB

The eleventh-circuit affirmed the district court’s dismissal of Isabel del Pino Allen’s amended complaint with prejudice and its denial of her motion for relief pursuant to Federal Rule of Civil Procedure 59(e). The court held that the district court did not abuse its discretion in determining that the plaintiff’s pleadings constituted impermissible “shotgun pleadings” because they failed to provide the defendant with fair notice of the specific claims asserted or the factual grounds supporting them. The court applied the standard of review for abuse of discretion, requiring affirmation unless the district court made a clear error of judgment or applied the wrong legal standard. Under Federal Rule of Civil Procedure 8(a)(2) and Rule 10(b), a complaint must contain a short and plain statement showing entitlement to relief with claims set forth in numbered paragraphs limited to a single set of circumstances. The appellate court found that Allen’s amended complaint, while containing numbered paragraphs, failed to separate distinct causes of action into separate counts or clearly link factual allegations to specific legal theories. Instead, the filing contained loose references to Florida statutes and contradictory statements regarding her intent to assert a bad faith claim, rendering it impossible to discern which facts supported which claims. The court further reasoned that allowing further amendment would be futile because Allen had already been given an opportunity to correct these deficiencies and had explicitly stated she did not intend to pursue the only viable cause of action (bad faith) while attempting to relitigate claims previously rejected in prior suits against the same defendant. Additionally, the district court properly considered documents outside the four corners of the complaint, such as previous judicial records and GEICO’s motions, to conclude that dismissal with prejudice was appropriate under the court’s inherent authority to control its docket. The denial of the Rule 59(e) motion was upheld because Allen failed to present newly discovered evidence or demonstrate a manifest error of law or fact, instead attempting to relitigate issues already resolved. As a practical consequence, the dismissal stands with prejudice, meaning the case is closed and Allen cannot refile the same claims in federal court.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.