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No. 10765500
United States Court of Appeals for the Fourth Circuit

Josefa Catalan Adame v. Pamela Bondi

No. 10765500 · Decided December 23, 2025
No. 10765500 · Fourth Circuit · 2025 · FlawFinder last updated this page Apr. 2, 2026
Case Details
Court
United States Court of Appeals for the Fourth Circuit
Decided
December 23, 2025
Citation
No. 10765500
Disposition
See opinion text.
Full Opinion
USCA4 Appeal: 24-2166 Doc: 17 Filed: 12/23/2025 Pg: 1 of 2 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 24-2166 JOSEFA CATALAN ADAME, Petitioner, v. PAMELA JO BONDI, Attorney General, Respondent. On Petition for Review of an Order of the Board of Immigration Appeals. Submitted: October 16, 2025 Decided: December 23, 2025 Before NIEMEYER and RUSHING, Circuit Judges, and TRAXLER, Senior Circuit Judge. Petition denied by unpublished per curiam opinion. ON BRIEF: Mark J. Devine, Charleston, South Carolina, for Petitioner. Drew C. Ensign, Deputy Assistant Attorney General, Anthony C. Payne, Assistant Director, Neelam Ihsanullah, Office of Immigration Litigation, Civil Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Respondent. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 24-2166 Doc: 17 Filed: 12/23/2025 Pg: 2 of 2 PER CURIAM: Josefa Catalan Adame, a native and citizen of Mexico, petitions for review of an order of the Board of Immigration Appeals (Board) dismissing her appeal from the Immigration Judge’s denial of her applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The Board held that Catalan Adame waived review of independently dispositive rulings regarding her request for asylum and waived review of her entire withholding of removal and CAT claims. Upon review, we agree. As the Attorney General has properly invoked the exhaustion requirement specified in 8 U.S.C. § 1252(d)(1), we decline to review the asylum, withholding of removal, and CAT claims. * See Santos-Zacaria v. Garland, 598 U.S. 411, 413, 419 (2023); Trejo Tepas v. Garland, 73 F.4th 208, 213-14 (4th Cir. 2023). We have also reviewed the Board’s affirmance of the IJ’s denial of Catalan Adame’s motion for administrative closure and find no abuse of discretion. See Matter of Avetisyan, 25 I. & N. Dec. 688, 696 (B.I.A. 2012). Accordingly, we deny the petition for review. In re Catalan Adame (B.I.A. Nov. 6, 2024). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process. PETITION DENIED * For this reason, we need not address Catalan Adame’s remaining arguments challenging the denial of this relief. See INS v. Bagamasbad, 429 U.S. 24, 25 (1976) (recognizing that generally “courts and agencies are not required to make findings on issues the decision of which is unnecessary to the results they reach”). 2
Plain English Summary
USCA4 Appeal: 24-2166 Doc: 17 Filed: 12/23/2025 Pg: 1 of 2 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No.
Key Points
Frequently Asked Questions
USCA4 Appeal: 24-2166 Doc: 17 Filed: 12/23/2025 Pg: 1 of 2 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No.
FlawCheck shows no negative treatment for Josefa Catalan Adame v. Pamela Bondi in the current circuit citation data.
This case was decided on December 23, 2025.
Use the citation No. 10765500 and verify it against the official reporter before filing.
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