U.S. Court of Appeals for the Eleventh Circuit, 2026

Alex Ramirez v. U.S. Attorney General

Alex Ramirez v. U.S. Attorney General
U.S. Court of Appeals for the Eleventh Circuit · Decided June 22, 2026
Alex Ramirez v. U.S. Attorney General

Opinion

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NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-12254 Non-Argument Calendar ____________________ ALEX F. RAMIREZ, Petitioner, versus U.S. ATTORNEY GENERAL, Respondent. ____________________ Petition for Review of a Decision of the Board of Immigration Appeals Agency No. A095-034-330 ____________________ Before JILL PRYOR, BRANCH, and GRANT, Circuit Judges.

PER CURIAM: Alex Ramirez petitions for review of the Board of Immigra- tion Appeals order affirming the immigration judge’s denial of his USCA11 Case: 25-12254 Document: 23-1 Date Filed: 06/22/2026 Page: 2 of 4

2 Opinion of the Court 25-12254 application for cancellation of removal. He argues that the immi- gration courts lacked jurisdiction over his removal proceedings be- cause the written notice that initiated those proceedings misidenti- fied his citizenship and nation of origin—the “notice to appear” re- quired by 8 U.S.C. § 1229(a) incorrectly stated that he was a native and citizen of El Salvador.

It turns out that Ramirez is a native and citizen of Guate- mala. During a hearing on his application for cancellation of re- moval, Ramirez produced a Guatemalan passport to prove his citi- zenship. He admitted that he had falsely claimed that he was from El Salvador when he applied for temporary protected status in 2001 and that he had provided a false identification document to obtain authorization to work in the United States. 1 The immigration judge denied Ramirez’s application for cancellation of removal and ordered him removed to Guatemala or, in the alternative, El Salvador. Ramirez appealed to the Board of Immigration Appeals, but the Board adopted and affirmed the immigration judge’s decision and dismissed the appeal.

In his petition for review by this Court, Ramirez argues that his removal order is void because the immigration courts lacked

1 Ramirez’s application for temporary protected status was granted in 2003, but his protected status was withdrawn in 2015 because he had been convicted of two misdemeanors in this country.

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25-12254 Opinion of the Court 3 jurisdiction over his removal proceedings. 2 He argues that the no- tice of appearance was defective because it misidentified his coun- try of origin, and that a defective notice of appearance is insufficient to confer jurisdiction on the immigration court. We disagree.

In a provision titled “[i]nitiation of removal proceedings,” the Immigration and Nationality Act requires written notice, called a “notice to appear,” to be “given in person to the alien.” 8 U.S.C. § 1229(a)(1). The statute specifies information that must be pro- vided in the notice, including the nature of the proceedings, the “charges against the alien and the statutory provisions alleged to have been violated,” and the conduct alleged to be in violation of the law. Id. Immigration regulations state that jurisdiction vests, and removal proceedings commence, when a notice to appear is filed with the immigration court. 8 C.F.R. § 1003.14(a).

A notice to appear that does not include all the information required by statute may be ineffective for certain purposes. Pereira v. Sessions, 585 U.S. 198, 202 (2018). But neither the content re-

2 To the extent Ramirez raises non-jurisdictional arguments about the alleged defect in the notice of appearance, we decline to consider them because he failed to adequately present them to the Board of Immigration Appeals. See 8 U.S.C. § 1252(d)(1). But we can and do consider his argument that the final order of removal was void for lack of jurisdiction, because it implicates our own jurisdiction—which “extends only to final orders of removal.” Perez- Sanchez v. U.S. Att’y Gen., 935 F.3d 1148, 1153 (11th Cir. 2019); see 8 U.S.C. § 1252(a)(1).

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4 Opinion of the Court 25-12254 quirements of § 1229(a) nor the associated regulations establish ju- risdictional rules. See Perez-Sanchez v. U.S. Att’y Gen., 935 F.3d 1148, 1153–57 (11th Cir. 2019).

Here, the notice to appear served on Ramirez was not fatally deficient for misidentifying his country of origin. Section 1229(a) does not require a notice to appear to correctly identify the noncit- izen’s country of origin. See 8 U.S.C. § 1229(a)(1)(A)–(G). And even if it did, noncompliance with the content requirements in § 1229(a)(1) does not deprive the immigration court of jurisdiction.

See Perez-Sanchez, 935 F.3d at 1150, 1153–54. We therefore deny his petition for review.

PETITION DENIED.

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