Josefa Catalan Adame v. Pamela Bondi

U.S. Court of Appeals for the Fourth Circuit

Josefa Catalan Adame v. Pamela Bondi

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UNPUBLISHED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Petition denied by unpublished per curiam opinion.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Unpublished opinions are not binding precedent in this circuit.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

Reference

Status
Unpublished