U.S. Court of Appeals for the Fourth Circuit, 2025

Josefa Catalan Adame v. Pamela Bondi

Josefa Catalan Adame v. Pamela Bondi
U.S. Court of Appeals for the Fourth Circuit · Decided December 23, 2025

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UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT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Petition denied by unpublished per curiam opinion.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Unpublished opinions are not binding precedent in this circuit.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”).

Case-law data current through December 31, 2025. Source: CourtListener bulk data.