Rustico Lacsina v. Todd Blanche
CourtCourt of Appeals for the Eighth Circuit
Date FiledAugust 6, 2026
Docket24-3373, 25-1754
StatusPublished
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Full Opinion
United States Court of Appeals
For the Eighth Circuit
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No. 24-3373
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Rustico Lacsina
Petitioner
v.
Todd Blanche,1 Acting Attorney General of the United States
Respondent
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No. 25-1754
___________________________
Rustico Lacsina
Petitioner
v.
Todd Blanche, Acting Attorney General of the United States
Respondent
____________
Petitions for Review of an Order of the
Board of Immigration Appeals
____________
1
Acting Attorney General Todd Blanche is automatically substituted as
respondent pursuant to Federal Rule of Appellate Procedure 43(c)(2).
Submitted: April 14, 2026
Filed: August 6, 2026
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Before LOKEN, SHEPHERD, and STRAS, Circuit Judges.
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SHEPHERD, Circuit Judge.
Rustico Lacsina, a native and citizen of the Philippines, petitions for review
of an order of the Board of Immigration Appeals (BIA) affirming the immigration
judge’s (IJ) order sustaining his charges of inadmissibility and an order of the BIA
denying his motion to reopen proceedings. Having jurisdiction under 8 U.S.C.
§ 1252, we grant the petition for review in part, deny it in part, and remand.
I.
Lacsina was admitted to the United States as a lawful permanent resident in
1982. In 2013, Lacsina pled guilty to receiving stolen property, in violation of Cal.
Penal Code § 496(a); in 2015, he pled guilty to possession of a controlled substance,
to wit: methamphetamine, in violation of Cal. Health & Safety Code § 11377(a). In
March 2024, DHS commenced removal proceedings against Lacsina by issuing him
a Notice to Appear (NTA), which charged him with inadmissibility under 8 U.S.C.
§ 1182(a)(2)(A)(i)(I), on the grounds that his conviction for receipt of stolen
property was a “crime involving moral turpitude” (CIMT), and with inadmissibility
under § 1182(a)(2)(A)(i)(II), on the grounds that his conviction for possession of a
controlled substance constituted a violation of a law “relating to a controlled
substance (as defined in section 802 of title 21).”
The IJ issued an order sustaining the charges of inadmissibility against
Lacsina under § 1182(a)(2)(A)(i)(I) and (II). The IJ held that Lacsina’s conviction
for receiving stolen property was a CIMT because the crime required that he “know[]
the property to be so stolen or obtained,” Cal. Penal Code § 496(a), and “when an
offense requires knowledge that the property was stolen, it is a crime involving moral
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turpitude.” The IJ further held that Lacsina’s conviction for possession of a
controlled substance “involved a drug defined as [a] federal drug in 21 U.S.C.
§ 802.” The IJ subsequently ordered Lacsina removed to the Philippines.
Lacsina appealed the IJ’s order sustaining his charges of inadmissibility to the
BIA. The BIA dismissed his appeal. The BIA agreed with the IJ that Lacsina’s
conviction for receiving stolen property was a CIMT justifying his removal, and it
rejected his argument that a CIMT requires an intent to permanently deprive the
owner of their property because “neither this Board nor the . . . Eighth Circuit . . . has
adopted any such ‘permanent deprivation’ requirement.” Finding Lacsina’s
conviction for receiving stolen property to be independently sufficient to affirm the
IJ’s decision, the BIA declined to discuss Lacsina’s conviction for possession of a
controlled substance. Lacsina was then removed on November 14, 2024. Lacsina
petitioned this Court to review the BIA’s order on November 21st, but this petition
was later consolidated with the proceedings described below on his motion.
In January 2025, after Lacsina had been removed from the United States, he
moved to reopen removal proceedings. Lacsina pointed out that the California
Superior Court had recently vacated his convictions for receiving stolen property
and possession of a controlled substance, and thus, he argued, he was no longer
inadmissible or removable based on these grounds. The BIA did not dispute that
Lacsina’s convictions had been vacated, but it denied his petition under the
“departure bar” regulation, 8 C.F.R. § 1003.2(d). This regulation prevents aliens
who have been removed from the United States from filing a motion to reopen. See
id. The BIA further held that under its decision in Matter of Armendarez-Mendez,
24 I&N Dec. 646, 660 (BIA 2008), it lacked jurisdiction to reopen Lacsina’s case.
Now, Lacsina petitions for review of both the BIA’s earlier dismissal of his appeal
of the IJ’s order and its denial of his motion to reopen.
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II.
We first examine Lacsina’s petition to review the order denying his motion to
reopen removal proceedings. Lacsina argues that the BIA erred in denying his
motion to reopen because the departure bar contained in 8 C.F.R. § 1003.2(d)
conflicts with and is thus invalidated by the statute governing motions to reopen, 8
U.S.C. § 1229a(c)(7). “We review the BIA’s denial of a motion to reopen for abuse
of discretion.” Robles v. Garland, 23 F.4th 1061, 1063 (8th Cir. 2022). However,
“an abuse-of-discretion standard does not mean a mistake of law is beyond appellate
correction.” Henley v. Brown, 686 F.3d 634, 639 (8th Cir. 2012). Additionally,
following the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo,
603 U.S. 369 (2024), “[d]eference to the B[IA] . . . is now a relic of the past.”
Quito-Guachichulca v. Garland, 122 F. 4th 732, 735 (8th Cir. 2024). Thus, when a
statute is clear, like this one, “we no longer treat the government’s views as
controlling or even ‘especially informative.’” Id. (citation omitted); cf. Union Pac.
R.R. Co. v. Surface Transp. Bd., 113 F.4th 823, 833 (8th Cir. 2024) (recognizing
that when “confronted with a statutory ambiguity” a court may consider an agency’s
interpretation to help “determine the best reading of the statute” (quoting Loper
Bright Enters., 603 U.S. at 400)).
Section 1229a(c)(7) states that “[a]n alien may file one motion to reopen
proceedings.” The statute also contains requirements for filing a motion to reopen,
“including numeric limitations, evidentiary requirements, and time deadlines.”
Santana v. Holder, 731 F.3d 50, 56 (1st Cir. 2013) (citing 8 U.S.C.
§ 1229a(c)(7)(A)-(C)). However, the statute does not impose any geographic
limitations on ordinary motions to reopen filed pursuant to § 1229a(c)(7)(A): it “does
not distinguish between those aliens who are abroad and those who remain in the
United States.” Garcia-Carias v. Holder, 697 F.3d 257, 263 (5th Cir. 2012). The
statute only mentions a geographic requirement for motions brought by aliens
suffering from domestic violence. See 8 U.S.C. § 1229a(c)(7)(C)(iv)(IV). Because
aliens filing a motion to reopen under this provision are “exempt[] . . . from the
deadlines on motions to reopen,” “Congress limited this exemption by requiring that
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the alien victim be ‘physically present in the United States at the time of filing the
motion.’” Garcia-Carias, 697 F.3d at 262 (citation omitted).
In contrast to § 1229a, regulations promulgated by the Department of Justice
regarding motions to reopen impose a blanket geographic requirement on all such
motions. See 8 C.F.R. § 1003.2(d). 8 C.F.R. § 1003.2(d) reads as follows:
A motion to reopen . . . shall not be made by or on behalf of a person
who is the subject of exclusion, deportation, or removal proceedings
subsequent to his or her departure from the United States. Any
departure from the United States, including the deportation or
removal . . . occurring after the filing of a motion to reopen . . . shall
constitute a withdrawal of such motion.
The BIA adhered to this regulation in Matter of Armendarez-Mendez, stating
that “the departure bar rule remains in full effect” and that it “impos[es] a limitation
on [the BIA’s] jurisdiction to entertain motions filed by aliens who had departed the
United States.” 24 I&N Dec. at 648, 660.
We have not yet held whether the BIA’s adherence to the departure bar under
8 C.F.R. § 1003.2(d) is a valid exercise of agency authority under 8 U.S.C.
§ 1229a(c)(7). See Ortega-Marroquin v. Holder, 640 F.3d 814, 820 (8th Cir. 2011)
(“[W]hether the departure bar conflicts with 8 U.S.C. § 1229a(c)(7) is a hypothetical
question not properly before this court.”). However, the circuit courts that have
addressed this issue—ten in total—have unanimously held that the departure bar
either conflicts with 8 U.S.C. § 1229a(c)(7) or does not limit the BIA’s jurisdiction
to hear motions to reopen. See, e.g., William v. Gonzales, 499 F.3d 329, 334 (4th
Cir. 2007) (“[I]t is evident that 8 C.F.R. § 1003.2(d), containing the post-departure
bar on motions to reopen, conflicts with the [motion to reopen] statute by restricting
the availability of motions to reopen to those aliens who remain in the United
States. Therefore, we conclude that this regulation lacks authority and is
invalid.”); Prestol-Espinal v. Att’y Gen., 653 F.3d 213, 224 (3d Cir. 2011) (“[T]he
post-departure bar regulation conflicts with Congress’ clear intent[.]”); Santana, 731
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F.3d at 55 (“[T]he rule in every circuit to have addressed the arguments . . . is that
the post-departure bar either conflicts with the motion to reopen statute, or cannot
be justified as a jurisdictional limitation.”); Garcia-Carias, 697 F.3d at 264 (“[T]he
Board’s application of the departure regulation to statutory motions to reopen is
invalid . . . . This conclusion is consistent with the decisions of our sister
circuits[.]”).
Here, we find no reason to chart a different course from our sister circuit
courts. As they all have recognized, there is nothing in the text of § 1229a(c)(7) that
imposes a geographic limitation on filing motions to reopen. See, e.g., Santana, 731
F.3d at 56. The statute imposes limitations on the number of motions an alien may
file, 8 U.S.C. § 1229a(c)(7)(A), the content of the motion, id. at (c)(7)(B), and the
timing of the motion, id. at (c)(7)(C). But it says nothing about a requirement based
on the alien’s location at the time of the filing. Thus, because “[t]he relevant
language nowhere prescribes, or even suggests, a geographic restriction on an ‘alien
[who] may file’ the motion,” the provision “unambiguously confers . . . the right to
file a motion to reopen, in language that admits no exceptions.” Santana, 731 F.3d
at 56 (second alteration in original) (citation omitted); see also Garcia-Carias, 697
F.3d at 263 (“[T]he statutory text conferring a right to file a motion to reopen plainly
does not place any geographic restrictions on its exercise.”). Moreover, “the fact
that Congress [already] provided for specific limitations on the right to file a motion
to reopen bolsters the conclusion that § 1229a(c)(7)(A) cannot [also]
except . . . aliens who have departed the country,” William, 499 F.3d at 333, for
“[w]hen Congress provides exceptions in a statute . . . . [t]he proper inference . . . is
that Congress considered the issue of exceptions and, in the end, limited the statute
to the ones set forth,” United States v. Johnson, 529 U.S. 53, 58 (2000).
Additionally, “Congress’s requirement that domestic abuse victims physically
remain in the United States in order to file out-of-time motions to reopen also
buttresses our interpretation of the [motion to reopen] statute.” Garcia-Carias, 697
F.3d at 264. Where Congress “includes particular language in one section of a
statute but omits it in another section of the same Act . . . it is generally presumed
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that Congress acts intentionally and purposely in the disparate inclusion or
exclusion.” William, 499 F.3d at 333 (alteration in original) (citation omitted).
Thus, because geographic location is only mentioned in the portion of the statute
discussing the domestic violence exception, see 8 U.S.C. § 1229a(c)(7)(C)(iv)(IV),
but not anywhere else, this “supports the conclusion that Congress did not condition
the right to file a motion to reopen on an alien’s presence in the United States,”
Garcia-Carias, 697 F.3d at 264; see also William, 499 F.3d at 333 (“[F]inding that
physical presence in the United States is required before any motion to reopen may
be filed would render the physical presence requirement expressly written into
subsection (c)(7)(C)(iv)(IV) mere surplusage.”); Util. Air Regul. Grp. v. EPA, 573
U.S. 302, 320 (2014) (“[T]he words of a statute must be read in their context and
with a view to their place in the overall statutory scheme.” (citation omitted)).
While the statutory text is ultimately what matters most, the fact that every
other circuit court reviewing the issue has rejected the departure bar also bears
significant persuasive weight. For while “we are not bound by another circuit’s
decision,” “a sister circuit’s reasoned decision deserves great weight and
precedential value.” United States v. Auginash, 266 F.3d 781, 784 (8th Cir. 2001)
(citation omitted). This is particularly true here, where our sister circuit courts
invalidated the departure bar even under the previous Chevron framework, where
they had to “give the agency’s interpretation deference . . . . [so long as] ‘it [was] a
reasonable interpretation of the statute—not necessarily . . . the interpretation
deemed most reasonable by the courts.’” Beeler v. Astrue, 651 F.3d 954, 959 (8th
Cir. 2011) (emphasis omitted) (citation omitted). Given that, under Loper Bright,
“[d]eference to the Board [of Immigration Appeals] . . . is now a relic of the past,”
Quito-Guachichulca, 122 F. 4th at 735, there is now an even lower threshold to reject
the BIA’s interpretation of § 1229a(c)(7) than before.
The Government argues that the BIA did not abuse its discretion because its
decision in Matter of Armendarez-Mendez “remains good law in this Circuit” and
“the departure bar regulation . . . has not been repealed or invalidated by this Court.”
But this argument begs the question. We are not bound by the BIA’s precedent, and
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the very question now before us is whether the departure bar is valid. Furthermore,
the Government’s emphasis on the abuse-of-discretion standard of review is of no
help to it, as “[e]rroneous legal conclusions constitute an abuse of discretion.”
Palmer v. Union Pac. R.R. Co., 139 F.4th 970, 973 (8th Cir. 2025).
The Government also contends that the departure bar is implied in
§ 1229a(c)(7) because at the time it was adopted via the Illegal Immigration Reform
and Immigrant Responsibility Act of 1996 (IIRIRA), 110 Stat. 3009-546, lawmakers
were concerned that “aliens were filing frivolous motions to reopen as a means of
prolonging their time in the United States.” However, “legislative history is not the
law,” Avila v. Bondi, 170 F.4th 1128, 1138 (8th Cir. 2026) (citation omitted), and
even if it were, it would not support the Government’s contention here, see
Garcia-Carias, 697 F.3d at 261-62 (noting that IIRIRA repealed a prior statute
“prohibit[ing] federal courts from reviewing deportation and exclusion orders if the
alien ‘ha[d] departed from the United States after[wards]’” and instead “established
a statutory right to file a motion to reopen” (citation omitted)); Dada v. Mukasey,
554 U.S. 1, 14 (2008) (noting that IIRIRA “transform[ed] the motion to reopen . . . to
[create] a statutory form of relief”).
We also agree with Lacsina that the BIA abused its discretion in holding that
it lacked jurisdiction to reopen his removal proceedings. Although the BIA relied
on Matter of Armendarez–Mendez to conclude that it lacked jurisdiction, “Congress
alone controls the BIA’s jurisdiction to hear motions to reopen filed under 8 U.S.C.
§ 1229a(c)(7).” Luna v. Holder, 637 F.3d 85, 100 (2d Cir. 2011). And because
§ 1229a(c)(7) “says nothing about jurisdictional limitations of any kind, let alone
th[ose based on the departure bar],” the BIA’s interpretation here “has no roots in
any statutory source and misapprehends the authority delegated to [it] by Congress.”
Pruidze v. Holder, 632 F.3d 234, 235 (6th Cir. 2011). Thus, we agree that “the BIA
may not contract the jurisdiction that Congress gave it by applying the departure bar
regulation, as suggested by the BIA in Armendarez–Mendez, to statutory motions to
reopen.” Luna, 637 F.3d at 100 (citation omitted); see also Palmer, 139 F.4th at 973
(noting that erroneous legal conclusions are an abuse of discretion).
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Lastly, Lacsina argues that the BIA erred in declining to reopen his case sua
sponte pursuant to 8 C.F.R. § 1003.2(a); he argues that it erroneously concluded that
the departure bar deprived it of jurisdiction to do so. 2 However, Lacsina concedes
that “[t]his court has previously joined many other circuits in deciding that the court
does not have jurisdiction over the BIA’s decision whether to reopen sua
sponte . . . ‘under 8 C.F.R. § 1003.2(a).’” We agree. See, e.g., Tamenut v. Mukasey,
521 F.3d 1000, 1005 (8th Cir. 2008) (en banc) (per curiam) (“[W]e join ten other
circuits in concluding that the BIA’s decision whether to reopen proceedings on its
own motion under 8 C.F.R. § 1003.2(a) is committed to agency discretion by
law.”); Manyary v. Bondi, 129 F.4th 473, 479 (8th Cir. 2025) (“Although the BIA
may reopen removal proceedings sua sponte, this Court generally lacks jurisdiction
to review such decisions.”). Thus, we decline to address the legal question of
whether the departure bar deprives the BIA of jurisdiction to reopen a case sua
sponte, as we could not review the BIA’s decision to reopen a case sua sponte
anyway. Cf. Vorbeck v. Schnicker, 660 F.2d 1260, 1264 (8th Cir. 1981) (“This
Court is without power to give advisory opinions.” (citation omitted)). Accordingly,
we grant the petition for review as to the BIA’s denial of Lacsina’s statutory motion
to reopen, but deny the petition for review as to its denial of his motion for sua sponte
reopening.
III.
Lacsina also challenges the BIA’s order affirming the IJ’s order sustaining his
charges of inadmissibility. However, both the IJ’s and the BIA’s orders were based
on Lacsina’s criminal convictions in California state court, and Lacsina’s subsequent
motion to reopen was based on the fact that these convictions were vacated.
2
Because a sua sponte reopening of proceedings is a different remedy from
the grant of a statutory motion to reopen, see Tamenut v. Mukasey, 521 F.3d 1000,
1004 (8th Cir. 2008) (en banc) (per curiam) (noting that “[t]he statute governing
motions to reopen . . . does not establish any standard to guide the agency’s
discretion whether to reopen on its own motion”), we address this issue separately.
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Thus, the BIA should have the first opportunity to consider the motion to
reopen based upon the vacated California convictions. Our holding today is merely
that Lacsina’s “statutory right to file a motion to reopen is not trumped by the
B[IA]’s departure [bar] regulation.” Garcia-Carias, 697 F.3d at 265. So, “[g]iven
our narrow procedural ruling, nothing in this opinion should be read as commenting
on any substantive claim [Lacsina] may present on remand.” Id. at 265-66.
IV.
For the foregoing reasons, we grant Lacsina’s petition for review as to his
statutory motion to reopen, deny his petition for review as to his motion for sua
sponte reopening, and remand for further proceedings consistent with this opinion.
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