The Response to President Trump’s Shameless Religious Photo Op Gives Me Hope for the Future

MARCI A. HAMILTON

University of Pennsylvania professor Marci A. Hamilton praises the response of liberal clergy in response to President Trump’s seemingly opportunistic photo op in front of St. John’s Episcopal Church in Washington, D.C. Hamilton calls upon these religious leaders to continue speaking out loudly in the name of inclusion, love, and truth.

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Point Du Jour v. U.S. Attorney General

Docket: 18-15235

Opinion Date: June 4, 2020

Judge: Tjoflat

Areas of Law: Immigration Law

The Eleventh Circuit denied a petition for review of the BIA's dismissal of petitioner's appeal from the IJ's order of removal, and denial of petitioner's motion for remand based on a claim of ineffective assistance of counsel. The court held that the BIA did not abuse its discretion in determining that petitioner failed to satisfy the procedural requirements set out in Matter of Lozada for her ineffective assistance of counsel claim. In this case, the affidavit does not allege that petitioner conveyed to counsel that his assistance was ineffective, or that petitioner ever attempted to contact counsel for the purpose of telling him so. Therefore, nothing in the affidavit indicates that counsel had any actual notice of allegations that his assistance had been ineffective or any opportunity to respond to those allegations, as required by Lozada. The court also held that petitioner's additional contention that he substantially complied with the notice requirement of Lozada by filing complaints against counsel with the Florida Bar and the Executive Office for Immigration Review cannot be sustained because it would eviscerate the separate nature of the Lozada requirements. Furthermore, petitioner's complaints to disciplinary authorities about counsel cannot support substantial compliance with the notice requirement because the Florida Bar and immigration review procedures of sending notice to the complained-of attorney are not automatically triggered. Finally, the court held that the BIA did not fail to give reasoned consideration to petitioner's evidence.