MEERVIS v. GARLAND (2021)

Dave Henri R. Meervis, a native and citizen of Belgium, has filed a pro se petition for review of the order of the Board of Immigration Appeals affirming without opinion the immigration judge's written decision denying Meervis’ application for asylum and ordering Meervis removed to Belgium. On appeal, we confine our review to the issues raised in the informal brief. See 4th Cir. R. 34(b) (directing appealing parties to present specific arguments, issues, and supporting facts in an informal brief and observing that this court “limit[s] its review to the issues raised in the informal brief”). Affording Meervis’ pro se informal brief a liberal construction, see Erickson v. Pardus, 551 U.S. 89, 94, 127 S.Ct. 2197, 167 L.Ed.2d 1081 (2007) (instructing courts to liberally construe pro se documents), we conclude that Meervis has failed to challenge the immigration judge's dispositive rationale, which became the final agency determination, see 8 C.F.R. § 1003.1(e)(4) (2021). We therefore hold that Meervis has forfeited appellate review of the Board's order. See Jackson v. Lightsey, 775 F.3d 170, 177 (4th Cir. 2014) (“The informal brief is an important document; under Fourth Circuit rules, our review is limited to issues preserved in that brief.”).

Accordingly, we deny the petition for review. We deny as unnecessary the Attorney General's motion to remand and deny as moot Meervis’ motion for injunctive relief pending appeal. 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

PER CURIAM:

Petition denied by unpublished per curiam opinion. Unpublished opinions are not binding precedent in this circuit.