Yasmeen Manjiyani v. Immigration and Naturalization Service

BETTY B. FLETCHER, Circuit Judge,

dissenting:

I respectfully dissent. The majority adopts a rule that permits the INS to deport an alien in absentia when the agency, in full knowledge of the alien’s current address, has failed to mail notice to the alien of the deportation proceedings. Due process does not permit such a result.

Our precedents require that the agency must send notice of deportation proceedings to the alien’s last known address. See Dobrota v. INS, 311 F.3d 1206, 1210 (9th Cir.2002); Farhoud v. INS, 122 F.3d 794, 796 (9th Cir.1997). The law does not require that the alien actually receive notice of the proceedings, but it places a reasonable burden on the INS to make an effort consistent with the agency’s awareness of the alien’s address and contact information. Dobrota, 311 F.3d at 1210.

The undisputed record in this case demonstrates that the INS was aware of petitioner Manjiyani’s actual and then-current California address at least three months before any attempt was made to notify her of deportation proceedings in Seattle. In January 1996, two and a half years after the INS served her with an order to show cause, Manjiyani, after moving to California, provided the INS in Los Angeles with her California address and alien identifica*1144tion number in connection with proceedings to adjust her status. However, the immigration court in Seattle first mailed notice of Manjiyani’s deportation proceeding to her former address in Yakima, Washington. It is undisputed that the INS and the immigration court had received fully proper notice in 1994 that Manjiyani had moved from Yakima, Washington, to Bellevue, Washington. Apparently only after the notice that was sent to Yakima was returned did the INS check its records to find that Manjiyani had moved to Bellevue. Notice was then sent to the Bellevue address, which also was returned. As the majority correctly notes, no further action was taken to notify Man-jiyani.

The INS does not contend that it was not actually provided with notice of Manji-yani’s California address. It has merely argued that the INS office in Los Angeles did not communicate the information to the INS office in Seattle and that the agency was not required to do so because the agency treats deportation proceedings separately from other agency activities, including processing petitions to adjust status. It concludes, therefore, that the last known address for Manjiyani was the Bellevue, Washington, address. I find this argument unpersuasive.

In 1990 Congress required the INS to create and maintain a central address file with the names and addresses of all immigrants in deportation proceedings. See Act of November 29,1990, Pub.L. No. 101— 649, 104 Stat. 4978. Congress’s mandate stated that “[t]he Attorney General shall create a system to record and preserve on a timely basis notices of addresses and telephone numbers (and changes) provided under paragraph (1)(F).” 8 U.S.C. § 1252b(a)(4). In turn, paragraph (1)(F) requires that the alien initially provide the Attorney General with a written record of her address, id. § 1252b(a)(1)(F)(i), that the alien “provide the Attorney General immediately with a written record of any change of the alien’s address,” id. § 1252b(a)(1)(F)(ii), and that the possible consequence of failure to comply may be deportation in absentia. Id. § 1252b(a)(1)(F)(iii). The statute does not require an alien who, like Manjiyani, complies with paragraph (F)(ii) to indicate affirmatively that she is in deportation proceedings. I find it wholly implausible that Congress’s mandate to create and maintain the central address files was as limited as the majority appears to believe.

Clearly, if the INS had complied with the Congressional mandate embodied in § 1252b(a)(4), upon receipt of Manjiyani’s forms in California it would have entered her name, alien registration number, and address into the central address files and known immediately that there were deportation proceedings pending against her in Seattle. Moreover, the INS office in Seattle would have been able to check the central address file and would have known immediately of Manjiyani’s California address.

However, under the majority’s interpretation of § 1252b, the INS has no affirmative obligation to check whether an alien who presents herself for some other reason, such as change of status or renewal of a visa, is in deportation proceedings and no accompanying obligation to update its central files. This is not a reasonable interpretation of Congress’s statutory command.

The Eighth Circuit has already rejected this narrow interpretation of § 1252b’s scope. See Kamara v. INS, 149 F.3d 904, 906-07 (8th Cir.1998). The Kamara panel held that the written obligor form that Kamara’s uncle filed with the INS provided adequate notice to the INS of her changed address, even though it did not indicate that her address had actually *1145changed (but was merely the “same” as her uncle’s). The Eighth Circuit reasoned:

Once the Virginia INS office had received written notice of the change of address, it was their responsibility to enter the new address into the central filing system specifically created in connection with the enactment of § 1252b. It is possible that Kamara did not receive notice of her deportation hearing because the Virginia INS office failed to enter her new address into the filing system.

Id. at 907. The court then held that “the INS failed to send the deportation hearing notice to the most recent address provided by Kamara, and therefore did not provide notice in accordance with 8 U.S.C. § 1252b(a)(2).” Id. I find this reasoning persuasive. The majority infers that the INS in Kamara was aware that Kamara was in deportation proceedings because her uncle posted a bond. The Kamara opinion provides no support for that proposition. There is no indication that the obligor form indicated that Kamara was in deportation proceedings; nor does merely posting a bond on behalf of an alien clearly show that the alien is in deportation proceedings. See 8 C.F.R. 103.6 (discussing circumstances in which bonds for aliens may be posted).1

Because Manjiyani provided the Attorney General via the INS office in Los Angeles with adequate written notice of her change of address and the INS failed to comply with the requirements of § 1252b to send notice to Manjiyani’s last known address, I conclude that the INS did not comply with the requirements of due process, see Farhoud, 122 F.3d at 796, and that the BIA’s decision not to grant her petition to reopen deportation proceedings must be reversed.

However, even if the documents that were filed with the Los Angeles INS office did not trigger any obligations under § 1252b’s central address file provision, there is uncontradicted evidence that, at some point in the status-adjustment proceedings, the Los Angeles office learned that Manjiyani was in deportation proceedings and stopped its own proceedings. At oral argument, counsel for the INS conceded that, based on the record presented, he could not determine why and when this had happened. The easiest (but not only) explanation is that, contrary to the INS’s assertions, the Los Angeles and Seattle offices did communicate and became aware of Manjiyani’s identity, status, and her California address. I submit that it would be proper to remand to the BIA for further proceedings to determine when the Los Angeles office became aware of Manji-yani’s deportation proceedings in Seattle and the circumstances of their discovery. Of course, if the offices communicated about Manjiyani before her deportation proceedings in Seattle were completed, then her deportation in absentia plainly *1146did not comport with the requirements of due process of law.

The equities of this ease, to me, weigh strongly in favor of Manjiyani. There is no indication in the record that Manjiyani sought to “forum shop” between the INS offices in Seattle and Los Angeles. Nor is there any indication that she, herself, acted with the intent to deceive or mislead the immigration service. However, Manji-yani’s attorney before the INS in her deportation proceedings and her proceedings in Los Angeles to adjust her status, Dan P. Danilov, was brought up before this court on disciplinary charges for failure to prosecute ten petitions for review of INS proceedings properly.2 See In re Danilov, No. 98-80043 (9th Cir. Jul. 22, 1998) (report and recommendation of the appellate commissioner). The disciplinary proceedings were terminated without prejudice upon Danilov’s resignation from the bar of this court. The record in this case is replete with evidence that Manjiyani’s representation by Danilov below was flawed.

Accordingly, I respectfully dissent from the majority’s determination that Manjiya-ni’s petition to reopen her deportation proceedings must be denied.

. The majority does not reach the question of whether the INS's regulation, 8 C.F.R. § 3.15(d)(2), is a basis independently for denying Manjiyani’s petition. The regulation itself, insofar as it permits the INS to avoid complying with Congress's intent in enacting § 1252b and with basic notions of due process, presents quite serious problems. Reading the regulation to delineate the only circumstances in which the INS must send notice to a new address raises the difficulty of substantially undermining Congress's clear mandate that the INS centrally keep track of the addresses of aliens in deportation and of constitutional due process. I read § 3.15(d)(2) as a safe-harbor provision that permits an alien to know when reporting a change of address to the INS that it will indubitably trigger the INS's obligations to provide notice to a specific address. Accordingly, I conclude that it does not require us independently to deny Manjiyani’s petition.

. Danilov has also been suspended from the practice of law in Washington State as of December 12, 2002; and at oral argument, Manjiyani's current attorney was able to inform the court that there were proceedings by the INS to discipline him for his practice before that agency.