Ovalles v. Holder: Better Late than . . . on Time? The Fifth Circuit Avoids Ruling on the Validity of the Postdeparture Bar

Recent Development by Emma Rebhorn

The United States Court of Appeals for the Fifth Circuit held that Ovalles's motion to reconsider was untimely, that the regulatory postdeparture bar precluded the BIA's reconsideration of his motion, and that the denial of the motion did not violate Ovalles's due process rights. Ovalles v. Holder, 577 F.3d 288, 299-300 (5th Cir. 2009).


About the Author

Emma Rebhorn. J.D. candidate 2011, Tulane University School of Law; B.A. 2008, Columbia University.

Citation

84 Tul. L. Rev. 1347 (2010)