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UNITED STATE DISTRICT COURT Wheel N . Milby

FOR THE 5r-TH e*DISTRICT AUG 1 .92005 Clerk of Court

File No. ~ 2 -? 13 q 038

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Respondent AT 4 LL ~ ~ ^ ^ 8 ~UO am

Petitioner, BrigbRman O. Nwptu, hereby moves the Court for an Order staying hisphysical deportation from the United States until such time as the Court has issued a finaldecision on the petition for review . In support of such Motion, Petitioner statest11111111110as foll0vv :

4.

uscAS 107

Unfbd Suft District CourtSouthern Distr i ct of Text

FILED

'U. sA couRr of APPEAW 11 2005F1 L Irn

~(Ll" TnvArJ ovW A-7uPetitioner,

CH_ARW R, ,FULB,RUGE IIICLERK

PEITONER'S MOTION FOR A STAY OF DEPORTATIONPENDING RESOLUTION OF PETITION FOR REVIEW

and MEMORANDUM OF LAW IN SUPPORT OF STAY OF DEPORTATION

1 .

2.

3 .

Petitioner's administrative appeal to the Board of Immigration (BIA) appeals wasdismissed by the Board on May 22, 1997. This decision was received bypetitioner six months late. Attorney, Joseph DeM,ott, did not contact petitioneruntil December 2002. This prevented a timely response by the petitioner . TheBIA upheld the Immigration Judge's finding that petitioner was deportablewithout access to relief from deportation.Petitioner has on this date filed a petition for Review before this Court pursuant toINA 106(a)(l) and (2). In cases involving deportation in absentia, Petition forReview must be filed within thirty days of the final administrative order ofdeportation . In such cases, filing the Petitioner's deportation from the UnitedStates during the pendency of the Petition for Review. INA 106(a)(3~ 8 USC1105(aX3), as amended by section 513 of the Immigration Act of 1990, Act ofNov. 29, Pub. L . 101-649,104 Stat 4978.1Petitioner is therefore subject to being physically removed and deported from theUnited States at any time.Petitioner contends that the Immigration Judge's finding of deportability/denial ofaccess to relief from deportation was contrary to statue and regulation and aviolation of his right to a hearing consistent with fundamental and due process oflaw. His contentions that he was denied a Fair hearing and that he is entitled torelief are supported by legal authority. His case presents an issue of firstimpression in the Circu it which, pursuant to his Petition for Review, he will fullybriefand argue before his Court.

Case: 05-60832 Document: 005177021 Page: 1 Date Filed: 08/19/2005

5. Petitioner has substantial liberty interest at stake-his right to remain with hisfamily, not to be virtually exiled and/or subjected to persecution/extremehardship. He has considerable equities under the immigration laws . A denial of aStay of Deportation would allow INS to act to deport him and render his Petitionfor Review mood

6. A Petition for Review and a writ of habeas corpus of original convictions isbefore the Court of Criminal Appeals (see attached) .

7. Relief has been sought in this Court because this Court is the proper venue inwhich to seek stay. Petitioner, therefore, seeks the protection of this Court andasks that the Court issue and Order granting a Stay of Deportation during itsconsideration of the petitioner's Motion for Stay and during its Consideration ofthe Petition for Review.

PETITIONER'S MEMORANDUM OF LAWIN SUPPORT OF STAY OF DEPORTATION

Petitioner, Brighlman O. Nwatu, seeks to raise before this Court legal is= offirst impression in this Circuit. A Stay of Deportation is critical for the Petitioner toobtain meaningful review of these issues.

Respondents, Executive Office of Immigration Review (hereinafter EOIR) at boththe Immigration Court and Board of Immigration Appeals (hereinafter BIA of the43oard)levees have prevented Mr . Nwatu from making an application for the mandatory relief ofwithholding of deportation, and have frustrated his opportunity to obtain meaningfuladjudication of his claim that his life and safety will be endangered within the meaning ofthe Refuge Act of 1980 should he be deported to Nigeria. Respondents have effectivelydenied Petitioner's application for withholding of deportation under Section 243(h) of theImmigration and Nationality Act (hereinafter INA) without any consideration of thelikelihood of persecution he now daces or whether he poses any danger to the communityof the United Stakes.

By refusing to consider the evidence in support of Petitioner's application forwithholding of deportation in fight of his criminal convictions, Respondents effectivelydenied Petitioner a full and complete hearing on his statutory right to apply for and, ifeligible, receive withholding of deportation . In so doing, Respondents denied Petitionerdue process as afforded by the Fifth Amendment .

The BIA denied Petitioner's application for relief in violation of the plain Meaning of the language contained in the Immigration Act of 1990. The Immigration

Act of ] 99Q (hereinafter IMMACT) added language to those sections of the INS whichgovern asyltim and withholding of deportation applications made by aggravated felons .Under Section 208(d) of the INS, Congress added an absolute bar preventing anaggravated felon from having access to political asylum relief with the followingunambiguous language: "An alien who has been convicted of an aggravated felony-maynot apply for or be granted asylum." Section 208(d) ; 8 USC 1158(d) .

CSCAS 108


In amending Section 243(h) -the withholding of deportation section, Congress didnot use language which would absolutely preclude protection for qualified aggravatedfelons, Instead, Congress added a provision that "For purpose of subparagraph (B), analien who has been convicted of an aggravated felon shall be considered to havecommitted a particularly serious crime ." INA 241(h)(2), 8 USC 1253(hX2) .Subparagraph (B), which predated the 1990 states that withholding ofdeportation shall not apply to an alien if the Attorney General determines that, "the alien,having been convicted by a final judgement of a particularly serious crime, constitutes adanger to the community of the United States . . ."

The admimistraiive interp etatio - of the "particulary serious crime" provisionunder prior law was ambiguous . In one decision the Board held that all of the facts andcircumstances, including the nature of the crime for which the alien was convicted, theelement of danger to the community, and the Level of persecution he would face if deniedprotection, should be evaluated together if their totality . Matter of Frentescu, 18 I&NDec. 244 (BIA 1982). In other cases, the Board held that no separate finding ofdangerousness was required to bar Section 243(h) relief. Matter of Gonzalez, Int. Dec.3071 (BIA 1988) .

Regardless of what the administrative interpretation was previously, Congress'amendment of the statute compels a reviewing court to revisit the agency's constructionof the provision. By now providing the absolute preclusion for asylum and theconditional preclusion for withholding for aggravated felons who are a danger to thecommunity, Section 243(hx2) must be regarded as a subsequent legislative enactmentdemons' stiog Congressional intent to reject prior interpretations . In denying relief toPetitioner, the Board failed to examine the plain meaning of the present statutorylanguage and the legislative history of these two differently worded preclusions .

The statutory lion that withholding is available to aggravated felons whoare not a danger to the community is supported by one of the principal architects ofIMMACT, Karl Hampe, minority counsel to the Senate Subcommittee on ImmigrationAffairs. He has written the following about the Section 243(h) amendments : "Thelegislation also limited or eliminated the use by aggravated felons of certain forms ofrelief from deportation. . .lt should be emphasized that, although criminal aliens may notapply for asylum, withholding of deportation may still be requested ." "Ramps,Immigration E*rceme»t, Exclusions, and Deportation Provisions of the ImmigrationAct of1990,212,216-7, Prentice Hall, Law and Business, December, 1990 . SenatorKennedy, as recently as April 1992, has affirmed that Congress did not intend to precludeall aggravated felons from access to relief from deportation in the face of probability ofpersecution sufficient to trigger the protections of INS 243(h).

As in Caraloza-Fo»esca v. IIVS, 107 S. Ct 1207 (19", the plainmeaning of the statue indicates that Congress had one intention for asylum applicants,and a different one for withholding applicants . In Cardoza-Fonesca the Court looked tothe legislative history of the sections as well and stated: "('T] he plain language of thisstatute appears to settle the questions before us . Therefore, we look to the legislative

L'~ SCAS 109


history to determine only whether there is `clearly expressed legislative intention'contrary to that language, which would require us to question the strong presumption thatCongress expresses its intent through the language it chooses . Id. At 1217 (citationsomitted) . In this case the legislative history an the plain meaning of the statute indicatethat Congress meant to absolutely bar aggravated felons from asylum, but to bar themfrom withholding only if they we in danger to the community . The BIA has failed toconsider whether Petitioner poses a serious danger to the community and, in so doing, hasrefused to even consider the possibility that he may be eligible for withholding .

The Ninth Circuit Court of Appeals has held that it is an abuse of discretion todeny a stay of deportation when an alien raises a non-frivolous constitutional issue whichhas not yet been decided by either this Circuit or by the Supreme Court. Blancada v.Turriage, 891 F.2d 688. 690 (91h Cir. 1989). Petition contends that he is eligible to applyfor and eligible to receive withholding of deportation . The BIA has refused-to grant hima full an complete hearing on this request and in so doing has denied him due process.

FYI: Petitioner was held in the immigration detention center in Los Fresnos, TXfor almost 6 months. Petitioner was subsequently released to pursue oppeals and motionbefore the BIA, district courts, and Criminal Court of A .ppeaZs .

The INS has blatantly disregarded the Rule of Law and petitioner will ask theCourt to grant this request and dismiss any fiuthez motion, extension, and appeals that theINS may bring forth .

PRAYER FOR RELIEFAppoint counsel on behalf of petitionerTerminate deportation proceedings .Vacate the Order of Deportation in absentia and grant petitioner necessary time to

continue his quest for citizenship .Grant petitioner any other relief this Court may seem just .

For the foregoing reasons, Petitioner's Motion for a Stay of Deportation should begranted .

Respectfully submitted,

Date : ~41 10 s t39 1 &H T- rv A-tJ Nw A-N

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USCA5 I 10


BRIGHTMAN NWATU, A27174038208 Vines Drive

Cedar Hill, TX 7510414th Day of February 2005

In Removal ProceedingsNo. A27174038

Aaron Cabrera, Officer in ChargeAlberto Gonzale4 Attorney GeneralAlfoaso Deleon, District Director et al .

In the matter ofBrightman NwatuRespondent

V .

USCAS 1 ] ]


ISSUE

I . The September 10, 1992 memorandum of the oral decision of the ImmigrationJudge, Honorable Bernal Maldonado of San Antonio in the matter ofBrightman Nwatu reads : "The proceedings were suspended [un il) probationis revoked, or expungement is refused, or until respondent has had areasonable opportunity to obtain an easement after discharge fromprobation, which event occurs first .

In 1996, the Service moved to recalendar proceedings and a hearing was setfor February 14, 1996 despite the fact that none of the stipulations of the 1992decision had been met as to warrant a re-opening of the proceedings .

II. Application of Section 440(d) of AEDPA and Panel's Interpretation ofSection 241(ax2xAxii) of the Immigration and Nationality Act .

USCAS 112


PETITIONER'S PETITION AND SUPPLEMENTAL MOTION, AND ARGUMENT

ALIENS STATEMENT OF PURPOSE

In the judgment of undersigned alien, the Petitioner's appeal merits rehearing for thefollowing reasons:

1 . The Panel overlooked a material principle of law in its decision . Specifically, itcompletely ignored longstanding United States Supreme Court precedent holdingthat the Immigration and Naturalization Services bears the burden of establishingan alien's deportability by clear and convincing evidence . See Woodby v. INS385 US 276 (1966).

2. The Panel's decision is in conflict with prior rulings of the BIA, Supreme Court,Federal Courts, and District Courts in that it affirms an order of deportation basedon a ground of deportability not final where all legal remedies have not beenexhausted. Petitioner had clearly made it known that allegations would becontested. The Panel further ignored the prior IJ ruling--Until petitioner has hadreasonable time after discharge from probation ."

3. The Panel's decision is in conflict with the decisions of the United StatesSupreme Court, in that it violates applicable canons of statutory construction .First, it failed to interpret the statute at issue (241 Xax2xu) of the Immigrationand Nationality Act and AEDPA 12xH) of the Immigration and Nationality Actand AEDPA 440(d), in accordance with its plain meaning . In addition, it failed toapply the principle of "expression unius est exclusio a2terius," which dictates thatthe enumeration of particular things in the language of a statute excludes the ideaof something else not mentioned. Finally, it ignored the principle that statutesregarding deportability are to be strictly construed in favor of the alien .

4. The proceedings involve two issues of exceptional importance:a. The proper application of the government's burden of proof in establishing

the deportability of a lawful permanent resident of the United States. TheBIA's decision, if left undisturbed, presents a substantial risk thatdecisions with the courts and the BIA rtseK the US Supreme Courtregarding deportability from the United States will be made or reviewedpursuant to the wrong legal standard .

b. The proper role of the judiciary in interpreting statutes. Here the BIAfailed to interpret the statute at issue according to three longstandingcanons of statutory construction. The plain meaning doctrine, the doctrineof "expresio unius eat exclusion alterius," and the doctrine requiring thedeportability statute a crime not expressly enumerated or act therein byCongress.

SUGGESTION

Because the BIA's decision ignored the applicable burden of proof upheld a finding ofdeportability based on ground of wrong interpretation and violated applicable canons ofstatutory construction, Petitioner requests a re-hearing and termination of proceedingsand grant of naturalization.

USC.A55 113


BACKGROUND FACTS

Petitioner is a native and citizen of Nigeria, who has been a lawful permanent resident ofthe United States since 1990 . He lives and contributes to the support of his fit nily whoare United States citizens . Mr. Nwatu had no criminal record until he was convicted oftheft by check and theft from a person. Those convictions gave rise to the issuespresented in this appeal .

Mr. Nwatu was placed in deportation proceedings by the Immigrat ion Service. The INSissued an Order of Show Cause (OSC or charging document) , which alleged in pertinentpart that Mr. Nwatu deportable pursuant 241(ax2}(ii) of the Immigration and NationalityAct (INA).

The Immigration Judge Honorable Bernal Maldonado in 1992 suspended petitioner'sdeportation proceedings. The Immigration Service concurred by not filing an appeal butsought to recalendar case years later with no just cause . Petitioner's probation had notended, expungement had not been sought since petitioner was still on probation andmeeting the conditions set by the Court .

RELEVANT ASPECTS OF THE PANEL'S DECISION

Nowhere in th~ Panel's decision does it even address the burden of proof the INS mustsatisfy to establish an alien's deportability. Obviously, it never determined whether the Uhad satisfied that standard.

With regard to the specific issues by Mr . Nwatu, the BIA and Ws decision was in error ina number of respects. First, the Panel (BIA) dismissed the issue concerning the proprietyof the second IJ recalendaring the case when none of the conditions by Judge BernalMaldonado had been met. The Panel stated the OSC "did cite the statutory authority fordeportation" INA 241(a}(2)(n) and this was sufficient to give notice of the change .

Further, the Board concluded that the recalendared proceedings were sent to therespondent's counsel of record and the respondent's last known address . This is furtherfrom the truth. Enclosed is a copy of a rental box agreement with the US Post Office .The Immigration Service alleged that the box address was closed .

This language and interpretation illustrates the Immigration Judge and the BIA error .Rather than reading the statute to determine what type of method was used to contactrespondent, the BIA ignored is previous precedent that held-INS must show thoroughconvincing and clear process was used to contact alien . The BIA standard also mandatesthat correspondence to alien must be made directly to alien . The Service even concludedin their argument that it was aware last address was not valid through mere assumption .They never directly attempted to contact alien but rather relied on hearsay by formercounsel.

Similarly, the Board failed to directly address the canon of statutory construction adoptedby earlier (BIA) decisions, circuit courts, providing that "expression unius eat exclusioalterius." The language set forth demonstrates that it failed to abide by that controllingprinciple.

USCA5 114


ARGUMENT

The Panel completely ignored the standard of p roof identified by the UnitedStates Supreme Court, by which the Immigration and Naturalization Servicemust establish deportability .

The seminal case regarding the burden the INS must satisfy in establishing an individualalien's deportability from the United s is way v. INS, 385 US 276 ( 1966). InWoodby, which also involved a lawful permanent resident alien, the Supreme Courtspecifically analyzed the burden the INS must satisfy, recognizing "the drasticdeprivations that may follow when a resident of this country is compelled by ourGovernment to forsake bonds formed here . . ." Id at 285. The Court rejected thepreponderance of the entire standard urged by INS, and held instead that the agency mustmeet the wine high standards of proof required in denaturalization and expatriationcauses; if the INS must establish its allegations by clear, unequivocal, and convincingevidence. Id. The Supreme Court based its ruling on the fact that deportation sometimesimposes greater hardship than d~nahualization, because it necessarily results in expulsionfrom our shores.

Moreover, the Court recognized hat in some cases, permanent residents have lived in theUnited States longer than some who have become citizens, and as a result, haveestablished stronger family, social, and economic ties Id .

This is precisely the situation in the instant case . Mr. Nwatu has been a permanentresident for a period now exceeding 24 years. He has virtually no ties to Nigeria, butlives here in an intact nuclear family unit with a U .S. citizen child and mother. His socialand economic support system is exclusively in the United States . Supreme Courtprecedent demands that his deportabift be established by clear, unequivocal, andconvincing evidence.

The INS has failed to meet the burden in this case . To the contrary, Mr. Nwatu has beenfound deportable on a ground of deportability that the INS did not convincingly establishagainst him. His probation was not complete, expumgea~ent had not been sought, and alllegal remedies had not been exhausted .

To make matters worse, the BIA and the IJ have interpreted the statute of 440(d) in anexpansive manner inconsistent with the principles established by the Supreme Court andCongress.

II. THE PANEL ERRONEOUSLY UPHELD THE IJ INCOMPLETE FINDINGIN RECALENDARING CASE AGAINST PETITIONER

The petitioner has consistently argued that he can not be found deportable on the basis ofa charge that its final remedy has not been achieved and in which an IJ had suspendedproceedings until Respondent has had time to seek expuagement .

III. THE PANEL EXCEEDED ITS AUTHORITY BY EFFECTIVELYBROADENING AEDPA TO ELIMINATE RELIEF OF 212(C) WHEN ITWAS NOT EXPRESSLY ENUMERATED BY CONGRESS WHEN

USCAS 115


CONGRESS DID NOT INTEND TO DO SO. AT THE PRESENT TIME,PETITIONER IS ENTITLED TO 212(C) .a. The Plain Meaning Doctrine

The principal canon of statutory construction is that a statute must first be interpreted bygiving its language its plain and ordinary meaning. K-Mart v. Cartier, Inc 486 USC 281(1998). Therefore, in determining whether Mr. Nwatu was deportable, the Panel shouldhave looked at the specific language of 242(A}(2xu) and asked itselfwhether Mr .Nwatu's conviction arises to the level of crimes listed therein. The Panel should havealso looked at whether the order of Immigration Judge Maldonado had been met. If ithad done so, it would have determined that Mr. Nwatu is nat .deportable. It failed to doso, completely ignoring the plain meaning rule and the clear and convincing methods ithad applied in previous decisions .

Although invoking the plain meaning doctrine, the BIA actually engaged in a completerewrite of a statute when it retroactively applied Section 440(d) of AEDPA to petitioner.The convictions were almost 10 years before President Clinton signed AEDPA into lawon April 24, 1996. The Panel relied on the fact that both the Immigration Acts expandedthe definition of AEDPA when Congress did not intend as such.

This conchision is completely unsupported . In fact, exactly the opposite is a ppareuL Thesimple fact that Congress did not say so is evidence it did not intend to go that far.

b. Expressio Unis eat Exclusio AlteriusThe same conclusion is compelled by the other applicable canon of statutoryconstruction, 'expressio unis eat exclusion alterius', dictating that enumeration ofparticular things in the language of a statute excludes the idea of something else notmentioned. Adams v. Dole, 927 F.2d 771(4'" Cir.) cert. denied, 502 US 837 (1991);Allstate Ins. Co v. Skeeters, 846 F .2d 932 (0 Cu. 1988) .

Congress clearly chose to enumerate a laundry list of specific acts that are not included invarious parts of 440(d) . The error was compounded by the way the U and BIA dispensedwith the requirement for a conviction and the degree clearly enumerated by Congress .By interpreting 440(d) as such and the degree of crime, it read the requirement right outof the statute.

c. Narmw Construction of Deportation StatutesThe Panel's decision also ignored the longstanding principle that deportation statutesmust be narrowly construed, and construed in favor of aliens . The Supreme Court hasconsistently applied this rule . INS v. Errico, 385 US 214, 225 (1996) ; INS v. Cardoza-Fonseca, 480 US 421, 449 (198 ; Rosenbeag v. Flenti, 374 US 449,459 (1963) ; Bonattiv. Rogers, 356 US 691, 699 (1956); Barber v. Gonzalez, 347 US 637; 642-433 (1954) ;Fong Hon Tan v. Phelan 333 US 6 (1948) .

The discussion above illustrates that the approach by the Panel was repeatedly at oddswith this aspect of Supreme Court precedent. At every turn, the IJ and BIA interpreted440(d) and 242 A (2Xii), as broadly as possible, rather than narrowly. It cannot bedisputed that this worked to the detriment of Mr. Nwatu. If the statute had been readnarrowly, according to its plain meaning, and without reading into the statute a simple

USCA5 116


• _A6%

theft conviction was not an argument which resulted in this charge was not expresslyenumerated therein, the Panel would have been compelled to reach a different result .

A re-examination of the Panel's decision reveals a decision made too hastily . A closerexamination ofthe record and applicable law, including canons of statutory construction,show that the Panel and the IJ ignored the burden of proof and the law; and in doing ,reached an incorrect decision on an issue of highest importance, the deportation of alawful permanent resident of the United States .

CONCLUSION

A decision regarding deportability is extremely serious. Indeed, the Supreme Court hasrecognized the importance that deportation implicated "issues basic to human liberty andhappiness." along Yang Sung v. McGrath, 339 US 33 (1950). When a lawful permanentresident is. involved, deportation is the equivalent ofbanishment or exile DelGadillo v.Carmichael, 332 US 398 (1947) . With this degree of constitutionally protected interestsat stake, and the requirement that this Court Board should co nstrue statutes establishingdeportability narrowly rather than broadly; the cumulative impact of errors in the U andBIA decision are obvious. This is particularly true in light of the burden of proof the INSmust bear in establishing deportability.

For all of the reasons set forth above, Petitioner respectfully urges th is Court to vacate theIJ and BIA decision, order immediate release of the Petitioner, a lawful permanentresident. Declare that the retroactive application of AEDPA 440 in Petitioner's caseviolates the due process clause of the Fifth Amendment . Vacate the order ofdeportability and great relief under former INA 212(c) . Declare that INA 236(c) violatesthe Due Process Clause of the Fifth Amendment of the United States Constitution andthat persons such as Petitioner are entitled to a prompt custody hearing .

Grant petitioner asylum under the Torture Convention.Grant petitioner application for naturalization.

Respectfully Submitted,

Brightman Nwatu, A27174038208 Vines DriveCedar Hill, TX 75104

zcyq 97 6 $/,6

February 14, 2005

FYI-Petitioner was released fiom detention on January 28, 2005 and is awaiting adecision from the Courts . It is the hope that the Courts will concur and rule in favor ofthe Petitioner.

USCAS 117


CERTIFICATE OF SERVICE

I certify that a true and correct copy sf the foregoing Wvi~w, ~ti~was ~ this I ~~`haday of F~ , 200Son the IN $ `~c~ y firstclass U.S. mail, postage prepaid .

Date Signature

USCA5 118


Dear Judges,

I had poor representation My attorney did not contact me until 6 months after theMay 23rd decision by the BIA. This prevented a timely response to the Courts thuseclipsing the 30-day limit . -I believe that I should not be exiled due to faults that I did notcreate .

My appeals raises constitutional and fkkness issues .I swear under penalty of perjury that this statement is true .

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