Josefa Catalan Adame v. PAMELA JO BONDI, Attorney General

UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 24-2166
JOSEFA CATALAN ADAME,
Petitioner,
v.
PAMELA JO BONDI, Attorney General,
Respondent.
On Petition for Review of an Order of the Board of Immigration Appeals.
Submitted: October 16, 2025 Decided: December 23, 2025
Before NIEMEYER and RUSHING, Circuit Judges, and TRAXLER, Senior Circuit Judge.
Petition denied by unpublished per curiam opinion.
ON BRIEF: Mark J. Devine, Charleston, South Carolina, for Petitioner. Drew C. Ensign,
Deputy Assistant Attorney General, Anthony C. Payne, Assistant Director, Neelam
Ihsanullah, Office of Immigration Litigation, Civil Division, UNITED STATES
DEPARTMENT OF JUSTICE, Washington, D.C., for Respondent.
Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:
Josefa Catalan Adame, a native and citizen of Mexico, petitions for review of an
order of the Board of Immigration Appeals (Board) dismissing her appeal from the
Immigration Judge’s denial of her applications for asylum, withholding of removal, and
protection under the Convention Against Torture (CAT). The Board held that Catalan
Adame waived review of independently dispositive rulings regarding her request for
asylum and waived review of her entire withholding of removal and CAT claims. Upon
review, we agree. As the Attorney General has properly invoked the exhaustion
requirement specified in 8 U.S.C. § 1252(d)(1), we decline to review the asylum,
withholding of removal, and CAT claims.* See Santos-Zacaria v. Garland, 598 U.S. 411,
413, 419 (2023); Trejo Tepas v. Garland, 73 F.4th 208, 213-14 (4th Cir. 2023). We have
also reviewed the Board’s affirmance of the IJ’s denial of Catalan Adame’s motion for
administrative closure and find no abuse of discretion. See Matter of Avetisyan, 25 I. & N.
Dec. 688, 696 (B.I.A. 2012). Accordingly, we deny the petition for review. In re Catalan
Adame (B.I.A. Nov. 6, 2024). 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
* For this reason, we need not address Catalan Adame’s remaining arguments
challenging the denial of this relief. See INS v. Bagamasbad, 429 U.S. 24, 25 (1976)
(recognizing that generally “courts and agencies are not required to make findings on issues
the decision of which is unnecessary to the results they reach”).

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