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24-1995•Walter Jose Galeas Sanchez v. PAMELA JO BONDI, Attorney General
24-1995Court of Appeals for the Fourth CircuitOct 1, 2025
UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 24-1995
WALTER JOSE GALEAS SANCHEZ,
Petitioner,
v.
PAMELA JO BONDI, Attorney General,
Respondent.
On Petition for Review of an Order of the Board of Immigration Appeals.
Submitted: September 17, 2025 Decided: October 1, 2025
Before THACKER, QUATTLEBAUM, and HEYTENS, Circuit Judges.
Petition denied by unpublished per curiam opinion.
ON BRIEF: Japheth Matemu, MUSA-OBREGON LAW, P.C., Maspeth, New York, for
Petitioner. Yaakov M. Roth, Acting Assistant Attorney General, Julie M. Iverson, Senior
Litigation Counsel, Arthur L. Rabin, 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Unpublished opinions are not binding precedent in this circuit.
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2
PER CURIAM:
Walter Jose Galeas Sanchez, a native and citizen of El Salvador, petitions for review
of an order of the Board of Immigration Appeals (Board) dismissing his appeal from the
Immigration Judge’s denial of his applications for asylum, withholding of removal, and
protection under the Convention Against Torture (CAT). The Board held that Galeas
Sanchez waived review of independently dispositive rulings regarding his request for
asylum and withholding of removal and, 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 and withholding of removal 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). Next, we have considered Galeas Sanchez’s challenge to the denial of
CAT protection and conclude that substantial evidence supports the denial of relief.
Cabrera Vasquez v. Barr, 919 F.3d 218, 222 (4th Cir. 2019) (stating standard of review).
Accordingly, we deny the petition for review. In re Galeas Sanchez (B.I.A. Sep. 10, 2024).
We deny the motion for summary disposition as moot and 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 Galeas Sanchez’s arguments challenging the
denial of asylum and withholding of removal based on the Red Notice. See INS v.
Bagamasbad, 429 U.S. 24, 25 (1976) (recognizing that courts of appeal are generally not
required to make findings on “issues the decision of which is unnecessary to the results
they reach”).
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