Jorge Mario Martinez-Ortiz v. PAMELA JO BONDI, Attorney General

UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 25-1296
JORGE MARIO MARTINEZ-ORTIZ,
Petitioner,
v.
PAMELA JO BONDI, Attorney General,
Respondent.
On Petition for Review of an Order of the Board of Immigration Appeals.
Submitted: October 2, 2025 Decided: October 10, 2025
Before NIEMEYER, WYNN, and RICHARDSON, Circuit Judges.
Petition denied by unpublished per curiam opinion.
ON BRIEF: Jorge E. Artieda, JORGE E. ARTIEDA LAW OFFICE P.C., Falls Church,
Virginia, for Petitioner. Brett A. Shumate, Assistant Attorney General, Sabatino F. Leo,
Assistant Director, Corey L. Farrell, Senior Litigation Counsel, Office of Immigration
Litigation, 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Unpublished opinions are not binding precedent in this circuit.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:
Jorge Mario Martinez-Ortiz, a native and citizen of Guatemala, 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
Martinez-Ortiz waived review of independently dispositive rulings regarding his request
for asylum and withholding of removal, and waived review of his entire CAT claim. 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). In addition,
Martinez-Ortiz’s procedural due process claim alleging errors in the hearing transcript was
not exhausted before the Board, which could have addressed and remedied the issue. See
Kurfees v. INS, 275 F.3d 332, 337 (4th Cir. 2001). Because the Attorney General has also
invoked § 1252(d)(1) with respect to this claim, we deny review.
Accordingly, we deny the petition for review. In re Martinez-Ortiz (B.I.A. Mar. 3,
2025). We dispense with oral argument because the facts and legal contentions are
* For this reason, we need not address Martinez-Ortiz’s other arguments challenging
the denial of asylum and withholding of removal. 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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adequately presented in the materials before this court and argument would not aid the
decisional process.
PETITION DENIED

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