Sandeep Singh v. PAMELA J. BONDI, Attorney General of the United States

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted January 6, 2026*
Decided January 9, 2026
Before
ILANA DIAMOND ROVNER, Circuit Judge
MICHAEL Y. SCUDDER, Circuit Judge
DORIS L. PRYOR, Circuit Judge
No. 25-1409
SANDEEP SINGH,
Petitioner,
v.
PAMELA J. BONDI,
Attorney General of the United States,
Respondent.
Petition for Review of a Final
Administrative Removal Order.
No. 220 471 649
O R D E R
Sandeep Singh petitions for review of a final administrative removal order
issued against him by the Department of Homeland Security. He contends that the
Department committed procedural errors when issuing the order and requests that the
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 25-1409 Page 2
order be vacated. But because Singh has not demonstrated any prejudice arising from
the alleged errors, we deny the petition.
Singh, a citizen of India and permanent resident of Canada, entered the United
States from Canada in November 2021 on a visitor visa. In April 2024, he pleaded guilty
to conspiracy to possess with intent to distribute methamphetamine. See 21 U.S.C.
§ 841(a)(1); United States v. Singh, No. 0645 2:22CR20124 (1) (E.D. Mich. May 2, 2024).
The district court imposed 60 months’ imprisonment.
In December 2024, the Department served Singh with a Notice of Intent to Issue a
Final Administrative Removal Order under 8 U.S.C. § 1228(b). The order charged Singh
as removable under 8 U.S.C. § 1227(a)(2)(A)(iii) based on his conviction for an
aggravated felony.
Singh responded four days later, raising three points. First, he argued that his
removal proceedings should proceed under § 1228(a) and § 1229a—before an
immigration judge—rather than under § 1228(b), where the Department makes the final
determination. Second, he requested to be removed to Canada, where he is a lawful
permanent resident. Third, he asked that the Department issue a detainer notice rather
than a final removal order so that he could apply toward early release or prerelease
custody the time credits he earned under the First Step Act. See 18 U.S.C.
§ 3632(d)(4)(A), (E).
About two months later, the Department issued a final removal order. It directed
Singh’s removal to India. About five months after that, after Singh had filed his opening
brief on appeal, the Department amended the final order by crossing out “India” and
inserting “Canada” as the country of removal.
Singh petitions for review of the removal order, arguing that the Department
violated his procedural rights. Singh contends that the Department violated the
Immigration and Nationality Act and its implementing regulations by failing: (1) to
provide a list of free legal services, 8 C.F.R. § 238.1(b)(2)(iv); (2) to translate his Notice
into his native language, Punjabi, id. § 238.1(b)(2)(v); and (3) to grant his requests for
additional time to respond to the Notice and for a copy of the Department’s evidence,
id. § 238.1(c)(1).† To the extent that these arguments involve “constitutional claims or
† Singh initially challenged the order’s designation of India as his country of
removal. But he withdrew that argument after the government provided a copy of the
amended order in its response brief designating Canada as his country of removal.

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No. 25-1409 Page 3
questions of law,” 8 U.S.C. § 1252(a)(2)(D), we have limited jurisdiction to review them.
See, e.g., Issaq v. Holder, 617 F.3d 962, 967 (7th Cir. 2010).
But even if Singh could demonstrate procedural error, he cannot obtain relief
unless those errors caused prejudice. See Silais v. Sessions, 855 F.3d 736, 745 (7th Cir.
2017) (“Courts … do not set aside agencies’ decisions unless mistakes cause prejudice.”
(internal quotation marks omitted)). In other words, Singh must show that the
Department’s errors affected the outcome of the proceedings. See id.
And Singh cannot show that any procedural errors caused prejudice because he
does not dispute the allegation in the Notice that he was convicted of an aggravated
felony. Because of his conviction, Singh is “conclusively presumed to be subject to
removal and is ineligible for cancellation of removal, voluntary departure, and
registration as a permanent resident alien.” United States v. Santiago-Ochoa, 447 F.3d
1015, 1020 (7th Cir. 2006).
Singh also contends that he is prejudiced because the removal order prevents
him from applying toward early release his time credits under the First Step Act. He
argues that the Attorney General should have exercised discretion to delay issuing the
removal order. But noncitizens in expedited removal proceedings are barred from any
discretionary relief that the Attorney General may grant, so “the absence of prejudice is
deducible almost as a matter of law.” Id. at 1020; see 8 U.S.C. § 1228(b)(5).
Accordingly, we DENY the petition for review.

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