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J.E.F.M. v. Holder

United States District Court for the Western District of Washington
107 F. Supp. 3d 1119 (2015)


Facts

The United States government (defendant) subjected nine minor aliens (plaintiffs) to removal proceedings. The aliens had a right to representation under the Immigration and Nationality Act (INA) but could not afford counsel. The government rejected the aliens’ request to pay for their counsel. The aliens brought suit in the United States District Court for the Western District of Washington, claiming that their financial inability to retain counsel and the government’s refusal to provide counsel violated their due process rights. The government filed a motion to dismiss for failure to state a claim. The government claimed that Mathews v. Eldridge, 424 U.S. 319 (1976), did not apply to the aliens’ claims and, if it did, the aliens did not meet the Mathews balancing test.

Rule of Law

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Issue

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Holding and Reasoning (Zilly, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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