Ralph Bronson Fils-Aime v. Todd Blanche — 1st Cir. (Nov 3, 2026)

No. 25-1733 Argued November 3, 2026 Published November 4, 2026

The First Circuit hears a Haitian man's challenge to being sent to Mexico. An immigration judge had already granted him withholding of removal to Haiti, protecting him from deportation to that country. But in July 2025, the Department of Homeland Security told him it intended to remove him to Mexico instead. He says he was kidnapped and threatened with death in Mexico while traveling to the United States. He asked to reopen his immigration case and sought review in the First Circuit. Withholding is country-specific: protection against return to Haiti does not automatically prevent removal somewhere else. A motion to reopen asks the immigration agency to reconsider a completed case in light of new facts. You will hear ultra vires, meaning action beyond an official's lawful authority. Statutory withholding requires a connection between threatened persecution and a protected ground, such as race or nationality. Protection under the Convention Against Torture has a different focus: whether torture is more likely than not.

Ralph Bronson Fils-Aime v. Todd Blanche (No. 25-1733) — U.S. Court of Appeals for the First Circuit, argued November 3, 2026.

Sources

Argument audio — official First Circuit recording. The original cuts off during the judge's final administrative closing remark after all advocacy has ended; the gap is preserved and no speech reconstructed:https://www.ca1.uscourts.gov/sites/ca1/files/oralargs/25-1733_20261103.mp3

Argument date — official First Circuit recording listing:https://www.ca1.uscourts.gov/doar/results/2026-11

Consolidated case/date — official First Circuit November calendar:https://www.ca1.uscourts.gov/sites/ca1/files/calendar.pdf?TB_iframe=true

Case background — filed D.N.H. habeas petition, August 3, 2025; public mirrored copy, allegations not findings:https://habeasdockets.org/media/documents/71006849/001_11703306062-48d4a290fdfe.pdf

Country-specific statutory withholding — 8 U.S.C. § 1231(b)(3):https://www.law.cornell.edu/uscode/text/8/1231

Reopening proceedings — 8 U.S.C. § 1229a(c)(7):https://www.law.cornell.edu/uscode/text/8/1229a

Withholding, torture protection and third-country removal — 8 C.F.R. § 1208.16:https://www.law.cornell.edu/cfr/text/8/1208.16

Legal vocabulary — Cornell Wex definition of ultra vires:https://www.law.cornell.edu/wex/ultra_vires

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