Abandonment of Dispositive Issues and Counsel’s Duty of Candor in Immigration Appeals: Commentary on Medina‑Sarango v. Bondi (2d Cir. 2025)

1. Introduction

The Second Circuit’s summary order in Medina‑Sarango v. Bondi, No. 24‑1441 (2d Cir. Dec. 5, 2025), though expressly non‑precedential, offers an important illustration of two recurring themes in immigration litigation:

• The decisive consequences of abandoning dispositive issues on appeal, particularly in asylum and CAT cases; and
• The court’s growing willingness to call out, and potentially discipline, immigration counsel for misstatements of the record and governing law.

The case involves an Ecuadorian mother and her minor daughter seeking asylum, withholding of removal, and protection under the Convention Against Torture (CAT). Their claims rested on alleged past abuse by a former co‑worker and, secondarily, on their status as indigenous persons from Ecuador. An Immigration Judge (IJ) rejected their claims on credibility and “pattern or practice” grounds; the Board of Immigration Appeals (BIA) affirmed, finding that key issues had been waived. At the Second Circuit, petitioners again failed to challenge these dispositive findings and presented a brief that, in the panel’s view, mischaracterized both the record and the CAT standard.

The court denied the petition for review, found the abandoned issues dispositive of all forms of relief, and, notably, referred counsel to the court’s Grievance Panel. While the order does not create new binding precedent, it sharply reinforces existing doctrine on appellate abandonment and underscores the professional obligations of attorneys practicing before federal courts in immigration matters.

2. Factual and Procedural Background

2.1 Parties and Claims

Petitioners, Nusta Rocio Medina‑Sarango and her minor daughter, are natives and citizens of Ecuador. The record, as summarized by the panel, indicates that:

• Their protection claims were grounded primarily in Medina‑Sarango’s allegations of past abuse by a former co‑worker in Ecuador.
• They also relied on their indigenous identity but did not demonstrate individualized targeting based on that identity or a broader pattern or practice of persecution against indigenous people in Ecuador.

They sought three forms of relief:

1. Asylum, based on a fear of persecution on account of a protected ground;
2. Withholding of removal, which imposes a higher standard of proof than asylum; and
3. Protection under the Convention Against Torture (CAT), which requires a showing of likely torture with government involvement or acquiescence, but no nexus to a protected ground.

2.2 Proceedings Before the Immigration Judge

The IJ (Judge Reid) denied all relief by decision dated September 28, 2022. Two points of the IJ’s decision—critical to the Second Circuit’s ultimate ruling—stood out:

1. Adverse credibility finding. The IJ found that Medina‑Sarango’s allegations of past abuse by a co‑worker were not credible. Given that the daughter’s claims were derivative of the mother’s and rested on the same factual narrative, this credibility determination effectively undermined the factual predicate for all claims.
2. No proof of individual or group targeting as indigenous persons. Although the IJ accepted that petitioners are indigenous, he held that:
   • They did not credibly establish that they, personally, would be singled out for harm on that basis; and
   • The evidence failed to establish a pattern or practice of persecution against indigenous people in Ecuador that would independently support a well‑founded fear claim.

The IJ also:

• Found that petitioners did not meet the standard for asylum; and under well‑settled law, failure to meet the asylum standard necessarily meant they did not meet the higher standard for withholding of removal.
• Denied CAT relief, both because the underlying factual narrative was not credible and because the legal standard for government involvement/acquiescence was not satisfied.
• Contrary to petitioners’ later appellate assertions, the IJ did not find that they had abandoned any of their claims for failure to timely submit evidence. The IJ accepted all proffered evidence, including untimely submissions.

2.3 BIA Appeal

On April 29, 2024, the BIA:

• Affirmed the IJ’s decision, adopting the IJ’s reasoning with respect to:
  • The adverse credibility determination;
  • The failure to establish individualized targeting or a pattern or practice of persecution based on indigenous identity; and
  • The denial of asylum, withholding of removal, and CAT protection.
• Found waiver: The BIA specifically held that petitioners’ brief to the Board had waived review of:
  • The IJ’s adverse credibility finding; and
  • The IJ’s conclusion that this adverse credibility determination was dispositive of all requested relief.

Thus, by the time the case reached the Second Circuit, there were at least two layers of unchallenged or waived findings: the IJ’s adverse credibility judgment and the BIA’s determination that it had been waived on administrative appeal.

2.4 Petition for Review to the Second Circuit

Petitioners, represented by attorney Michael Borja, then sought review in the Second Circuit. Their brief, however:

• Did not address or contest:
  • The adverse credibility determination;
  • The IJ’s “no pattern or practice” finding; or
  • The BIA’s ruling that challenges to the adverse credibility finding had been waived.
• Mischaracterized the IJ’s decision, asserting—incorrectly—that the IJ denied withholding of removal because the petitioners allegedly abandoned their asylum application by not timely providing evidence.
• Advanced an incorrect view of the CAT standard, arguing that petitioners did not need to show that the Ecuadorian government condoned or acquiesced in the harm by a private actor, notwithstanding the contrary language of 8 C.F.R. § 1208.18(a)(1).

The panel explicitly notes that these same misstatements of law and record had appeared in other briefs filed by the same counsel, a fact that becomes significant for the disciplinary referral.

3. Summary of the Court’s Order

The Second Circuit (Judges Newman, Sullivan, and Nathan) denied the petition for review. The key holdings can be summarized as follows:

1. Scope of review. The court reviewed the IJ’s decision “as supplemented by the BIA.” This means it considered the IJ’s reasoning together with the BIA’s additional findings, a standard practice in cases where the BIA adopts and supplements an IJ decision.
2. Standards re‑stated but not substantively applied. The panel recited the usual legal standards for:
   • Asylum and “well‑founded fear” (including past persecution and pattern or practice routes);
   • Withholding of removal and its higher “clear probability” burden; and
   • CAT relief and its distinct torture and state‑action requirements.
   However, the court did not engage deeply with these standards in relation to the facts, because the petition was resolved on procedural grounds—abandonment of issues.
3. Abandonment of dispositive issues. The court found that petitioners had abandoned, on appeal, all dispositive grounds for denial:
   • They did not challenge the IJ’s adverse credibility finding.
   • They did not challenge the IJ’s rejection of their pattern or practice claim regarding indigenous people in Ecuador.
   • They did not challenge the BIA’s determination that the adverse credibility issue was waived.
   Citing Debique v. Garland, the court held that claims not adequately raised in an appellant’s brief are deemed abandoned. Because the unchallenged findings were dispositive of asylum, withholding, and CAT, the abandonment was determinative.
4. Knock‑on effect for withholding and CAT. Relying on Lecaj v. Holder, the court reiterated that a failure to establish a well‑founded fear of persecution for asylum purposes necessarily precludes meeting the more demanding standards for withholding of removal and CAT. Accordingly, once asylum fell, the others followed.
5. Criticism of counsel and referral to Grievance Panel.
   • The court identified “defects in the briefing” by petitioners’ counsel:
     • Misstatement that the IJ denied withholding because petitioners allegedly abandoned asylum by late evidence submission—contradicted by the record.
     • Misdescription of the CAT standard, asserting that government condonation or acquiescence was not required, contrary to the regulation.
     • Failure to acknowledge the adverse credibility finding when arguing CAT relief.
   • The order explicitly notes that such misstatements have been made in “other briefs filed by Mr. Borja,” and directs that a copy of the order be forwarded to the court’s Grievance Panel.

The petition was therefore denied, all pending motions and applications were denied, and any stays of removal were vacated.

4. Detailed Analysis

4.1 Standards of Review and Substantive Legal Framework

4.1.1 Standard of Review

The court begins with standard appellate review principles in immigration cases:

• Factual findings (including adverse credibility findings) are reviewed under the substantial evidence standard. Under 8 U.S.C. § 1252(b)(4)(B), factual findings “are conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.” This is a highly deferential standard toward the agency.
• Questions of law and the application of law to fact are reviewed de novo, see Hong Fei Gao v. Sessions, 891 F.3d 67, 76 (2d Cir. 2018).
• The panel reviews the IJ’s decision “as supplemented by the BIA,” per Yan Chen v. Gonzales, 417 F.3d 268, 271 (2d Cir. 2005). This means that if the BIA adopts the IJ’s reasoning but adds its own analysis, both are considered part of the agency’s decision under review.

4.1.2 Substantive Standards for Asylum and Withholding

The order rehearses familiar principles:

• Asylum requires a showing that the applicant is unable or unwilling to return to her home country because of “persecution or a well‑founded fear of future persecution” on account of a protected ground: race, religion, nationality, political opinion, or membership in a particular social group. See 8 U.S.C. § 1101(a)(42)(A); Pinel‑Gomez v. Garland, 52 F.4th 523, 528 (2d Cir. 2022).
• A well‑founded fear has:
  • a subjective component (the applicant actually fears harm), and
  • an objective component (the fear is reasonable in light of the evidence).
  See Liang v. Garland, 10 F.4th 106, 112 (2d Cir. 2021).
• Past persecution triggers a presumption of a well‑founded fear of future persecution, shifting the burden to the government to rebut that presumption. Liang, 10 F.4th at 112.
• Persecution must be inflicted either by the government or by private actors whom the government is unable or unwilling to control. See Pan v. Holder, 777 F.3d 540, 543 (2d Cir. 2015).

An applicant can meet the future‑persecution requirement either by:

• Showing she will be singled out individually for persecution, or
• Proving a pattern or practice of persecution against a group of persons similarly situated to her. See 8 C.F.R. § 1208.13(b)(2)(iii); § 1208.16(b)(2); Y.C. v. Holder, 741 F.3d 324, 332 (2d Cir. 2013).

For withholding of removal, the applicant must show a “clear probability of persecution,” meaning it is more likely than not that she would be persecuted if removed. See Pinel‑Gomez, 52 F.4th at 528. Because this standard is more stringent than the well‑founded fear standard for asylum, an applicant who fails to qualify for asylum on the merits necessarily cannot qualify for statutory withholding. Wei Sun v. Sessions, 883 F.3d 23, 28 (2d Cir. 2018).

4.1.3 CAT Protection

Protection under the Convention Against Torture is distinct from asylum and withholding in two main respects:

• There is no requirement of a nexus to a protected ground (race, religion, etc.). See Hong Fei Gao, 891 F.3d at 76.
• The applicant must show it is more likely than not that she would be tortured if removed, and that the torture would be:

  “by, or at the instigation of, or with the consent or acquiescence of, a public official acting in an official capacity.”

  8 C.F.R. § 1208.18(a)(1).

Thus, for CAT relief, the central issues are (1) whether the harm rises to the level of “torture” and (2) whether there is sufficient governmental involvement (or deliberate inaction) to meet the state‑action requirement.

4.2 Precedents Cited and Their Role

The panel’s order is heavily grounded in prior Second Circuit immigration and appellate practice decisions:

• Yan Chen v. Gonzales, 417 F.3d 268 (2d Cir. 2005).
  This case establishes the standard that the Court of Appeals will review the IJ’s decision as supplemented by the BIA’s reasoning when the BIA adopts but supplements the IJ’s analysis. In Medina‑Sarango, the court explicitly follows this structure, clarifying that both tiers of agency reasoning are in play.
• Hong Fei Gao v. Sessions, 891 F.3d 67 (2d Cir. 2018).
  This decision is cited for the bifurcated standard of review (substantial evidence for facts, de novo for law), and for the principle that CAT relief does not require a nexus to a protected ground, a point the panel reiterates.
• Pinel‑Gomez v. Garland, 52 F.4th 523 (2d Cir. 2022).
  Used to restate the statutory definition of a refugee and the “clear probability” standard for withholding.
• Liang v. Garland, 10 F.4th 106 (2d Cir. 2021).
  Cited for the subjective–objective articulation of the well‑founded fear standard and the presumption triggered by past persecution.
• Pan v. Holder, 777 F.3d 540 (2d Cir. 2015).
  Supports the requirement that persecution either be by government actors or by private actors whom the government is unable or unwilling to control, reinforcing that private disputes without such a failure of state protection generally do not suffice.
• Wei Sun v. Sessions, 883 F.3d 23 (2d Cir. 2018).
  Confirms the hierarchy of burdens: failure to meet the asylum standard necessarily implies failure to meet the more demanding withholding standard. The panel in Medina‑Sarango uses this as part of the chain that disposes of withholding once asylum has fallen.
• Y.C. v. Holder, 741 F.3d 324 (2d Cir. 2013).
  Invoked for the “pattern or practice” methodology and the related deference to agency factual findings about country conditions.
• Debique v. Garland, 58 F.4th 676 (2d Cir. 2023).
  This is the key authority on abandonment of arguments. It holds that:

  “We consider abandoned any claims not adequately presented in the appellant’s brief, and an appellant’s failure to make legal or factual arguments constitutes abandonment.”

  In Medina‑Sarango, the panel uses Debique to deem petitioners’ challenges to the adverse credibility finding, the pattern/practice finding, and the BIA’s waiver determination abandoned.
• Lecaj v. Holder, 616 F.3d 111 (2d Cir. 2010).
  This case provides the doctrinal link for the “all or nothing” effect once asylum fails:

  an applicant who fails to establish a well‑founded fear of harm rising to the level of persecution for asylum “necessarily” fails to meet the higher burdens for withholding of removal and CAT relief.

  The Medina‑Sarango court cites this to explain why the abandonment of dispositive asylum issues is equally fatal to withholding and CAT.

None of these precedents are novel; rather, the order applies them in a straightforward manner. What is distinctive about this case is not the legal standard but the procedural route to affirmance and the court’s explicit disciplinary concerns.

4.3 The Court’s Legal Reasoning in Medina‑Sarango

4.3.1 Adverse Credibility and Pattern/Practice Findings as Dispositive

The IJ’s core determinations were:

• Petitioners’ story of abuse by a former co‑worker was not credible.
• They did not show either:
  • a likelihood of individualized harm on account of their indigenous identity, or
  • a pattern or practice of persecution of indigenous persons in Ecuador sufficient to substitute for individualized proof.

These determinations are critical because:

• Without credible testimony, the factual foundation of all claims is gravely weakened. Under 8 U.S.C. § 1158(b)(1)(B)(ii), the applicant’s testimony can be sufficient but only if it is “credible, persuasive, and refers to specific facts.” Here, it was found not credible.
• The alternative “pattern or practice” route, which can sometimes mitigate weak individualized evidence, was explicitly rejected by the IJ. Petitioners therefore lacked both prongs: no credible individualized persecution and no group‑level persecution.

The BIA accepted these findings and further found that the adverse credibility issue was waived because petitioners did not properly raise it in their appeal to the Board.

4.3.2 Abandonment Before the Second Circuit

The petitioners’ brief to the Second Circuit did not:

• Challenge or even mention the IJ’s adverse credibility finding;
• Address the IJ’s conclusion that there was no pattern or practice of persecution against indigenous persons in Ecuador; or
• Challenge the BIA’s finding that petitioners had waived any challenge to the adverse credibility determination.

Under Debique v. Garland, these omissions are fatal. Courts of appeals treat issues that are not adequately briefed as abandoned. It is not enough to gesture generally toward a claim; the appellant must make substantive legal or factual arguments addressing the disputed rulings.

The panel thus concludes that:

“These issues have thus been abandoned. … And that abandonment is dispositive of all relief.”

In other words:

• Because the adverse credibility finding and the “no pattern/practice” finding were both dispositive at the agency level, failing to challenge them on petition for review leaves nothing for the court to overturn.
• Even if petitioners had correctly stated the legal standards for asylum or CAT, the unchallenged factual findings would still require denial.

4.3.3 Collateral Consequences for Withholding and CAT

Having found that asylum fails due to abandonment of vital issues, the court relies on Lecaj and Wei Sun to dispose of withholding and CAT:

• Withholding of removal demands a higher standard (“more likely than not”) than asylum (“well‑founded fear”). If petitioners cannot meet the lighter standard, they cannot meet the heavier one.
• CAT relief, though conceptually distinct, also requires a “more likely than not” finding of torture and is often decided under a comparable or higher factual threshold. Moreover, where the alleged persecution is disbelieved, courts generally reject CAT claims unless there is strong independent corroborative evidence—which petitioners here did not show, and which they did not argue around the adverse credibility finding.

The panel succinctly invokes Lecaj to state that a failure to show a well‑founded fear “necessarily” implies a failure to satisfy the higher burdens for withholding and CAT. Strictly speaking, CAT analysis is sometimes treated as analytically distinct; but in practice, where the underlying narrative is rejected and there is no serious independent showing of likely torture by or with government acquiescence, the result is the same.

4.4 Treatment of Counsel’s Briefing and Referral to the Grievance Panel

4.4.1 Misstatement of the Record

The panel devotes a separate paragraph to identifying defects in the petitioners’ brief authored by attorney Michael Borja. First, it calls out a misstatement of the record:

• The brief claimed that the IJ denied withholding of removal because he found that petitioners had “abandoned their asylum application by not timely providing all evidence.”
• The court corrects this, noting that:
  • The IJ “accepted all proffered evidence (including evidence that was untimely), and did not find that any of Petitioners’ claims were abandoned.”
  • The court cites to the Certified Administrative Record (CAR at 82–84) to confirm this.

Mischaracterizing what the IJ did—especially when the record clearly contradicts counsel’s assertions—implicates the duty of candor to the tribunal.

4.4.2 Misstatement of CAT Law

Second, the panel addresses misstatements concerning CAT:

• The brief argued that petitioners met their burden for CAT by showing that the Ecuadorian government “exacerbated” their problems, without acknowledging that the IJ had found their account of past events not credible.
• More importantly, the brief contended that petitioners were not required to show that the Ecuadorian government “condoned or acquiesced” to their harm by a private actor.
• The court flatly rejects this assertion as contrary to the CAT regulation’s explicit language requiring that torture occur “by, or at the instigation of, or with the consent or acquiescence of, a public official acting in an official capacity.” 8 C.F.R. § 1208.18(a)(1).

Presenting such a statement—ignoring directly applicable regulatory text already quoted in countless CAT decisions—raises serious concerns about competence and candor.

4.4.3 Pattern of Misconduct and Referral

Perhaps most striking is the panel’s observation:

“We note that the same misstatements of the record and the law have been advanced in other briefs filed by Mr. Borja.”

This signal—that the court has seen this behavior repeatedly—justifies escalation. The order concludes with:

“A copy of this order will be forwarded to the Grievance Panel.”

In the Second Circuit, the Grievance Panel deals with potential attorney misconduct, encompassing:

• Misrepresentations to the court;
• Repeatedly deficient or frivolous filings; and
• Violation of professional responsibility obligations.

While the order does not specify what sanctions or remedial measures might follow, the referral itself underscores that:

• The court is tracking patterns of misrepresentation or incompetence among immigration practitioners.
• Repeated, documented misstatements of law and record can trigger disciplinary proceedings, including possible censure, suspension from practice before the court, or other sanctions.

5. Clarifying Key Legal and Procedural Concepts

5.1 Adverse Credibility Determination

An adverse credibility determination occurs when an immigration judge finds that the applicant’s testimony cannot be relied upon, often due to:

• Internal inconsistencies;
• Inconsistencies with other evidence;
• Plausibility concerns; or
• Non‑responsive or evasive answers.

Because asylum and CAT cases frequently turn on the applicant’s testimony, an adverse credibility finding usually has profound effects:

• It means the applicant’s story of persecution or torture is not accepted as fact.
• To succeed, the applicant would then need strong independent corroborating evidence sufficient to carry the burden without relying on the discredited testimony—rare in practice.

On judicial review, such findings are highly deferentially reviewed under the “any reasonable adjudicator” standard. In Medina‑Sarango, the petitioners did not even attempt to challenge the adverse credibility finding at the Second Circuit stage, rendering it unassailable.

5.2 Pattern or Practice of Persecution

A pattern or practice claim allows an applicant to obtain asylum or withholding not because she is personally singled out, but because:

• She belongs to a particular group (e.g., a specific ethnic, religious, or political group), and
• There is systematic, pervasive persecution of that group in her home country.

To succeed, the applicant must generally provide:

• Country‑conditions evidence (e.g., U.S. State Department reports, NGO reports, news articles);
• Expert testimony where available; and
• A showing that the harm rises to the level of persecution and is widespread or systemic.

In Medina‑Sarango, the IJ found that:

• While petitioners are indigenous, the evidence did not show that indigenous persons in Ecuador face persecution rather than mere discrimination or hardship; and
• Therefore, there was no “pattern or practice” of persecution sufficient to satisfy the regulation.

Petitioners’ failure to challenge this finding on appeal rendered the pattern/practice avenue closed.

5.3 Abandonment of Issues on Appeal

In appellate practice, abandonment (sometimes termed “waiver” or “forfeiture” in specific contexts) refers to the principle that:

• Issues not adequately raised and argued in an appellant’s opening brief are treated as abandoned and will not be considered.
• “Adequately raised” means providing at least a basic legal and factual argument, with citation to authority and the record—mere conclusory assertions or passing references are usually insufficient.

Debique v. Garland crystallizes this for immigration cases in the Second Circuit. In Medina‑Sarango, abandonment occurred at both:

• The BIA level (failure to challenge the IJ’s adverse credibility finding, resulting in “waiver” before the Board); and
• The Circuit level (failure to challenge the adverse credibility finding, the pattern/practice finding, or the BIA’s waiver ruling).

Once issues have been abandoned in this way, the court generally will not rescue the appellant by raising them sua sponte.

5.4 Grievance Panel Referral

Most federal courts of appeals, including the Second Circuit, maintain a Grievance Panel or similar body to oversee attorney conduct. Referral to such a panel typically occurs when:

• An attorney repeatedly files deficient briefs;
• There are concerns about unprofessional conduct or incompetence; or
• The attorney is suspected of violating duties of candor, honesty, or other ethical norms.

Consequences can range from:

• Private admonitions;
• Requirements to complete continuing legal education or mentoring;
• Public reprimands; or
• Suspension or disbarment from practice before the court.

In immigration practice, where vulnerable noncitizens often depend entirely on their attorneys to articulate complex claims, disciplinary oversight is especially significant.

6. Likely Impact and Practical Implications

6.1 No Formal Precedential Effect, but Strong Persuasive Signaling

The order is explicitly labeled a “Summary Order” with no precedential effect under Second Circuit Local Rule 32.1.1. It may be cited in accordance with Fed. R. App. P. 32.1, but it does not create binding circuit law. Nonetheless, it is:

• A clear application of existing precedent (Debique, Lecaj, etc.) to a typical asylum/CAT scenario; and
• A strong signal of the court’s intolerance for:
  • Inadequate briefing that omits dispositive issues; and
  • Systematic misstatements of law and record in immigration appeals.

6.2 Guidance for Immigration Practitioners

The order sends several practical messages to immigration counsel:

1. Always directly address adverse credibility findings.
   If an IJ has found the client not credible, the BIA appeal and any petition for review must grapple with that finding: explain why it is erroneous under the substantial‑evidence standard, point to record inconsistencies in the IJ’s analysis, and marshal corroborating evidence. Ignoring it is effectively conceding the case.
2. Do not ignore “pattern or practice” and other alternative grounds.
   When an IJ denies relief on multiple independent grounds (e.g., credibility and lack of pattern/practice), each ground generally must be challenged on appeal; failure to do so leaves that ground as an independent basis for denial.
3. Be scrupulously accurate about the record.
   Claims that the IJ found abandonment or refused evidence must be firmly grounded in the transcript or written decision. The court will not tolerate misrepresentations that are contradicted by straightforward citations to the Certified Administrative Record.
4. Know and apply the correct CAT standard.
   CAT requires government involvement—whether through direct perpetration, instigation, consent, or acquiescence. Arguing the opposite invites correction and undermines counsel’s credibility.
5. Understand that repeated errors can lead to discipline.
   When the court notes that similar misstatements have been made “in other briefs filed by” the same attorney and refers the matter to a Grievance Panel, it signals that patterns of poor practice in immigration appeals are under active scrutiny.

6.3 Consequences for Noncitizens

From the perspective of noncitizen litigants:

• The case illustrates how procedural missteps by counsel—especially failure to brief critical issues—can foreclose substantive review of their claims.
• Even potentially meritorious arguments (for example, if the credibility finding were arguably flawed) cannot be resurrected if they are not properly raised at each administrative and judicial stage.
• It highlights the importance of:
  • Retaining competent, specialized immigration appellate counsel; and
  • Understanding that appeal success often hinges as much on procedural rigor as on underlying facts.

7. Conclusion

Medina‑Sarango v. Bondi does not break new legal ground in asylum, withholding, or CAT jurisprudence. Instead, it reinforces established doctrine in two crucial respects:

• Abandonment of dispositive issues. Under Debique and related cases, petitioners who fail to challenge key adverse findings—here, credibility and lack of pattern/practice—effectively concede defeat. The court will not reach the merits of underlying claims when no argument is made addressing the actual reasons the agency denied relief.
• Counsel’s duty of candor and competence. The court’s explicit identification of misstatements in the brief, combined with the referral of counsel to the Grievance Panel for similar recurring errors, sends a clear message: immigration counsel must accurately represent both the record and the governing law, and must present fully developed arguments on all dispositive points.

In a system where the stakes for noncitizens are extraordinarily high—potential detention, removal, and return to possible harm—the quality of advocacy can decisively shape outcomes. Medina‑Sarango stands as a cautionary illustration: even where substantive law and standards are well settled, failures in briefing and professional responsibility can, by themselves, terminate a case and trigger disciplinary scrutiny.