Flowers v. Bondi: Enforcing Jurisdictional Limits on Review of Discretionary Immigration Relief

I. Introduction

The Seventh Circuit’s nonprecedential order in Jeannette Loretta Flowers v. Pamela J. Bondi illustrates, in stark and sympathetic terms, how tightly federal courts are constrained in reviewing discretionary immigration decisions. Despite highly compelling equities—a nearly forty-year residence, five U.S.-citizen children, a history of domestic abuse, no criminal record, and longstanding employment—the court held that it lacked authority to second-guess the immigration agencies’ discretionary denial of relief.

The case arises from two consolidated petitions for review:

Flowers’s challenge to an Immigration Judge’s (IJ) and the Board of Immigration Appeals’ (BIA’s) denial of her application for cancellation of removal under 8 U.S.C. § 1229b(b)(1); and
Her challenge to the BIA’s subsequent denial of her motion to reopen based on new evidence (a family-based visa petition and her child’s new medical diagnosis).

Ultimately, the Seventh Circuit:

Affirmed the agencies’ decision to deny cancellation of removal without reaching statutory eligibility, and
Upheld the BIA’s refusal to reopen the case.

The opinion does not create new binding precedent—it is explicitly styled as a “NONPRECEDENTIAL DISPOSITION” and may be cited only in accordance with Federal Rule of Appellate Procedure 32.1. Nonetheless, it provides a clear, practical application of several important Supreme Court and Seventh Circuit decisions—especially Patel v. Garland, Wilkinson v. Garland, and INS v. Bagamasbad—on:

The two-step nature of cancellation of removal (eligibility + discretionary judgment),
The ability of an IJ to deny relief purely on discretionary grounds without deciding eligibility, and
The narrowness of federal appellate review over discretionary immigration decisions, even in sympathetic cases.

II. Factual and Procedural Background

A. Personal History and Equities

Jeannette Loretta Flowers was born in Belize City, Belize. She entered the United States unlawfully in 1987 at age eighteen and has remained in the country for nearly forty years. By the time of removal proceedings:

She was the mother of five U.S.-citizen children.
Four of those children, plus one grandchild, lived with her and depended on her for care.
She had continuous employment in an Evanston, Illinois restaurant since at least 2006, with her employer testifying that she was “very caring, hardworking, and trustworthy.”
She had never been convicted of a crime.
She had been the primary caretaker of her elderly father, who resided in a nursing home (and has since passed away).

The undisputed record painted Flowers as a long-term, law-abiding, family-centered member of her community with deep ties and substantial responsibilities.

B. Initiation of Removal Proceedings

In 2011, the Department of Homeland Security conducted a raid that led to the arrest of Glen Gillett, Flowers’s abusive former partner and the father of two of her children. Flowers herself was “swept up in the raid” and charged as a removable noncitizen.

Before the IJ, Flowers:

Conceded removability, and
Sought cancellation of removal for certain nonpermanent residents under 8 U.S.C. § 1229b(b)(1).

C. Evidence Before the Immigration Judge

At the cancellation hearing, a different IJ heard testimony from:

Flowers herself,
Two of her children,
Her sister, and
Her long-term employer.

The testimony emphasized:

Her role as sole or primary caregiver to:
- Her youngest daughter (then nine), who would have no alternative caregiver if Flowers were removed.
- Her teenage son (then seventeen) with ADHD who struggled with school, work, and counseling.
- Her adult daughter (then twenty-eight) and five-year-old granddaughter, who faced homelessness without her support.
- Her elderly father in a nursing home, for whom she had been the primary caretaker.
Her history of lawful, steady employment and strong character references.

D. The False Claims to U.S. Citizenship

Crucial to the case were two incidents in which Flowers made false representations of U.S. citizenship:

2001 incident. Flowers obtained a fake passport and used it to reenter the United States after a two-week trip to Belize.
2005 incident. At the U.S.–Mexico border, she told a border patrol agent that she was a U.S. citizen (though she did not use the fake passport on this occasion).

Flowers testified that on both occasions she traveled with Gillett and that he forced her to leave and reenter the country with him. Neither incident resulted in arrest or criminal conviction. Nonetheless, the false citizenship claims carry grave civil immigration consequences under 8 U.S.C. § 1182(a)(6)(C).

E. The IJ’s Decision: Discretionary Denial Without Reaching Eligibility

Cancellation of removal under § 1229b(b)(1) involves two stages:

Statutory eligibility (meeting certain threshold requirements), and
Discretionary relief (the IJ’s judgment whether, even if eligible, the person merits relief as a matter of discretion).

The IJ acknowledged this framework but chose to decide Flowers’s case solely on the discretionary prong:

The IJ recited the statutory eligibility criteria for cancellation under § 1229b(b)(1), and
Noted that § 1229a(c)(4)(A) separately requires the noncitizen to show that discretionary relief is warranted.

Rather than issuing findings on statutory eligibility (e.g., ten years’ continuous presence, good moral character, hardship to qualifying relatives), the IJ concluded that Flowers did not merit relief as a matter of discretion. The IJ described Flowers’s two false claims to citizenship as “abhorrent and serious,” and held that these outweighed her equities.

The IJ did:

Explicitly acknowledge her long residence, family ties, and community contributions; and
Mention, in the background section, Flowers’s contention that Gillett’s abuse compelled her false citizenship claims.

Nonetheless, the IJ denied the application “as a matter of discretion,” without resolving statutory eligibility.

F. The BIA’s Initial Affirmance

On appeal, Flowers argued to the BIA that the IJ had failed to meaningfully consider the role of Gillett’s abuse in prompting the false citizenship claims. The BIA:

Adopted the IJ’s decision,
Affirmed the discretionary denial of cancellation, and
Noted that both the IJ and the BIA had considered Flowers’s evidence of abuse.

Like the IJ, the BIA found it unnecessary to decide whether Flowers was statutorily eligible for cancellation because, even assuming eligibility, she had not shown that she merited relief in the exercise of discretion.

G. Motion to Reopen

Flowers later moved to reopen proceedings on two grounds:

Her child had filed a Form I-130 visa petition on her behalf—beginning the process for potential adjustment of status to that of a lawful permanent resident.
Her youngest daughter had recently been diagnosed with ADHD, which Flowers argued heightened the hardship if she were removed.

The BIA denied reopening on two independent grounds:

Insufficient documentation of the I-130. Flowers did not adequately document that an I-130 petition had actually been filed or approved.
Statutory ineligibility for adjustment of status. Regardless of the I-130, Flowers’s admitted false claims to U.S. citizenship rendered her inadmissible under 8 U.S.C. § 1182(a)(6)(C)(i), (ii)(I) and therefore ineligible for adjustment of status.

H. The Petitions for Review

Flowers filed timely petitions for review of:

The BIA’s affirmance of the discretionary denial of cancellation, and
The denial of her motion to reopen.

The Seventh Circuit consolidated the petitions and reviewed:

Both the IJ’s and the BIA’s decisions, because the BIA adopted the IJ’s reasoning and supplemented it, pursuant to Bathula v. Holder, 723 F.3d 889 (7th Cir. 2013).

III. Summary of the Seventh Circuit’s Disposition

The Seventh Circuit denied both petitions for review. Its core conclusions were:

No legal error in denying cancellation solely on discretionary grounds.
Under INS v. Bagamasbad and Patel v. Garland, an IJ may deny cancellation of removal as a matter of discretion without first deciding statutory eligibility. The court rejected Flowers’s argument that the failure to analyze the eligibility criteria constituted reversible legal error.
No reviewable error in weighing evidence of abuse.
Both the IJ and the BIA acknowledged Flowers’s claim that her abusive partner forced her to make false citizenship claims. Because the agencies did not ignore this “swath of evidence,” but simply gave it less weight than Flowers believed appropriate, the court held that it lacked jurisdiction to revisit that discretionary evidentiary weighing.
Affirmance of the BIA’s denial of the motion to reopen.
Flowers argued only that the BIA erred in finding insufficient documentation of an I-130 petition; she did not challenge the BIA’s independent holding that she was statutorily ineligible for adjustment of status due to her false citizenship claims. Under Seventh Circuit waiver doctrine, failure to contest that independent, dispositive ground forfeited her challenge. Even putting waiver aside, the court found no abuse of discretion in the BIA’s decision.

The court expressly acknowledged the compelling humanitarian aspects of Flowers’s case, but concluded that it had no authority to second-guess discretionary denials of relief. It closed by noting that Flowers’s remaining options lay in the realm of prosecutorial discretion by immigration authorities, not judicial review.

IV. Legal Framework and Key Precedents

A. Cancellation of Removal: Two-Step Structure

Cancellation of removal for certain nonpermanent residents, 8 U.S.C. § 1229b(b)(1), is a discretionary form of relief that allows an otherwise removable noncitizen to remain in the United States if both:

She meets strict statutory eligibility criteria (such as continuous presence, good moral character, absence of disqualifying crimes, and “exceptional and extremely unusual hardship” to qualifying U.S.-citizen or lawful permanent resident relatives), and
An IJ chooses to grant relief in the exercise of discretion.

Section 1229a(c)(4)(A) confirms that meeting eligibility requirements is only the start: the noncitizen still bears the burden of demonstrating that relief should be granted “as a matter of discretion.”

B. Judicial Review and Jurisdiction-Stripping

Judicial review of discretionary immigration relief is tightly constrained by 8 U.S.C. § 1252(a)(2):

Section 1252(a)(2)(B)(i) bars judicial review of “any judgment regarding the granting of relief under” specified provisions, including cancellation of removal.
Section 1252(a)(2)(D), however, preserves review over “constitutional claims or questions of law.”

The Supreme Court has recently clarified these boundaries:

Patel v. Garland, 596 U.S. 328 (2022).
Held that federal courts lack jurisdiction to review factual determinations underlying denials of discretionary relief such as adjustment of status, even when framed as “eligibility” questions. The Court described review of such denials as “very limited.”
Wilkinson v. Garland, 601 U.S. 209 (2024).
Clarified that courts retain jurisdiction, under § 1252(a)(2)(D), to review at least some mixed questions of law and fact, such as whether established facts amount to the “exceptional and extremely unusual hardship” required for cancellation. Yet even after Wilkinson, courts may not reweigh evidence or revisit discretionary balancing.

In Flowers, the Seventh Circuit applied this framework: it could examine only whether the IJ and BIA committed legal errors (e.g., misinterpreting statutes, applying incorrect standards, or ignoring a category of evidence), but not whether they reached the “right” discretionary outcome.

C. Motions to Reopen and Standard of Review

A motion to reopen immigration proceedings is generally:

An opportunity to present new, material evidence or changed circumstances; and
Subject to strict time and number limits, with narrow exceptions.

The Seventh Circuit reviews denials of motions to reopen under a deferential abuse of discretion standard, as reiterated in:

Yusev v. Sessions, 851 F.3d 763, 766 (7th Cir. 2017) – The BIA abuses its discretion only if its decision is made “without a rational explanation, inexplicably departs from established policies, or rests on an impermissible basis.”
Cruz-Velasco v. Garland, 58 F.4th 900, 904 (7th Cir. 2023) – Reiterates this standard almost verbatim and applies it in the context of reopening.

Applying this standard, the court in Flowers found no irrationality or unlawful basis in the BIA’s refusal to reopen.

D. Treatment of Evidence by the IJ and BIA

When petitioners argue that the agency “ignored” evidence, courts distinguish between:

A genuine failure to consider an entire swath of relevant evidence, which can present a reviewable legal issue; and
A disagreement over the weight the agency assigned to that evidence, which is typically unreviewable.

Key Seventh Circuit authorities include:

Martinez-Baez v. Wilkinson, 986 F.3d 966, 976 (7th Cir. 2021) – The court cannot review claims that the agency simply failed to “conduct a thorough review of the record,” but it may intervene if the agency ignored “an entire swath of pertinent evidence.”
Aparicio-Brito v. Lynch, 824 F.3d 674, 687 (7th Cir. 2016) – Reiterates that appellate courts cannot reweigh the equities; they only ensure that the agency considered the evidence and applied correct legal standards.

In Flowers, because the IJ and BIA explicitly mentioned the abuse and Flowers’s claim that Gillett forced the false citizenship statements, the court treated the dispute as purely about weight, not consideration—and thus unreviewable.

E. I-130 Petitions and Adjustment of Status

An I-130 petition is a foundational step in many family-based immigration processes:

A U.S. citizen or lawful permanent resident relative files the I-130 to establish the qualifying relationship.
If approved, the petition classifies the noncitizen relative as eligible for an immigrant visa in a particular category.

The Seventh Circuit cited:

Souley v. Holder, 779 F.3d 720, 722 (7th Cir. 2015) – Explains that an I-130 is merely the first step toward adjustment of status; it does not confer any status by itself. The noncitizen must still be admissible and meet other statutory requirements for adjustment.

In Flowers’s case, the BIA concluded that even assuming an I-130 was filed or approved, her false claims to citizenship made her inadmissible and therefore ineligible for adjustment of status.

F. Waiver and Failure to Challenge Independent Grounds

An important procedural doctrine: when a lower tribunal’s decision rests on multiple, independent grounds, an appellant must challenge each ground on appeal. Failure to contest one such ground typically results in waiver, leaving that ground intact and dispositive.

The Seventh Circuit invoked:

Bradley v. Village of University Park, 59 F.4th 887, 897 (7th Cir. 2023) – Where a party does not address an independently dispositive reason for the judgment below, the issue is waived.

Here, Flowers argued that the BIA had erred in finding insufficient proof of the I-130 filing, but did not challenge the BIA’s separate conclusion that her inadmissibility (based on misrepresentation/false citizenship) made her ineligible for adjustment regardless of any I-130. Under Bradley, her failure to challenge that independent holding meant she had effectively conceded it.

V. The Court’s Legal Reasoning in Detail

A. Denial of Cancellation Without Reaching Statutory Eligibility

Flowers argued that the IJ and BIA erred legally by failing to first decide her statutory eligibility for cancellation of removal before denying relief on discretionary grounds. The Seventh Circuit rejected this argument, relying heavily on:

INS v. Bagamasbad, 429 U.S. 24 (1976) (per curiam) – The Supreme Court held that agencies are not required to make findings on issues that do not affect the outcome of the case. Thus, if an IJ concludes that relief would be denied as a matter of discretion, even assuming statutory eligibility, the IJ may decline to reach the eligibility question.
Patel v. Garland, 596 U.S. 328 (2022) – The Court reaffirmed that “eligibility only gets a noncitizen so far”; the noncitizen must also persuade the IJ that she merits a favorable exercise of discretion. Patel explicitly cites Bagamasbad and confirms that the agency may deny relief in its discretion without resolving eligibility first.

The Seventh Circuit quoted Patel’s formulation:

“[I]f the judge decides that denial would be appropriate regardless of eligibility, the judge need not address eligibility at all.” (Patel, 596 U.S. at 332 (citing Bagamasbad))

Applying these principles, the court concluded:

The IJ acted within lawful bounds by denying relief solely on discretionary grounds, based on the seriousness of the false citizenship claims.
The BIA committed no legal error in affirming on the same basis and likewise declining to resolve eligibility.

Thus, there was no reviewable “legal error” in the agencies’ choice of sequence (or non-sequence) between eligibility and discretion.

B. The Abuse Evidence: Considered, but Not Controlling

Flowers next asserted that the IJ and BIA had ignored evidence that her abusive former partner forced her to make the false citizenship representations. The distinction between “ignored” and “considered but not credited/weighted heavily” is crucial.

The Seventh Circuit observed:

The IJ explicitly mentioned Flowers’s contention about Gillett’s abuse in the order.
The BIA also referenced the abuse and indicated that it took this into account.

Under Martinez-Baez and Aparicio-Brito, the court’s jurisdiction allows it to correct legal error where an entire category of pertinent evidence is disregarded, but it does not allow the court to:

Reassign weight to different pieces of evidence, or
Substitute its own view of the equities for the agency’s.

The panel therefore characterized Flowers’s challenge as an attempt to relabel a disagreement over weight as an “ignored evidence” claim, and held that:

“Her argument boils down to the contention that the IJ and the Board gave her evidence insufficient weight—but we cannot resolve that dispute.”

Because weighing equities is the essence of discretionary adjudication, and Congress has stripped courts of power to review that aspect, the court lacked jurisdiction to revisit the agencies’ balance of:

Favorable equities (family ties, long residence, no criminal history, abuse survivor, employment), and
Adverse factors (particularly the false claims of U.S. citizenship).

C. The Motion to Reopen: Inadmissibility, Adjustment, and Waiver

On reopening, Flowers argued that:

Her child’s I-130 petition created a new path to lawful status (adjustment of status); and
Her youngest daughter’s ADHD diagnosis was a new hardship factor.

The BIA declined to reopen because:

Flowers did not provide adequate documentation of the I-130; and
In any event, her false citizenship claims rendered her inadmissible under 8 U.S.C. § 1182(a)(6)(C)(i), (ii)(I) and thus ineligible for adjustment of status regardless of any I-130.

In her petition for review to the Seventh Circuit, Flowers attacked only the first rationale (insufficient I-130 proof), but did not challenge the BIA’s separate conclusion that her inadmissibility barred adjustment.

Relying on Bradley v. Village of University Park, the court held:

Because Flowers ignored an independent, dispositive ground on which she lost before the BIA, she waived any challenge to that ground.
Once that ground stands unchallenged, the BIA’s denial of reopening must be affirmed, regardless of any errors concerning the I-130 documentation.

The court further noted that Flowers had not argued that her new evidence warranted reopening as a matter of discretion; but even if she had, the BIA’s reasoning did not lack a rational basis or deviate from established policies, so there was no abuse of discretion under Cruz-Velasco.

D. The Court’s Closing Observation: Constraints vs. Compassion

The panel ended by acknowledging explicitly that:

Flowers’s “appeal mostly comes down to her belief that the IJ and the Board exercised their discretion unfairly.”
The judges were “not unsympathetic” to her situation, recognizing her “decades-long track record of being a law-abiding, hard-working, family-supporting, upstanding member of the community who overcame an abusive relationship.”

Yet the court underscored that “Congress has stripped us of the authority to second-guess discretionary denials of relief, no matter our view of the merits.” Judicial review is limited to identifying legal and constitutional errors; it does not extend to revisiting how the agency weighed equities or exercised mercy.

The court noted that Flowers’s remaining hope might lie in prosecutorial discretion—that is, the executive branch’s choice whether to prioritize, defer, or forbear removal in individual cases—rather than in any further judicial remedy.

VI. Complex Concepts Simplified

A. Cancellation of Removal (Non-LPR Cancellation)

Cancellation of removal under 8 U.S.C. § 1229b(b)(1) is:

A discretionary form of relief for certain undocumented or otherwise removable noncitizens.
Intended for individuals who can demonstrate deep, long-standing ties to the United States and significant hardship to U.S.-citizen or lawful permanent resident family members if removed.

Even if all statutory boxes are checked, an IJ can still say: “You technically qualify, but as a matter of discretion I will not grant you this extraordinary relief.”

B. “Discretion” vs. “Eligibility”

Think of cancellation as a two-stage gate:

Eligibility Gate: Does the law permit the person to ask for this forgiveness? (e.g., enough years in the U.S., good moral character, no disqualifying crimes, and sufficiently severe family hardship.)
Discretionary Gate: Even if eligible, is this person deserving of this exceptional relief when we look at everything in the record—positive and negative?

Courts can usually review whether the IJ applied the right legal definition of eligibility. But they almost never can review the IJ’s judgment call that the person does or does not deserve the relief as a matter of discretion.

C. False Claim to U.S. Citizenship and Misrepresentation

Under 8 U.S.C. § 1182(a)(6)(C):

Paragraph (i) bars admission of any noncitizen who, by fraud or willful misrepresentation of a material fact, seeks to procure a visa or other immigration benefit.
Paragraph (ii)(I) adds an especially harsh bar: a noncitizen who falsely represents herself to be a U.S. citizen for any immigration purpose or to obtain certain benefits is generally permanently inadmissible, with only extremely narrow exceptions.

These provisions mean that a single false claim to being a U.S. citizen—even if it never led to criminal charges—can permanently block many forms of relief, including:

Adjustment of status (obtaining a green card from within the U.S.), and
Lawful “reentry” to the U.S. after travel abroad.

Flowers’s two admitted false claims to U.S. citizenship were thus not only significant to the IJ’s discretionary analysis but also legally fatal to her later attempt at adjustment of status.

D. Motion to Reopen

A motion to reopen is a request to the BIA (or IJ) to:

Reopen a completed case,
Consider new evidence or changed circumstances that could not have been presented earlier, and
Potentially change the outcome (for example, because a new form of relief has become available).

The bar is high. The new evidence must be:

Material,
Previously unavailable despite due diligence, and
Likely to affect the result.

Even then, the agency has broad discretion to deny reopening, and appellate courts review such decisions only for abuse of discretion.

E. Appellate “Waiver” of Arguments

On appeal, it is not enough for a petitioner simply to reiterate general dissatisfaction. The petitioner must:

Identify specific legal or constitutional errors, and
Address every independent reason the lower decision gave for denying relief.

If the BIA denies relief for multiple independent reasons and the petitioner fails to challenge one of them, the court treats that omission as waiver and will affirm the decision on the unchallenged ground alone.

That is what occurred in Flowers’s challenge to the denial of reopening: she did not contest the BIA’s conclusion that her false citizenship claims made her inadmissible and ineligible for adjustment.

“Prosecutorial discretion” refers to the executive branch’s power to choose whether and how to enforce immigration laws against particular individuals, including:

Deciding whether to initiate removal proceedings,
Whether to join or oppose certain forms of relief, and
Whether to grant deferred action or stay of removal in compelling cases.

Courts generally cannot order the government to exercise prosecutorial discretion; they can only note that it may be appropriate in sympathetic cases. The panel’s closing note suggests that Flowers’s remaining hope lies in administrative, not judicial, grace.

VII. Impact and Broader Significance

A. Reinforcement of Patel and Bagamasbad in the Seventh Circuit

Although nonprecedential, Flowers reinforces a now-settled principle: in cancellation cases, IJs and the BIA may:

Assume, without deciding, that a noncitizen is statutorily eligible for relief; and
Proceed directly to deny relief as a matter of discretion.

This approach streamlines adjudication and focuses on discretionary balancing rather than frequently complex eligibility determinations, but it also:

Limits the scope of appellate review—because purely discretionary judgments are largely unreviewable.
Prevents the development of eligibility-related case law in hard cases, since the agency never rules on those issues.

B. Narrowing Pathways for Long-Time Residents with False Citizenship Claims

The order vividly illustrates how a noncitizen’s long-term positive equities can be legally overshadowed by:

Past false claims to U.S. citizenship, even if coerced and never criminally prosecuted; and
The resulting inadmissibility that blocks other relief such as adjustment of status.

For practitioners and noncitizens, Flowers underscores:

The severe, often permanent immigration consequences of any false claim to being a U.S. citizen.
The importance of building a record—where possible—on coercion, duress, or abuse, and exploring any statutory exceptions that may exist (though these are extremely limited for false citizenship claims).

C. Litigation Strategy: Preserving Issues and Challenging All Grounds

The case is an object lesson in appellate strategy:

Petitioners must challenge every independent ground on which the BIA relied.
Failure to contest even one dispositive holding (such as ineligibility due to inadmissibility) can doom an appeal, regardless of how strong other arguments might be.

Counsel litigating immigration appeals must carefully read BIA decisions and structure briefs to ensure that no independent rationale is left unaddressed.

D. Humanitarian Cases in a Post-Patel, Post-Wilkinson Landscape

Flowers also illustrates how, even after Wilkinson slightly expanded review over mixed law-fact questions, courts remain:

Unable to review the core discretionary balancing of equities, and
Bound by Congress’s explicit jurisdictional limitations, even in deeply sympathetic, family-centric cases.

Where Congress has barred review of discretionary judgments, appellate courts may acknowledge hardship but must defer to the agency’s judgment unless a clear legal or constitutional error is identified.

E. Signals to the Executive Branch

While courts cannot compel prosecutorial discretion, decisions like Flowers implicitly signal to the executive branch the types of cases where such discretion might be especially warranted:

Long-term residents with strong U.S. family ties,
Victims or survivors of abuse,
Individuals with no criminal history and positive community contributions.

Here, the panel all but invited DHS to consider such discretion, noting that judicial avenues have been exhausted.

VIII. Conclusion

The Seventh Circuit’s disposition in Flowers v. Bondi is a sobering reminder of the rigid structure of modern U.S. immigration law and the narrowness of judicial review. Even in a case involving:

Nearly four decades of residence,
Five U.S.-citizen children and a grandchild dependent on the petitioner,
Absence of criminal convictions,
A documented history of domestic abuse, and
Consistent employment and positive community testimony,

the court concluded that:

It lacked authority to reassess the immigration judge’s and BIA’s discretionary weighing of positive versus negative factors;
An IJ may lawfully deny cancellation of removal solely on discretionary grounds without determining statutory eligibility; and
The BIA did not abuse its discretion in denying reopening, especially where an independent dispositive ground (inadmissibility due to false citizenship claims) went unchallenged on appeal.

The order synthesizes and applies key precedents—Patel, Wilkinson, Bagamasbad, Martinez-Baez, and others—to reaffirm that appellate courts:

Can guard against legal and constitutional errors,
Can ensure the agency has considered relevant evidence, but
Cannot second-guess the ultimate discretionary decision to withhold relief.

In the broader legal landscape, Flowers underscores the harsh consequences of false claims to U.S. citizenship, the limitations of judicial relief for long-settled, undocumented residents, and the crucial importance of executive-branch discretion in providing any remaining safety valve where the law itself offers none.

Note: This commentary is a legal analysis of the court’s opinion and does not constitute legal advice for any specific individual or case.