Reaffirming Specific Intent and Chain-of-Events Analysis in CAT Claims Involving Mental Illness: Commentary on Kebede v. Bondi

I. Introduction

This commentary examines the Second Circuit’s summary order in Kebede v. Bondi, No. 24‑441 (2d Cir. Nov. 20, 2025), a petition for review arising from the denial of protection under the Convention Against Torture (CAT) to an Ethiopian national with mental illness. Although the order is non‑precedential under the court’s rules, it is citable and provides a clear illustration of how federal courts apply the CAT “specific intent” requirement and the “chain of events” probability analysis, particularly in cases where the feared harm stems from inadequate mental health care and poor prison conditions in the country of removal.

The petitioner, Adane Kebede, a native and citizen of Ethiopia, sought CAT relief on the theory that, if removed, he would be unable to access necessary psychiatric medication. As a result, his untreated mental illness would allegedly lead to erratic behavior, arrest, incarceration under substandard prison conditions, and ultimately torture by prison guards or fellow inmates, or with the acquiescence of Ethiopian authorities.

An Immigration Judge (IJ) in Batavia, New York, denied CAT relief, and the Board of Immigration Appeals (BIA) affirmed. Kebede then petitioned the Second Circuit for review. The panel—Judges Newman, Menashi, and Pérez—denied the petition, holding that substantial evidence supported the agency’s determination that any likely harm did not amount to torture as defined under CAT and that the asserted chain of events was too speculative.

At its core, the decision:

Reaffirms that CAT protection requires specific intent to inflict severe pain or suffering by government actors (or with their acquiescence), and that harms resulting from poverty, overcrowding, or lack of resources do not ordinarily meet that standard.
Reinforces the “chain of events” framework, requiring that each necessary link leading to torture be “more likely than not” to occur, not merely possible or plausible.
Highlights the evidentiary burden facing applicants with serious mental illness who fear removal to countries with severely deficient mental health and prison systems.

II. Summary of the Opinion

The court begins by setting out the scope and standard of review. It reviews the IJ’s decision “as modified by the BIA” (citing Xue Hong Yang v. DOJ, 426 F.3d 520, 522 (2d Cir. 2005)), applies substantial evidence review to factual findings and de novo review to legal issues and mixed questions (citing Yanqin Weng v. Holder, 562 F.3d 510, 513 (2d Cir. 2009)), and notes the statutory command that administrative factual findings are conclusive unless “any reasonable adjudicator would be compelled to conclude to the contrary.” 8 U.S.C. § 1252(b)(4)(B).

The panel recites the CAT standard:

The applicant bears the burden to show that it is “more likely than not” that he would be tortured if removed. 8 C.F.R. §§ 1208.16(c)(2), 1208.17(a).
“Torture” is defined as severe physical or mental pain or suffering intentionally inflicted for specified purposes (such as punishment, coercion, or discrimination) by, or with the consent or acquiescence of, a public official. 8 C.F.R. § 1208.18(a)(1).
Pain or suffering arising only from, inherent in, or incidental to “lawful sanctions” is excluded. § 1208.18(a)(3).
The act must be “specifically intended” to inflict severe pain or suffering; unintended or unanticipated severity does not qualify. § 1208.18(a)(5); Pierre v. Gonzales, 502 F.3d 109, 118 (2d Cir. 2007).
Negligent acts and harm arising from lack of resources generally do not constitute torture (citing Matter of J‑R‑G‑P‑, 27 I. & N. Dec. 482 (BIA 2018); Matter of J‑E‑, 23 I. & N. Dec. 291 (BIA 2002)).

Turning to Kebede’s claim, the court acknowledges evidence that:

People with mental illness in Ethiopia face serious social stigma and discrimination, including difficulty obtaining employment and a belief that mental illness may be caused by supernatural forces.
There are significant shortages of psychiatric medication in Ethiopia.
Although there is one prison with mental health services, it is ill‑equipped to handle inmates with mental health conditions.

However, the court emphasizes that Kebede’s expert, Dr. Lahra Smith, attributed these deficiencies to “overcrowding and a lack of resources” rather than to a government policy or intent to cause suffering. That testimony, the court holds, does not satisfy CAT’s specific intent requirement: substandard prison conditions do not constitute torture absent evidence that authorities deliberately maintain them for the purpose of inflicting severe pain or suffering (citing Pierre and Matter of J‑R‑G‑P‑).

The court also rejects Kebede’s “chain of events” theory of future harm, which posited that:

He would not be able to obtain his psychiatric medication in Ethiopia because he lacks family connections.
Without medication, he would likely behave in ways leading to his arrest and detention.
In detention, he would lack access to medication or treatment.
His untreated mental illness would cause him to say or do inflammatory things, resulting in guards attacking him or permitting other inmates to attack him.

Relying on Savchuk v. Mukasey, 518 F.3d 119, 123 (2d Cir. 2008), and the Attorney General’s decision in In re J‑F‑F‑, 23 I. & N. Dec. 912 (A.G. 2006), the panel holds that CAT relief cannot rest on a speculative chain of events in which one or more links are not shown to be “more likely than not” to occur. A chain “cannot be more likely than its least likely link.” Here, the record fails to establish that all of the links—especially the alleged assaults by guards or fellow inmates—are probable rather than merely possible.

Further, invoking Jian Hui Shao v. Mukasey, 546 F.3d 138, 157–58 (2d Cir. 2008), the court notes that the record contained no evidence of violence against mentally ill prisoners or governmental disregard of such violence. The petitioner also did not clearly present, at the agency level, a specific theory that his unusual behavior would cause him to be attacked by guards or other prisoners; nor did he provide supporting evidence. The general testimony that speaking on “controversial topics” in prison could lead to “danger” was too vague and did not compel a finding that torture was “more likely than not.”

Because the record did not compel a conclusion contrary to the BIA’s, the court denies the petition, citing Quintanilla‑Mejia v. Garland, 3 F.4th 569, 593–94 (2d Cir. 2021) for the standard that substantial evidence review requires affirmance unless the evidence mandates a different result.

III. Detailed Analysis

A. Precedents and Authorities Cited

1. Xue Hong Yang v. DOJ – Scope of Review

In Xue Hong Yang v. DOJ, 426 F.3d 520 (2d Cir. 2005), the Second Circuit clarified that when the BIA issues a short decision that affirms the IJ but modifies or supplements the reasoning, the court reviews the IJ’s decision “as modified” by the BIA. That is, the court considers:

The IJ’s factual findings and legal conclusions that the BIA has expressly or implicitly adopted.
Any additional reasoning or legal analysis supplied by the BIA.
Excludes any grounds the BIA expressly rejected.

In Kebede, this principle justifies focusing on the IJ’s analysis of the CAT claim, as refined but not fundamentally altered by the BIA. The court does not revisit matters the BIA did not rely upon, which helps frame the universe of relevant issues on review.

2. Yanqin Weng v. Holder – Standards of Review

Yanqin Weng v. Holder, 562 F.3d 510 (2d Cir. 2009), restates key standards:

Factual findings (including predictions of future harm) are reviewed under the “substantial evidence” standard and are “conclusive unless any reasonable adjudicator would be compelled to conclude to the contrary.”
Questions of law and the application of law to undisputed facts are reviewed de novo.

In Kebede, these standards mean the court gives substantial deference to the IJ/BIA’s evaluations of what is likely to occur in Ethiopia (e.g., likelihood of arrest, prison conditions, likely treatment by guards) so long as those findings are reasonably supported by the record.

3. CAT Regulations – Defining “Torture” and the Burden of Proof

The court quotes and relies on several key provisions:

8 C.F.R. § 1208.16(c)(2) – To obtain CAT protection, the applicant must establish that “it is more likely than not that he or she would be tortured” in the country of removal.
8 C.F.R. § 1208.17(a) – Governs deferral of removal under CAT when the applicant is otherwise ineligible for withholding; the same “more likely than not” torture standard applies.
8 C.F.R. § 1208.18(a)(1) – Provides the definition of “torture,” requiring:
- Severe physical or mental pain or suffering,
- Intentionally inflicted,
- For certain purposes (e.g., obtaining information, punishment, intimidation, coercion, or discrimination),
- By, at the instigation of, or with the consent or acquiescence of a public official or person acting in an official capacity.
8 C.F.R. § 1208.18(a)(3) – Excludes from “torture” pain or suffering “arising only from, inherent in or incidental to lawful sanctions,” such as imprisonment that is lawfully imposed, so long as the sanction does not defeat CAT’s purpose of preventing torture.
8 C.F.R. § 1208.18(a)(5) – Clarifies the requirement of “specific intent”: torture must be specifically intended to inflict severe pain or suffering; unintended severity of pain or suffering is not enough.

These provisions form the backbone of the court’s analysis. The panel’s central conclusion is that the deficiencies in Ethiopia’s mental health infrastructure and prisons—as described by Dr. Smith—reflect resource constraints, not a specific intent by the government to inflict severe suffering on mentally ill persons.

4. BIA Precedents on Prison Conditions and Resource Constraints

a. Matter of J‑E‑, 23 I. & N. Dec. 291 (BIA 2002)

In Matter of J‑E‑, the BIA considered whether extremely harsh prison conditions in Haiti constituted torture. The decision held that:

Substandard prison conditions, even very harsh ones, generally do not constitute torture unless they are deliberately imposed to inflict severe pain or suffering.
Conditions resulting from poverty, neglect, or lack of resources generally fall short of “torture.”
Negligent acts do not suffice under CAT’s specific-intent standard.

J‑E‑ became foundational for prison‑conditions CAT claims, and the Second Circuit has repeatedly endorsed its approach.

b. Matter of J‑R‑G‑P‑, 27 I. & N. Dec. 482 (BIA 2018)

Matter of J‑R‑G‑P‑ built on J‑E‑ and similarly held that:

“Torture” does not cover negligent acts or harm arising from a lack of resources.
“Detention under substandard conditions” will not constitute torture absent evidence that authorities are “intentionally and deliberately” maintaining such conditions for the purpose of inflicting torture.

The Second Circuit in Kebede explicitly invokes J‑R‑G‑P‑ to underscore that the Ethiopian government’s failures to provide adequate mental health services—even coupled with stigma and poor prison conditions—do not, without more, establish the deliberate, specific intent to cause severe suffering required by CAT.

5. Pierre v. Gonzales, 502 F.3d 109 (2d Cir. 2007)

Pierre is the Second Circuit’s leading case on whether substandard prison conditions can amount to torture. Key points include:

The phrase “specifically intended” in § 1208.18(a)(5) incorporates a criminal law “specific intent” standard: the actor must intend the consequences (severe pain or suffering), not merely engage in conduct that foreseeably leads to such pain.
Prison conditions might be torture if:
- They cause severe pain or suffering, and
- The authorities’ purpose in imposing or maintaining such conditions (beyond normal incarceration discomforts) is to punish, intimidate, coerce, discriminate, etc.
Failures in diet, hygiene, and living space do not constitute torture under CAT unless they are “sufficiently extreme” and intentionally inflicted to cause severe suffering, not merely the product of “poverty, neglect, or incompetence.”

In Kebede, the panel quotes Pierre to emphasize:

Even the “utmost severity” of suffering is not torture without specific intent.
The record here shows overcrowding and resource-based failings, but no evidence that Ethiopian officials design or maintain those conditions for the purpose of harming mentally ill inmates.

6. Savchuk v. Mukasey and In re J‑F‑F‑ – Chain-of-Events Probability

Savchuk v. Mukasey, 518 F.3d 119 (2d Cir. 2008), adopting language from Attorney General’s opinion in In re J‑F‑F‑, 23 I. & N. Dec. 912 (A.G. 2006), holds:

A CAT applicant relying on a chain of future events must show that each link in the chain is “more likely than not” to occur.
The probability of the chain as a whole cannot exceed the probability of its least likely component: a chain “cannot be more likely than its least likely link.”

In Kebede, the petitioner’s theory depends on several sequential steps (no medication; erratic behavior; arrest and detention; no treatment in prison; provocations leading to attacks). The court applies Savchuk to hold that:

Not all the links were supported by evidence as “more likely than not.”
In particular, there was no concrete evidence that mentally ill detainees in Ethiopia are typically attacked or tortured by guards or inmates, or that the government acquiesces in such abuse.
Therefore, the overall chain of events remains too speculative to satisfy CAT’s standard.

7. Hui Lin Huang v. Holder, 677 F.3d 130 (2d Cir. 2012)

Hui Lin Huang reiterates that predictions of future events or likelihoods (such as whether someone will be arrested or tortured) are factual findings, not pure legal conclusions. As such, they receive substantial deference on judicial review.

In Kebede, this supports the panel’s deference to the IJ/BIA’s conclusion that the alleged chain of events was not more likely than not to occur. The court treats the agency’s assessment of how Ethiopian society and institutions will respond to Kebede’s mental illness as a factual matter.

8. Jian Hui Shao v. Mukasey, 546 F.3d 138 (2d Cir. 2008)

Jian Hui Shao articulates an important evidentiary rule in the substantial evidence context: when the petitioner bears the burden of proof, the absence of evidence supporting his theory can itself constitute substantial evidence for the agency’s contrary finding.

In Kebede, the panel notes that:

The record contains no evidence of violence against mentally ill prisoners in Ethiopia or governmental tolerance of such violence.
Kebede did not present documentary evidence (e.g., human rights reports) or specific testimony on this point.

Thus, his failure to produce evidence to support a key link in his chain (guards or inmates attacking him with official acquiescence) becomes an affirmative reason to uphold the denial of CAT protection.

9. Quintanilla‑Mejia v. Garland, 3 F.4th 569 (2d Cir. 2021)

Quintanilla‑Mejia restates the standard for substantial evidence review: a court must deny a petition unless the record compels a conclusion contrary to that reached by the agency. This underscores the deferential posture of appellate review, especially where the record is equivocal or incomplete.

In Kebede, the court holds that the record does not compel the conclusion that Kebede is more likely than not to be tortured if returned to Ethiopia. At most, the evidence suggests significant hardship and potential danger, but not the inevitable or probable infliction of torture as narrowly defined by CAT.

B. The Court’s Legal Reasoning

1. The Specific-Intent Requirement in the CAT Context

A central pillar of the decision is the reaffirmation of CAT’s specific intent requirement. Under § 1208.18(a)(5) and Pierre:

The actor must intend to cause severe physical or mental pain or suffering.
The mere foreseeability that certain conditions will cause pain or suffering is inadequate.
Negligence, recklessness, incompetence, or the by‑products of limited resources do not satisfy this requirement.

Applied to Ethiopia, the court accepts that:

Mental health services and medications are scarce, partly due to systemic resource constraints.
Prisons are overcrowded and lack adequate mental health facilities.
These conditions may cause very serious hardship for individuals like Kebede.

However, the record does not show that Ethiopian officials are:

Deliberately designing prison conditions or health policies with the purpose of inflicting severe suffering on mentally ill persons, or
Using deprivation of treatment as a punishment or tool of discrimination in a way that rises to the level of “torture.”

Because Dr. Smith tied the shortcomings to “overcrowding and a lack of resources,” the panel treats the harms as primarily resource‑driven rather than intent‑driven. Under CAT as interpreted in Pierre and the BIA cases, such harms are not enough, even if they could cause extreme suffering in practice.

2. “Lawful Sanctions” and the Limits of CAT Protection

The court also invokes § 1208.18(a)(3), which excludes from “torture” pain or suffering that is incidental to “lawful sanctions,” such as imprisonment that is lawfully imposed under domestic law, provided those sanctions do not defeat CAT’s purpose.

In Kebede, this principle reinforces the notion that:

Legitimate criminal prosecution and imprisonment—together with the usual hardships of incarceration—do not automatically amount to torture.
Only when prison conditions are so deliberately harsh and purposively inflicted to cause severe suffering do they cross the line into torture.

The panel effectively treats the possibility that Kebede may be arrested and imprisoned as falling within the realm of lawful sanctions unless he can show that the authorities would weaponize imprisonment specifically to torture him.

3. Application to Mental Illness: Stigma vs. Torture

The court acknowledges evidence that persons with mental illness in Ethiopia face:

Social stigma and discrimination,
Beliefs in supernatural causation of mental illness,
Difficulties accessing employment and medical care.

Nonetheless, the key gap in Kebede’s case is:

The lack of evidence that Ethiopian officials intentionally target mentally ill people for severe mistreatment for punitive, coercive, or discriminatory purposes rising to the level of torture.
The absence of documentation that guards or prison authorities regularly abuse mentally ill inmates with the conscious objective of causing severe pain or suffering.

Thus, while the court does not minimize the seriousness of the discrimination and deprivation, it treats these harms as falling short of the legal threshold for “torture” as currently defined in U.S. law and regulations.

4. The Chain-of-Events Analysis and Speculation

The court’s treatment of Kebede’s four‑step chain illustrates how strictly the chain‑of‑events framework is applied under CAT:

No access to medication due to lack of family connections.
The record suggests shortages and systemic obstacles to mental health treatment, but does not definitively establish that it is more likely than not that Kebede himself would be unable to obtain any treatment. This is a contested factual premise.
Untreated mental illness leading to arrest and detention.
Kebede posits that his symptoms would result in behavior that draws police attention and leads to incarceration. The record does not demonstrate, however, that mentally ill people in Ethiopia are regularly arrested simply for symptomatic behavior, or that such an outcome is more likely than not for him.
No treatment in detention.
There is evidence that prison mental health services exist but are inadequate. It is unclear whether this makes it more likely than not that Kebede would receive no meaningful treatment if jailed. The record points to shortages and poor quality, but the court focuses more heavily on the next link.
Untreated illness leading to inflammatory speech or conduct, causing guards or inmates to attack him.
This link is the most speculative and least supported. The court notes the absence of:
- Evidence that mentally ill prisoners are routinely subjected to violence by guards or inmates because of their condition, and
- Country-condition reports or testimony indicating that the government condones or ignores such violence.

Because at least one, and arguably several, links in the chain are not shown to be “more likely than not,” Savchuk and J‑F‑F‑ dictate that the chain as a whole cannot satisfy CAT’s probability standard. The court therefore characterizes Kebede’s future torture scenario as speculative rather than probable.

5. Burden of Proof and Evidentiary Gaps

Jian Hui Shao plays a pivotal role in the panel’s logic: Kebede bears the burden of proof, and his failure to produce evidence of systematic violence against mentally ill detainees or governmental acquiescence is itself a reason to deny relief. The court explicitly notes:

The administrative record contains no reports documenting such violence.
Kebede did not substantively argue before the agency that he would be attacked by prisoners or guards because of his behavior, nor did he support that theory with evidence.
His expert’s generalized observation that speaking on “controversial topics” in prison could lead to “danger” does not equate to a finding that torture is more likely than not.

Under substantial evidence review, these omissions suffice to uphold the agency’s denial, because the record does not compel a contrary conclusion.

C. Impact and Implications

1. CAT Claims Based on Mental Illness and Inadequate Health Systems

Though non‑precedential, Kebede sends a strong signal to practitioners and adjudicators:

CAT claims rooted in mental illness and inadequate health care systems face a high evidentiary bar.
Evidence that a country lacks psychiatric infrastructure, has medication shortages, or stigmatizes mental illness is not, by itself, sufficient to establish torture.
Applicants must show that:
- Government officials (or those acting with their consent or acquiescence) deliberately exploit those conditions to inflict severe pain or suffering, or
- There is a systematic pattern of purposeful abuse directed at mentally ill people that rises to the level of torture.

The decision may make it harder for similarly situated noncitizens to prevail on CAT claims based primarily on systemic neglect, stigma, and poor services, unless they can document a pattern of state‑sponsored or state‑condoned violent abuse.

2. Prison-Conditions Claims Under CAT

Kebede continues the Second Circuit’s adherence to Pierre, J‑E‑, and J‑R‑G‑P‑ by reaffirming that:

Substandard prison conditions, even when extreme, are usually not enough.
Specific intent remains the decisive factor: the state must be shown to be deliberately imposing or allowing those conditions in order to cause severe suffering.
Resource‑based deficiencies, even if severe and foreseeable, are not ordinarily “torture” in this framework.

For prisoners and detainees with mental illness, this means that evidence of abusive or punitive treatment—above and beyond structural deficiencies—is critical for CAT success.

3. Litigation Strategy and Issue Preservation

Kebede underscores several strategic points for counsel:

Develop each link in the chain: When relying on a chain‑of‑events theory, each step must be supported by specific, credible evidence (e.g., country reports, expert testimony, affidavits) showing it is more likely than not.
Document patterns of violence: For claims based on potential assault by guards or inmates, applicants need:
- Human rights reports detailing abuse of mentally ill prisoners,
- Expert testimony linking mental illness to increased risk of targeted violence, and
- Evidence of official acquiescence or encouragement.
Raise arguments clearly before the IJ and BIA: The court specifically notes Kebede did not allege before the agency that he would be attacked by prisoners or guards based on his behavior, nor did he offer evidence for that theory. Failure to properly raise such arguments can effectively foreclose them on judicial review.

4. Nonprecedential Yet Influential

Although this disposition is a summary order without formal precedential effect, under Federal Rule of Appellate Procedure 32.1 and Local Rule 32.1.1:

It can be cited as persuasive authority.
It reflects the current approach of a Second Circuit panel to mental‑illness‑based CAT claims, thereby influencing how IJs, the BIA, and litigants may frame and evaluate similar claims.

Practitioners in the Second Circuit will likely point to Kebede when opposing or supporting CAT claims that rely on generalized allegations of poor medical or prison conditions in the country of removal.

5. Broader Human Rights and Disability Context

From a broader human rights perspective, Kebede highlights a tension:

International disability and human rights norms often treat severe deprivation of medical care, inhumane confinement conditions, and discriminatory treatment of persons with mental illness as serious violations.
Under U.S. implementing regulations and judicial interpretation of CAT, however, only those abuses carried out with the specific intent to cause severe pain or suffering qualify as “torture.”

The decision thus illustrates how U.S. CAT jurisprudence can leave a gap between profound suffering caused by systemic neglect and the narrower set of state actions that qualify as “torture” for purposes of protection from removal.

IV. Complex Concepts Simplified

For clarity, the following legal concepts used in the opinion are explained in simpler terms:

Convention Against Torture (CAT)
An international treaty that prohibits states from sending people to countries where there are substantial grounds to believe they would be tortured. In U.S. immigration law, CAT protection prevents removal to such countries but does not necessarily provide lawful permanent status.
“More likely than not” standard
A probability standard meaning “greater than 50%.” To win under CAT, the applicant must show that there is a better than even chance he will be tortured if removed.
Specific intent
In this context, the perpetrator must intend to cause severe pain or suffering, not just engage in conduct that happens to cause it. For example, deliberately beating someone to make them suffer satisfies specific intent; failing to provide medical treatment because of systemic shortages, without a deliberate purpose to cause suffering, does not.
Lawful sanctions
Penalties such as imprisonment that are allowed under a country’s law. Pain or hardship that comes only from being lawfully punished (e.g., the normal discomforts of prison) does not usually count as torture, unless the conditions are so deliberately cruel that they defeat the purpose of CAT.
Acquiescence of a public official
A public official’s awareness of, and failure to prevent, torture by others. Under CAT, the government may be held responsible not only for directly inflicting torture but also for knowingly allowing others (like private actors or prison guards) to do so.
Substantial evidence review
A very deferential standard of judicial review. The court must uphold the agency’s factual findings as long as they are supported by “reasonable, substantial, and probative” evidence—unless the record compels a contrary conclusion.
Chain-of-events analysis
When a CAT claim is based on several future events happening in sequence, the applicant must show that each step is more likely than not. If any one step is too uncertain, the entire chain is too speculative to satisfy CAT.
Summary order (nonprecedential decision)
A relatively brief decision of the court that, under local rules, does not have binding precedential effect. It can be cited as persuasive authority but does not formally bind future panels as published opinions do.

V. Conclusion

Kebede v. Bondi provides a clear illustration of how the Second Circuit applies the CAT framework to claims arising from mental illness, poor medical infrastructure, and substandard prison conditions abroad. The court:

Reaffirms that CAT’s protection is limited to situations where severe pain or suffering is intentionally inflicted or knowingly condoned by officials.
Distinguishes structural deficiencies and resource shortages—even when gravely harmful—from torture as legally defined.
Applies a rigorous chain-of-events probability analysis, requiring each link in a predicted sequence of harms to be more likely than not.
Emphasizes the applicant’s burden to produce concrete, specific evidence, particularly of targeted violence and official acquiescence, rather than relying on generalized concerns.

While the decision does not break new doctrinal ground, it sharply illustrates the demanding evidentiary and intent requirements that govern CAT claims and underscores the challenges facing mentally ill noncitizens seeking protection from removal to countries with inadequate mental health and prison systems. In the broader legal context, Kebede continues the trend of a narrow, specific‑intent‑focused interpretation of “torture,” leaving substantial suffering caused by systemic neglect or resource scarcity outside the reach of CAT relief as currently implemented in U.S. immigration law.