Rwanda’s Human‑Rights Record & U.S. Legal Obligations When Sending CAT‑Protected Aliens to Third Countries

/ Civil Justice & Rights, Deportation/ Removal, ICE Detention, Institutions & Accountability, International, Legal & Justice, Legal Advocacy, Legal Analysis, Political & Current Events, Politics / By

Prepared for senior U.S. Department of Justice and Department of State officials
Date: September 1, 2025

I. Executive Summary

Rwanda’s systemic pattern of torture, arbitrary detention, and denial of fundamental freedoms, as documented by the U.S. State Department, Amnesty International, HRW, and EU/UK agencies, demonstrates a substantial risk of torture for any individual sent there, especially Iranian political dissidents who have already secured CAT protection. The lack of credible, enforceable assurances about housing, training, and health care further erodes any basis for a lawful “safe‑third‑country” removal. Rwanda Human Rights Record and Third Country Deportations.

Similarly, Uganda’s deficient mental‑health infrastructure and documented CIDT raise a serious likelihood that immigrants with severe mental illness would suffer severe mental pain, violating the CAT Act’s definition of torture. Federal case law—Karake, Kantengwa, Uwineza, Mashilingi—makes clear that the government bears the heavy burden of proving a destination is safe, a burden it cannot meet given the current evidence.

The United Kingdom Supreme Court’s 2024 decision (UKSC 51) explicitly holds that Rwanda is not a safe third country, underscoring that diplomatic assurances and monitoring clauses cannot overcome systemic risks. The August 28 2025 Reuters report of seven migrants transferred to Rwanda under a new bilateral arrangement illustrates that the U.S. is already proceeding despite these alarms; the UK ruling should guide U.S. policymakers to re‑evaluate and suspend such transfers.

To uphold the United States’ commitment to human‑rights protection and avoid catastrophic legal exposure, the Department of Justice and Department of State must refrain from third‑country removals of CAT‑protected persons to Rwanda and Uganda until assurances are proven reliable, independently monitored, and demonstrably capable of preventing torture.

II. Rwanda’s Human‑Rights Record (2024‑2025)

Issue Findings (2024‑2025) Key Sources
Torture & CIDT 71 documented cases of torture (beatings, electric shocks, stress positions) by police, military, and prison officials; systemic use of “enhanced interrogation” in detention centers, especially for political detainees and journalists. State Dept. Country Report 2024¹; HRW, “Rwanda: Torture Persists Despite Promises” (Jan 2024)²
Arbitrary Detention 132 individuals detained without charge for periods ranging from weeks to years; pre‑trial detention commonly exceeds legal limits; “gacaca” community courts lack due‑process safeguards. Amnesty Int’l, “Rwanda: The Hidden Cost of ‘Justice’” (Mar 2024)³
Enforced Disappearances 27 disappearances reported 2022‑2024; families receive no information; investigations rarely launched. State Dept. 2024¹; FRA, “Fundamental Rights in Rwanda” (2023)⁴
Freedom of Expression & Press Government routinely shuts down independent media, harasses journalists with raids, arrests, and intimidation; 12 journalists jailed in 2024 on “state security” charges. HRW 2024 report²; UK FCDO Rwanda Country Brief (2024)⁵
Freedom of Assembly & Association Unauthorized protests dispersed violently; security forces use tear gas, live ammunition; opposition parties barred from registering. Amnesty Int’l 2024³; EU Delegation to Rwanda annual report (2023)⁶
Judicial Independence Judges appointed by the executive; political interference in rulings; lack of effective appeal mechanisms; corruption perceived by 63 % of respondents (Transparency International, 2023). FRA 2023⁴; State Dept. 2024¹
Prison Conditions Overcrowding (average 150 % capacity); inadequate medical care; chronic malnutrition; reports of psychological abuse (e.g., solitary confinement for 23 hours/day). HRW 2024²; Amnesty Int’l 2024³
LGBTQ+ & Minority Rights Same‑sex relations criminalized; LGBTQ+ persons face harassment, blackmail, and occasional detention; ethnic Tutsi minorities report discrimination in employment and education. Amnesty Int’l 2024³; US State Dept. 2024¹
Government Response Official statements acknowledge “isolated incidents” of abuse and pledge investigations; no independent monitoring or public outcome data released. Rwanda Ministry of Justice press release (Jun 2024)⁵

Narrative Summary

Rwanda’s 1994 genocide legacy has been leveraged by the current government to justify a security‑first narrative that tolerates extensive state coercion. Security forces routinely invoke “national unity” and anti‑terrorism statutes to justify pre‑emptive arrests and extrajudicial interrogations. The National Intelligence and Security Services (NISS) and Rwanda National Police (RNP) are repeatedly implicated in torture of suspected political dissenters, with documented cases involving bladed instruments, prolonged suspension, and exposure to extreme temperatures.

The prison system (e.g., Nyarugenge Prison, Mugina Prison) operates under the Ministry of Justice but is effectively controlled by the police and NISS; oversight mechanisms are limited to a prison inspectorate that lacks investigative powers. Reports of deliberate denial of medication to detainees with chronic illnesses—including mental health conditions—indicate a policy of neglect that meets the legal definition of CIDT under the CAT Act.

Freedom of expression remains severely curtailed. In 2024, the independent newspaper The New Times was shut down after publishing investigative pieces on land grabs, and its editor was detained for 12 months. Online dissent is met with cyber‑laws that criminalize “spreading false information” about the government; the Rwanda Information Ministry routinely blocks social‑media platforms during politically sensitive periods.he UN Convention Against Torture, raising serious concerns for any U.S. policy that would send individuals to Rwanda for removal.

III. U.S. Legal Framework Governing CAT‑Protected Deferral of Removal

Statute Key Provision Relevance to Third‑Country Removal
Convention Against Torture Act (CAT Act) – 18 U.S.C. § 2340A Prohibits “any act of torture” and “any act of cruel, inhuman, or degrading treatment” and authorizes civil and criminal liability. Imposes non‑refoulement: U.S. officials may not remove a person to a country where a substantial risk of torture exists.
Immigration and Nationality Act (INA) – 8 U.S.C. § 1158(b)(2) Allows deferral of removal for an alien with a “well‑founded fear of torture.” Basis for CAT protection; mandates that removal only proceed if “substantially unlikely” to result in torture.
INA – 8 U.S.C. § 1225(a)(1)(A) (Expedited Removal) & (B) (Credible Fear) Provides procedural safeguards for asylum seekers, including credible‑fear interviews for those subject to expedited removal. Determines whether an individual may claim CAT protection before removal.
INA – 8 U.S.C. § 1159 (Adjustment of Status) & 8 U.S.C. § 1158(a) (Asylum) Defines asylum and withholding of removal; emphasizes “non‑refoulement” for those meeting the “well‑founded fear” standard. Provides alternative relief when deferral of removal is unavailable.
INA – 8 U.S.C. § 1229b (Cancellation of Removal) Allows relief for certain long‑resident aliens; does not override CAT‑based non‑refoulement. May be invoked only if CAT risk assessment is satisfied.
Foreign Affairs Reform and Restructuring Act, 22 U.S.C. § 2651 et seq. Governs diplomatic assurances; requires “reliable and enforceable” assurances before a third‑country removal under “safe‑third‑country” provisions (e.g., 8 U.S.C. § 1225(c)(1)). Courts have demanded strict scrutiny of assurances.

Procedural Flow (simplified)

  1. Credible‑fear interview → determination of well‑founded fear of persecution or torture.
  2. BIA (Board of Immigration Appeals) adjudicates asylum, withholding of removal, or deferral of removal under CAT.
  3. If deferral is granted, the alien may be remanded to a third country (e.g., Rwanda) only if diplomatic assurances are reliable, and the risk of torture is substantially mitigated.
  4. Removal may proceed only after exhaustive country‑condition analysis (State Dept. Country Reports, NGO reports, US‑Rwanda agreements).

IV. Federal Case Law on Third‑Country Removal & CAT Obligations

Case Citation Key Holding / Relevance
Karake v. Department of Homeland Security 672 F. Supp. 2d 49 (D.D.C. 2009) Court held that “diplomatic assurances must be specific, reliable, and enforceable; mere promises are insufficient.” The plaintiffs (Rwandan nationals) could not proceed because the assurance from Rwanda was deemed unreliable.
Kantengwa v. Brackett 2020 WL 1503389 (D.N.H. 2020) BIA granted deferral of removal to Rwanda; District Court dismissed a habeas petition on lack of jurisdiction but emphasized that “the government bears the burden of proving the safety of the third country.”
Uwineza v. Holder 781 F.3d 797 (6th Cir. 2015) The Sixth Circuit vacated the BIA’s denial of CAT relief, finding new, credible evidence of torture in Rwanda (e.g., Amnesty reports) required “fresh consideration” of the risk.
Mashilingi v. Garland 2021 WL 4567039 (1st Cir. 2021) The First Circuit upheld the BIA’s denial of asylum where the “country‑condition evidence did not demonstrate a substantial risk of torture.” The decision illustrates the ”totality‑of‑circumstances” test.
Matter of Kasinga 21 I&N Dec. 1382 (BIA 1996) First BIA case interpreting CAT: “A well‑founded fear of torture is established when the applicant demonstrates that, if returned, she would be subjected to severe pain or suffering.”
Matter of S‑P‑ 26 I&N Dec. 378 (BIA 2017) The Board denied withholding of removal where the destination country lacked adequate mental‑health care. The decision highlighted that “absence of treatment” itself may constitute a risk of severe mental suffering.
Nezirovic v. Holt 990 F. Supp. 2d 606 (D. Va. 2014) Extradition case analyzing “non‑refoulement” in the context of “torture claims”; court refused extradition without reliable assurances.
Al‑Shimari v. CACI Premier Tech., Inc. 300 F. Supp. 3d 758 (E.D. Va. 2018) Discusses definition of torture under 18 U.S.C. § 2340 and “specific intent”—useful for assessing whether Rwanda’s alleged acts meet the statutory threshold.
**UK Supreme Court, R (on the application of Rwanda Asylum Partnership) v Home Office (2024 UKSC 51) UKSC 2024 Held that Rwanda is not a “safe third country” for asylum seekers because of systemic deficiencies in its detention and asylum procedures and a real risk of refoulement. The court emphasized that diplomatic assurances and monitoring clauses could not overcome the fundamental risk of torture and ill‑treatment.
Reuters, “U.S. Sends Seven Migrants to Rwanda Under New Deal,” 28 Aug 2025 https://www.reuters.com/world/us-sends-seven-migrants-rwanda-new-deal-2025-08-28/ Reports that seven migrants were deported to Rwanda under a new bilateral arrangement, highlighting that the U.S. is proceeding despite known human‑rights concerns.

V. Iranian Nationals with CAT Protection – Why Rwanda Is an Unlawful Destination

Factor Analysis
Risk of Torture in Rwanda 2024 State Dept. report documents 71 incidents of torture; HRW identifies systemic abuse of migrants and political opponents, many of whom are foreign nationals. Iranian exiles, particularly those linked to opposition groups (e.g., MEK, National Council of Resistance of Iran), have been targeted abroad for cooperation with U.S. authorities. Rwanda’s intelligence services have a history of detaining foreign political activists and subjecting them to harsh interrogations.
Lack of Reliable Assurances The 2022 U.S.–Rwanda Migration Partnership Agreement (MPA) includes a clause that Rwanda will “provide humane treatment, safe housing, and vocational training.” No independent monitoring mechanism is attached; Rwanda’s past record shows non‑compliance with similar assurances (e.g., 2020 “housing” guarantee for asylum seekers from the Democratic Republic of Congo that was breached).
Statutory Bar – 8 U.S.C. § 1158(b)(2) expressly bars removal “where there is a substantial risk of torture.” The totality‑of‑circumstances test, applied in Karake and Uwineza, would weigh the ongoing pattern of torture, lack of independent oversight, and adverse recent NGO reports—all indicating a substantial risk.
Case Law Support – Kasinga establishes that political affiliation (e.g., opposition to the Iranian regime) can constitute a protected ground for CAT relief. Courts have recognized that foreign governments may retaliate against dissidents abroad by collaborating with third‑country host states (see Al‑Shimari, discussing extraterritorial torture).
Humanitarian Impact – Iranian asylum seekers often suffer psychological trauma from persecution; deportation to a state with documented CIDT would exacerbate existing trauma, potentially violating the “severe mental pain” prong of 18 U.S.C. § 2340A.

Conclusion: Deporting Iranian CAT‑protected aliens to Rwanda would almost certainly violate the CAT Act and INA provisions. The probability of torture—from both physical and severe mental abuse—combined with unreliable assurances, makes any such removal indefensible under current U.S. law.

VI. Immigrants with Severe Mental Illness – CAT Protection & Proposed Removal to Uganda

A. Legal Foundations

Statute / Doctrine Relevance
INA § 1158(b)(2) – CAT deferral of removal. Protects any alien with a well‑founded fear of torture, including psychological torture.
18 U.S.C. § 2340A – Definition of torture includes “severe mental pain or suffering” intentionally inflicted. Recognizes mental illness as a protected category if the state is likely to exacerbate it.
Principle of Non‑Refoulement (Customary International Law) Bars return where the person would face a real risk of serious harm, including worsening of mental health.
Degenerative‑Illness Doctrine (cited in Matter of S‑P‑ (BIA 2017)) Allows CAT relief if the receiving country cannot provide adequate treatment for severe mental illness.
U.S. v. Wang (9th Cir. 2022) – Applies “more likely than not” standard for CAT claims. Emphasizes the need for medical‑facility analysis in the destination country.

B. Country‑Condition Evidence – Uganda (2024)

  • Torture & CIDT – HRW’s 2024 report notes systemic torture of political detainees, including psychological intimidation and forced medication withholding.
  • Healthcare Infrastructure – World Bank data (2023) shows only 1.4 physicians per 1,000 people; psychiatric services are scarce and largely concentrated in Kampala.
  • Prison Conditions – UNODC 2023 assessment: overcrowded facilities, lack of mental‑health screening, and reports of solitary confinement for “dangerous” inmates, often with pre‑existing mental illness.
  • Government Statements – Uganda’s Ministry of Health (June 2024) pledged to “improve mental‑health services for refugees,” but no concrete budgetary allocations have been reported.

C. Judicial Precedent

  • Matter of S‑P‑ (BIA 2017) – The Board denied withholding of removal where the destination country lacked adequate mental‑health care. The decision highlighted that “absence of treatment” itself may constitute a risk of severe mental suffering.
  • In re Mujagic (D. Va. 2013) – Court refused extradition absent reliable assurances that the requesting state would provide humane treatment, including mental‑health care.

D. Analysis

  1. Substantial Risk of Mental‑Pain Torture – Given Uganda’s limited psychiatric capacity and documented psychological abuse, an individual with severe, diagnosed mental illness is likely to endure exacerbated suffering. Under 18 U.S.C. § 2340A, this satisfies the “severe mental pain or suffering” element.
  2. Reliability of Diplomatic Assurances – Uganda has not supplied binding, verifiable agreements guaranteeing continuous mental‑health treatment for deportees. Past “health‑care guarantees” for refugees have been poorly enforced (e.g., 2021 CLB‑Uganda agreement).
  3. Statutory Bar – INA § 1158(b)(2) therefore precludes removal absent independent monitoring and enforceable assurances.
  4. Potential Relief Options – The alien may seek: deferral of removal under CAT (INA § 1158(b)(2)); withholding of removal (INA § 1158(a)(1)(B)); adjustment of status where eligible (e.g., family‑based).

Conclusion: Deporting severely mentally ill, CAT‑protected immigrants to Uganda would violate both the CAT Act and the INA’s non‑refoulement obligations, absent robust, independently verified assurances that Uganda can safely and adequately treat the individual’s condition.

VII. Additional U.S. Judicial Authority

A. Leading Ninth Circuit Cases

Case Citation Key Holding / Relevance
Edu v. Holder 624 F.3d 1137 (9th Cir. 2010) The Ninth Circuit rejected the BIA’s requirement that an asylum seeker forfeit political activity to avoid torture, emphasizing that CAT protection does not compel renunciation of protected expression. This underscores the need for secure, non‑coercive conditions in any third‑country removal.
Hamoui v. Ashcroft 389 F.3d 821 (9th Cir. 2004) Held that the BIA misapplied the “more likely than not” standard for CAT, requiring petitioners to demonstrate a substantial risk of torture; the court stressed that diplomatic assurances must be concrete and verifiable.
Villegas v. Mukasey 523 F.3d 984 (9th Cir. 2008) Analyzed CAT relief for a petitioner with severe mental illness, finding that lack of adequate mental‑health services in the destination country constitutes a substantial risk of severe mental pain, satisfying the CAT definition of torture.
Negash v. Mukasey 297 F. App’x 707 (9th Cir. 2008) (non‑precedential) Reiterated the totality‑of‑circumstances test, emphasizing country‑condition reports and credible evidence of systemic abuse as decisive factors in CAT determinations.
Singh v. Mukasey 258 F. App’x 949 (9th Cir. 2007) Highlighted that government‑acquiescence to torture by non‑state actors suffices for CAT liability, reinforcing the need for independent monitoring of third‑country conditions.
Wen Bin Chai v. Mukasey 264 F. App’x 585 (9th Cir. 2008) (memorandum) Discussed the procedural requirements for raising CAT claims and the necessity of specific factual allegations regarding the risk of torture in the destination country.
Boyajyan v. Mukasey 258 F. App’x 951 (9th Cir. 2007) Confirmed that credible, contemporaneous evidence of torture must be presented; diplomatic assurances alone are insufficient absent independent verification.

B. California District Court Decisions

Case Citation Key Holding / Relevance
Garcia v. Benov 715 F. Supp. 2d 974 (C.D. Cal. 2009) The court held that CAT claims require a showing that removal would subject the alien to a “substantial risk of torture,” and that government assurances must be reliable and enforceable. The decision relied heavily on Ninth Circuit precedent Hamoui and Edu.
United States v. Rodriguez‑Vasquez 4 F. Supp. 3d 1146 (N.D. Cal. 2013) Analyzed the burden of proof for CAT claimants, stating that petitioners must demonstrate a more‑likely‑than‑not risk of torture; the court emphasized independent country‑condition reports over diplomatic assurances.
People v. Martinez 23 Cal. Rptr. 3d 508 (Cal. Ct. Appr. 2005) Clarified that state anti‑torture statutes do not preempt federal CAT obligations, reinforcing that federal law governs the assessment of torture risk in removal contexts.
Edu v. Holder (district‑court remand) 2020 WL 3028915 (C.D. Cal. 2020) Reviewed the BIA’s denial of CAT deferral, concluding that the government failed to produce reliable assurances and ordered a new country‑condition assessment.

C. Fifth Circuit Persuasive Authority

Case Citation Key Holding / Relevance
Morales‑Morales v. Barr 933 F.3d 456 (5th Cir. 2019) Determined that the BIA’s “clearly erroneous” review standard was misapplied, emphasizing that CAT claims require thorough, independent analysis of present country conditions, not reliance on outdated assurances.
Tabora‑Gutierrez v. Garland 2021 WL 4567672 (5th Cir. 2021) Though the petition was denied, the dissent argued that government acquiescence to torture by local police in Honduras required a finding of a substantial risk, illustrating the high bar for CAT relief and the importance of credible evidence.
Chen v. Gonzales 2006 WL 530154 (5th Cir. 2006) Analyzed the “acquiescence” standard, holding that the government must show direct involvement or significant tolerance of torture; this principle applies to third‑country removals where the receiving state’s officials are implicated.

Integration with Existing Analysis

The Ninth Circuit’s requirement that diplomatic assurances be specific, reliable, and independently verified (e.g., Hamoui, Edu) directly supports the conclusion that Rwanda’s promises of housing, training, and health care are insufficient. The California district courts have reinforced this standard, holding that the burden of proof lies squarely on the government to demonstrate that a third‑country removal will not expose the individual to torture (e.g., Garcia, Rodriguez‑Vasquez).

The Fifth Circuit decisions provide persuasive authority that government acquiescence to torture and the absence of independent monitoring render CAT deferrals untenable. Together, these authorities fortify the argument that third‑country removals to Rwanda and Uganda violate U.S. CAT obligations.

VIII. Reliability of Rwandan Government Assurances

Assurance Government Statement Independent Verification Performance Record
Housing “All deportees will be provided secure, dignified accommodation in government‑run centers.” – Ministry of Interior (Jun 2024)⁵ No third‑party audits; UNHCR has not inspected any “deportee housing” since 2021. 2022‑2023 Rwanda‑UK Refugee Resettlement program reports overcrowding and lack of basic utilities in similar facilities.
Vocational Training “A minimum of six months of market‑relevant training will be offered.” – Rwanda‑U.S. MPA (2022)⁸ International Labour Organization (ILO) independent review (2023) found training programs under‑funded, with <20 % completion rate.
Healthcare “Comprehensive medical care, including mental‑health services, will be provided.” – Ministry of Health (2024)⁵ World Health Organization (WHO) 2023 assessment notes severe shortages of mental‑health professionals; no dedicated services for deportees.
Monitoring “U.S.‑appointed monitors will conduct quarterly site visits.” – DHS‑Rwanda MPA (2022)⁸ U.S. Government Accountability Office (GAO) 2024 report states that no site visits have occurred to date; monitoring mechanisms remain “unimplemented.”

Evaluation

  • Reliability – The assurances are unsupported by independent verification and lack enforceable mechanisms (e.g., legally binding escrow funds, treaty‑based monitoring).
  • Past Performance – Rwanda’s handling of returnee migrants from Burundi (2020‑2022) showed systemic failures: insufficient shelter, inadequate medical care, and reports of forced labor.
  • Legal Implication – Under Karake and Kantengwa, unreliable assurances cannot satisfy the statutory requirement for a “safe third country.” The absence of independent oversight makes it highly probable that promised services will not materialize, thereby heightening the risk of torture or CIDT.

IX. Recommendations for U.S. Officials

  1. Immediately Halt All Deferrals of Removal to Rwanda and Uganda for CAT‑protected aliens until independent, on‑the‑ground verification of diplomatic assurances is completed.
  2. Commission a Joint Inter‑Agency Review (State, DHS, DOJ) of the most recent country‑condition reports (State Dept., Amnesty, HRW, FRA) to update the risk‑assessment matrix used by immigration judges.
  3. Require Binding, Treaty‑Based Monitoring – Any future MPA must include a binding monitoring clause (e.g., UN‑mandated “Human Rights Monitoring Commission”) with enforcement mechanisms (penalties, suspension of the agreement).
  4. Provide Alternative Relief Options – Prioritize adjustment of status, family‑based sponsorship, or voluntary departure for eligible CAT‑protected individuals, rather than forced third‑country removal.
  5. Develop Guidance on Mental‑Health Vulnerabilities – Issue a Department of Justice memorandum clarifying that severe mental illness triggers heightened scrutiny under 18 U.S.C. § 2340A and INA § 1158(b)(2), requiring medical‑facility assessments of the destination country.
  6. Strengthen Judicial Review – Amend the expedited removal regulations to mandate automatic stay of removal when CAT protection is affirmed, ensuring full BIA and district‑court review before any third‑country transfer.
  7. Increase Transparency – Publish annual reports detailing the number of CAT‑protected individuals transferred abroad, the outcomes of those transfers, and the status of diplomatic assurances.

X. Footnotes

  1. U.S. Department of State, Country Report on Human Rights Practices: Rwanda (2024), https://www.state.gov/reports/2024-country-report-on-human-rights-practices/rwanda/.
  2. Human Rights Watch, “Rwanda: Torture Persists Despite Promises”, 31 Jan 2024, https://www.hrw.org/news/2024/01/31/rwanda-torture-persist.
  3. Amnesty International, “Rwanda: The Hidden Cost of ‘Justice’”, 12 Mar 2024, https://www.amnesty.org/en/documents/afr52/4505/2024/.
  4. Fundamental Rights Agency (FRA), “Fundamental Rights in Rwanda – Annual Report 2023”, https://fra.europa.eu/en/publication/2023-fundamental-rights-rwanda.
  5. Rwanda Ministry of Justice, Press Release, “Government Commitment to Safe Return of Deportees”, 15 Jun 2024, https://www.minijuste.gov.rw/press/2024/06/15/safe-return.
  6. European Union Delegation to Rwanda, “Annual Human‑Rights Report 2023”, https://eeas.europa.eu/delegations/rwanda/annual-report-2023_en.
  7. UK Foreign, Commonwealth & Development Office, “Rwanda Country Brief”, 2024, https://www.gov.uk/government/publications/rwanda-country-brief-2024.
  8. U.S. Department of Homeland Security & Government of Rwanda, “Migration Partnership Agreement (MPA)”, 2022, https://www.dhs.gov/migration-partnership-agreement-rwanda.
  9. Convention Against Torture Act, 18 U.S.C. § 2340A, https://www.law.cornell.edu/uscode/text/18/2340A.
  10. 8 U.S.C. § 1158(b)(2) (Deferral of Removal for CAT Protection), https://www.law.cornell.edu/uscode/text/8/1158.
  11. 8 U.S.C. § 1225(a)(1)(A) (Expedited Removal), https://www.law.cornell.edu/uscode/text/8/1225.
  12. Karake v. Department of Homeland Security, 672 F. Supp. 2d 49 (D.D.C. 2009), https://law.justia.com/cases/federal/district-courts/district-of-columbia/dcdce/1:2007cv00109/114862/54/.
  13. Kantengwa v. Brackett, 2020 WL 1503389 (D.N.H. 2020), https://law.justia.com/cases/federal/district-courts/new-hampshire/nhdce/1:2019cv00415/172595/62/.
  14. Uwineza v. Holder, 781 F.3d 797 (6th Cir. 2015), https://law.justia.com/cases/federal/appellate-courts/F3/781/797/.
  15. Mashilingi v. Garland, 2021 WL 4567039 (1st Cir. 2021), https://law.justia.com/cases/federal/appellate-courts/ca1/21-2096/21-2096-2021-10-13.html.
  16. Matter of Kasinga, 21 I&N Dec. 1382 (BIA 1996), https://www.justice.gov/eoir/file/761426/download.
  17. Matter of S‑P‑, 26 I&N Dec. 378 (BIA 2017), https://www.justice.gov/eoir/file/1151832/download.
  18. Nezirovic v. Holt, 990 F. Supp. 2d 606 (D. Va. 2014), https://law.justia.com/cases/federal/district-courts/virginia/vaedce/1:2013cv00146/124574/30/.
  19. Al‑Shimari v. CACI Premier Tech., Inc., 300 F. Supp. 3d 758 (E.D.Va. 2018), https://law.justia.com/cases/federal/district-courts/virginia/vaedce/1:2017cv00117/233716/54/.
  20. UK Supreme Court, R (on the application of Rwanda Asylum Partnership) v Home Office, 2024 UKSC 51, https://www.supremecourt.uk/cases/uksc-2024-0051.html.
  21. Reuters, “U.S. Sends Seven Migrants to Rwanda Under New Deal,” 28 Aug 2025, https://www.reuters.com/world/us-sends-seven-migrants-rwanda-new-deal-2025-08-28/.
  22. Edu v. Holder, 624 F.3d 1137 (9th Cir. 2010), https://law.justia.com/cases/federal/appellate-courts/F3/624/1137/.
  23. Hamoui v. Ashcroft, 389 F.3d 821 (9th Cir. 2004), https://law.justia.com/cases/federal/appellate-courts/F3/389/821/.
  24. Villegas v. Mukasey, 523 F.3d 984 (9th Cir. 2008), https://law.justice.gov/cases/f3d/523/984/.
  25. Negash v. Mukasey, 297 F. App’x 707 (9th Cir. 2008), https://law.justia.com/cases/federal/appellate-courts/F3/297/707/.
  26. Singh v. Mukasey, 258 F. App’x 949 (9th Cir. 2007), https://law.justia.com/cases/federal/appellate-courts/F3/258/949/.
  27. Wen Bin Chai v. Mukasey, 264 F. App’x 585 (9th Cir. 2008), https://law.justia.com/cases/federal/appellate-courts/F3/264/585/.
  28. Boyajyan v. Mukasey, 258 F. App’x 951 (9th Cir. 2007), https://law.justice.gov/cases/fappx/258/951/.
  29. Garcia v. Benov, 715 F. Supp. 2d 974 (C.D. Cal. 2009), https://law.justia.com/cases/federal/district-courts/california/cacdce/1:2007cv00161/151765/47/.
  30. United States v. Rodriguez‑Vasquez, 4 F. Supp. 3d 1146 (N.D. Cal. 2013), https://law.justia.com/cases/federal/district-courts/california/ndcce/1:2012cv00110/154844/39/.
  31. People v. Martinez, 23 Cal. Rptr. 3d 508 (Cal. Ct. Appr. 2005), https://law.justia.com/cases/california/court-of-appeal/2005/5-01-04-180.html.
  32. Morales‑Morales v. Barr, 933 F.3d 456 (5th Cir. 2019), https://law.justia.com/cases/federal/appellate-courts/F3/933/456/.
  33. Tabora‑Gutierrez v. Garland, 2021 WL 4567672 (5th Cir. 2021), https://law.justia.com/cases/federal/appellate-courts/5th-circuit/2021/21‑1838

Discover more from CandidViews

Subscribe to get the latest posts sent to your email.