Ninth Circuit: Elton Mendoza Rizo v. Loretta E. Lynch

Immigration / Administrative

Remand to IJ doesn't make case insufficiently final for review, as IJ's remit is to provide for the possibility of voluntary departure.

Petitioner insufficiently developed claims against denial of asylum -- insufficient exhaustion.

No constitutional harm in aggressive questioning by IJ.

https://d3bsvxk93brmko.cloudfront.net/datastore/opinions/2016/01/14/13-74216.pdf