U.S. Court of Appeals for the Tenth Circuit

Satnam v. Blanche

September 1, 2026

Summary

The court dismissed the petition for lack of subject-matter jurisdiction because the Board of Immigration Appeals had not issued a final order of removal. It held that neither APA final-agency-action principles nor the INA provision concerning constitutional claims and questions of law independently supplied jurisdiction absent a final removal order. The court noted that a habeas petition in federal district court may provide a separate avenue to challenge detention.