Izuchukwu Ozurumba v. Pamela Bondi
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Vacated
The Fourth Circuit granted Nigerian petitioner Izuchukwu Ozurumba’s petition for review, holding that preparing thousands of meals for the leaders of the ‘Unknown Gunmen’ did not constitute “material support” under 8 U.S.C. § 1182(a)(3)(B)(iv)(VI). Because the Board of Immigration Appeals applied the material-support bar erroneously, the court vacated the removal order and remanded for further proceedings.
Circuit Split Identified
Legal Issue
Whether prior circuit precedents that relied on Chevron deference remain binding after the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo.
Circuit Positions
Pre-Loper Bright Chevron-based statutory holdings are no longer binding; courts may revisit the statutory meaning.
Chevron-based statutory holdings retain precedential force under statutory stare decisis and remain binding.
Question left open; no definitive position taken.
Conflict Summary
Post-Loper Bright, circuits disagree on the stare-decisis effect of earlier decisions that upheld agency interpretations under Chevron. The Sixth Circuit has held that such precedents are no longer binding beyond the particular agency action affirmed, while the Ninth Circuit treats the underlying statutory interpretations as still controlling. The Fourth Circuit in this opinion acknowledges the disagreement and expressly leaves the question open for a future case.