Alyse Sanchez v. Markwayne Mullin

Circuit 4Aug 14, 2026

Split Score

SplitScore: 55/100

Case Summary

Disposition

Vacated

In this immigration-class action, the Fourth Circuit held that non-citizens’ suit challenging DHS’s authority to remove them while they pursue provisional unlawful-presence waivers is not barred by 8 U.S.C. § 1252(g), but the court rejected the district court’s merits ruling that the regulations categorically protect applicants from removal. Concluding the record was insufficient to prove the government used the waiver program to target arrests, the panel vacated the summary judgment for plaintiffs and remanded for further proceedings.

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Whether 8 U.S.C. § 1252(g) strips federal courts of jurisdiction over suits by non-citizens who challenge the government’s legal authority to execute removal orders while they are pursuing provisional unlawful-presence waivers under 8 C.F.R. § 212.7(e).

Circuit Positions

Circuit 4(this circuit)

§ 1252(g) is narrow and does not bar review of claims asserting DHS lacks legal authority (as opposed to discretion) to execute a removal order while a provisional-waiver application is pending.

Circuit 3Circuit 11

§ 1252(g) bars review of challenges to the execution of removal orders even where the alien alleges DHS currently lacks legal authority because a provisional-waiver process is underway.

Conflict Summary

The circuits disagree on the scope of § 1252(g). The Fourth Circuit holds that § 1252(g) bars only challenges to discretionary enforcement decisions and therefore does not preclude review of claims alleging the Executive entirely lacks legal authority to remove an alien at a particular time. The Third and Eleventh Circuits interpret § 1252(g) more broadly to bar review of any challenge to the timing of removal, even when the alien claims the agency has no legal authority to act while a provisional-waiver process is pending.

Parties & Counsel

Parties

Appellant:Markwayne Mullin, Secretary of Homeland Security, et al.
Appellee:Alyse Sanchez, et al.

Legal Counsel

Appellant:Mary Lynn Larakers, U.S. Department of Justice, Civil Division, Office of Immigration Litigation
Appellee:Michael Abrams, ACLU of Maryland