Debeatham v. Holder

Petitioner Andrew Debeatham (“petitioner” or “Debeatham”), a native and citizen of Jamaica, seeks review of a December 15, 2008 decision of the Board of Immigration Appeals (“BIA”) denying his motion to reopen his removal proceedings. Petitioner argues, as he did before the BIA, that he is entitled to reopening based on the ineffective assistance of his prior counsel. We hold that petitioner failed to comply with the requirements of In re Lozada, 19 I. & N. Dec. 637, 639 (B.I.A.1988), in asserting one of counsel’s alleged errors and failed to show prejudice arising from the remaining alleged…