Celia Castillo v. Eric H. Holder Jr.

MEMORANDUM *

The Board of Immigration Appeals dismissed Celia Castillo’s appeal on the ground that she, as a derivative of her mother’s applications for asylum and withholding of removal, lacked “standing to appeal the [Immigration Judge’s] denial of [those] applications.” Although it is clear that the BIA believed it was deprived of “jurisdiction to consider [Castillo’s] challenges,” the source of this purported jurisdictional limitation is unclear.

Did the BIA believe that it was limited by the strictures of Article III of the United States Constitution? Was the BIA interpreting a statute or…