Mestanek v. Jaddou, No. 22-2285 (4th Cir. 2024)
Annotate this CaseThe case involves Robert Mestanek, a citizen of the Czech Republic, who filed two Form I-130 petitions to establish his eligibility for lawful permanent residence in the United States based on his marriages to two different U.S. citizens. The first petition was filed by his then-wife Angel Simmons, and the second by his current wife Mary Mestanek. The United States Citizenship and Immigration Services (USCIS) denied both petitions, the first on the grounds that Robert’s marriage to Angel was fraudulent, and the second based on the “marriage fraud bar” which prohibits approval of Form I-130 petitions for any noncitizen who has previously been found to have entered into a fraudulent marriage to circumvent immigration laws. The Mestaneks filed suit in federal district court seeking judicial review of USCIS’s denial of Mary’s Form I-130 petition. The district court granted summary judgment in favor of USCIS, and the Mestaneks appealed. The United States Court of Appeals for the Fourth Circuit affirmed the lower court's decision, agreeing that USCIS’s denial was neither arbitrary nor contrary to law. The court rejected all of the Mestaneks’ arguments, including their contention that USCIS applied the wrong legal standard for marriage fraud, and their assertion that the administrative record was incomplete and insufficient for judicial review. The court also found no due process violation by USCIS.
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