Samuel Jason Roberts v. U.S. Attorney General, 23-11960

Samuel Jason Roberts, a native of Guyana, entered the U.S. in 2002 on a tourist visa and overstayed.
Roberts was convicted in 2013 in Florida for insurance fraud, making him removable.
He applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), citing political persecution and threats due to his father's role in a high-profile government assassination case.
The immigration judge found him removable, rejected his claims (asylum application pretermitted for late filing, insufficient grounds for withholding/CAT), and determined he did not meet exceptions to deadlines or definitions required.
Roberts appealed to the BIA, arguing errors in the IJ’s consideration of evidence and a failure to allow voluntary departure. The BIA affirmed the IJ, and Roberts petitioned for review in the Eleventh Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether BIA gave reasoned consideration to the record	BIA failed to consider all relevant evidence for his claims	BIA made sufficient findings and reasoned decision	BIA provided adequate reasoned consideration
Whether BIA erred in denying remand for voluntary departure	Should have been allowed to apply for voluntary departure post-decision	Did not request voluntary departure timely before IJ proceedings end	No abuse of discretion in denying remand for voluntary departure

Ali v. U.S. Att’y Gen., 931 F.3d 1327 (11th Cir. 2019) (sets standard for "reasoned consideration" by BIA)
Ayala v. U.S. Att’y Gen., 605 F.3d 941 (11th Cir. 2010) (affirms review based on substantial, probative evidence)
Dos Santos v. United States Att’y Gen., 982 F.3d 1315 (11th Cir. 2020) (motion to remand based on new evidence treated as motion to reopen)
Jeune v. U.S. Att’y Gen., 810 F.3d 792 (11th Cir. 2016) (standard for examining BIA's reasoned consideration)
Carrizo v. U.S. Att’y Gen., 652 F.3d 1326 (11th Cir. 2011) (BIA need not address every piece of evidence)