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СпутникиРНSpaceXРоскосмосNASANinth Circuit Rules on Due Diligence Standard for Equitable Tolling For Motions to Reopen
Crimes
Post-Conviction Relief
Removal Defense
ddelacruz
Tue, 07/14/2026 - 13:32
Publication Date
Jul 14, 2026
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The Ninth Circuit issued a decision in Eskilian v. Bondi, 172 F.4th 682 (9th Cir. 2026) on April 2, 2026. This case can guide advocates on demonstrating due diligence for equitable tolling for an otherwise time- or number-barred Motion to Reopen. This analysis could be particularly helpful for clients from countries that previously did not accept individuals deported from the U.S., such as Laos, Cambodia, and Vietnam, as well as those from former Soviet countries.
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July 2026 9th Circuit Due Diligence Equitable Tolling final.pdf
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The Ninth Circuit issued a decision in Eskilian v. Bondi, 172 F.4th 682 (9th Cir. 2026) on April 2, 2026. This case can guide advocates on demonstrating due diligence for equitable tolling for an otherwise time- or number-barred Motion to Reopen. This analysis could be particularly helpful for clients from countries that previously did not accept individuals deported from the U.S., such as Laos, Cambodia, and Vietnam, as well as those from former Soviet countries.