ARSEN SARKISOV v. PAMELA BONDI, Attorney General - Articles

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ARSEN SARKISOV v. PAMELA BONDI, Attorney General

Posted by: Azya Thornton on Nov 21, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Anna Darbinian, ASHERSON, KLEIN & DARBINIAN, Beverly Hills, California, for Petitioner.

Attorneys 2: ON BRIEF: Alexander J. Lutz, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Respondent.

Judge(s): MOORE, BUSH, and DAVIS, Circuit Judges

Court Appealed: On Petition for Review from the Board of Immigration Appeals

KAREN NELSON MOORE, Circuit Judge. Arsen Sarkisov is a citizen of Russia who has lived in the United States for at least two decades without legal status. Since 2013, he has been subject to a final order of removal. Several years ago, Sarkisov filed a self-petition under the Violence Against Women Act (“VAWA”) alleging that his former U.S.-citizen spouse subjected him to physical and emotional abuse. After the petition was granted, Sarkisov moved to reopen his immigration proceedings under a special rule for VAWA petitioners. To satisfy the rule, the VAWA petitioner must demonstrate “extraordinary circumstances or extreme hardship to the alien’s child.” The Attorney General, through her designee the Board of Immigration Appeals (“BIA”), concluded that Sarkisov did not meet that standard. Sarkisov petitioned for review. As a matter of first impression, we conclude that we have jurisdiction to review the BIA’s determination that Sarkisov did not demonstrate extraordinary circumstances. But because the BIA’s determination was not erroneous, we DENY the petition for review.

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