Case Explained: MD FARID UDDIN v. TODD BLANCHE, Acting Attorney General

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-05 The Fourth Circuit denied the petition for review in part and dismissed it in part. The court held that Md Farid Uddin’s conviction under New Jersey law categorically qualifies as a “crime of child abuse” under the Immigration and Nationality Act, rendering him removable. Applying the categorical approach de novo, the court determined that the relevant version of the statute is the one in effect at the time of the criminal conduct (2017), not later amendments. The court found that the minimum conduct criminalized by the 2017 statute—knowingly storing or maintaining child sexual abuse material on a file-sharing program designated as available for searching or copying by other computers—creates a reasonable probability of harm to a child. This is because such storage facilitates the circulation of the materials, which inflicts ongoing trauma on the depicted children, satisfying the statutory elements of a crime of child abuse. The court further held that it lacks jurisdiction to review the Board of Immigration Appeals’ discretionary denial of Uddin’s applications for cancellation of removal and adjustment of status. Under 8 U.S.C. § 1252(a)(2)(B)(i), judicial review is barred for decisions involving the exercise of discretion, including factual determinations regarding the weight assigned to favorable and unfavorable equities. The court concluded that Uddin’s challenges to these denials sought to recast discretionary merits determinations as legal errors, which falls outside the scope of permissible review under 8 U.S.C. § 1252(a)(2)(D). As a practical consequence, the immigration judge’s removal order stands, and Uddin remains subject to deportation proceedings without relief from cancellation of removal or adjustment of status. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.