Case Explained: SAMUELS, ET AL. V. UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-26 Docket: 2:24-cv-00176-SVW-PD The Ninth Circuit affirmed the district court’s grant of summary judgment in favor of USCIS, upholding the agency’s denial of an immigrant visa petition under 8 U.S.C. § 1154(c) due to a finding of marriage fraud. The court held that the administrative record contained substantial evidence supporting the determination that Trarat Samuels’ prior marriage to Sattsawat Chuakrung was fraudulent, noting that circumstantial evidence and inconsistencies in testimony regarding cohabitation, financial arrangements, and undisclosed relationships were sufficient to meet the “substantial and probative evidence” standard required to establish fraud. The court further ruled that USCIS properly applied the burden-shifting framework by considering the plaintiffs’ rebuttal evidence—including affidavits, joint account statements, and photographs—and correctly concluding that this evidence failed to overcome the initial finding of fraud, particularly because the affidavits lacked objective corroboration and the photographs did not clearly establish a bona fide marital relationship. As a result, the denial of the I-130 petition stands, and the plaintiffs’ related argument regarding the reopening of their I-485 Adjustment of Status application is not addressed as it is moot given the upheld denial of the underlying petition. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.