The First Circuit Court of Appeals recently ruled against Rasha Alawieh, a Lebanese citizen, in her appeal concerning her expedited removal from the United States. The court upheld a lower court's decision that dismissed her habeas petition, which challenged the legality of her removal order. This ruling has significant implications for individuals facing similar immigration issues.
Rasha Alawieh, who had been working in the U.S. under an H-1B visa, was removed from the country after a customs inspection at Boston Logan Airport. The court's decision affects not only Alawieh but also sets a precedent for how expedited removal cases are handled under U.S. immigration law.
Background
Rasha Alawieh initially entered the United States in 2018 on an exchange visitor visa after completing her medical degree in Lebanon. She later obtained an H-1B visa, which allowed her to work as a transplant nephrologist at Brown University Health. In February 2025, Alawieh traveled to Lebanon to visit family. Upon her return to the U.S. in March 2025, she was detained by Customs and Border Protection (CBP) officers at Logan Airport.
During her inspection, CBP officers found photos and videos on Alawieh's phone related to Hezbollah, a group designated as a terrorist organization by the U.S. government. Alawieh admitted to deleting some of these photos prior to her arrival, stating she did not want to create a negative perception. Following the inspection, CBP officers issued her an order of expedited removal, which also revoked her H-1B visa, leading to a five-year bar on her reentry into the U.S.
Alawieh filed a habeas petition in the district court, seeking to challenge the expedited removal order and the revocation of her visa. However, the district court dismissed her petition, stating it lacked jurisdiction due to provisions in the Immigration and Nationality Act (INA) that restrict judicial review of expedited removal orders.
The Ruling
The First Circuit Court of Appeals, consisting of Judges GelpÃ, Lynch, and Dunlap, affirmed the district court's dismissal of Alawieh's habeas petition. The court ruled that it lacked jurisdiction to review her claims, citing the INA's provisions that limit judicial review of expedited removal orders. The court stated, "We lack jurisdiction to review her claims" and emphasized that Alawieh did not fit within the statutory exceptions that would allow for judicial review.
The court's opinion highlighted that the INA restricts judicial review to specific issues, such as whether the petitioner is an alien or whether an order of removal was issued. The court found that Alawieh's claims did not challenge the issuance of the removal order itself but rather its validity, which falls outside the scope of judicial review as defined by the INA.
Impact
This ruling has significant implications for individuals facing expedited removal orders. It reinforces the limitations placed on judicial review in immigration cases, particularly those involving expedited removal. The court's decision indicates that many claims challenging the validity of removal orders may not be heard in court, leaving individuals with limited options for recourse.
Alawieh's case also highlights the complexities of immigration law and the challenges faced by individuals who may be detained and removed without the opportunity for a full hearing. The ruling could affect future cases involving expedited removal, as it sets a precedent for how courts interpret the jurisdictional limitations imposed by the INA.
What's Next
While Alawieh's appeal has been dismissed, she may still have options for seeking relief, although details were not available in the court filing. The ruling can potentially be appealed to the Supreme Court, but it remains to be seen whether her legal team will pursue that route. Additionally, there may be related cases pending that could further clarify the legal landscape surrounding expedited removal and judicial review in immigration matters.