Barsoum v. Attorney General of America

Maged G. Barsoum, an Egyptian citizen, entered the U.S. in 1989 and was ordered deported in 1994 after his asylum claim was denied. He subsequently married a U.S. citizen, but in 2001 he was indicted for participating in a scheme to sell counterfeit tax stamps to fund an Egyptian terrorist organization. He pleaded guilty to one count and served a prison sentence. After his release, the government reinstated his removal order. Barsoum applied for withholding of removal and protection under the Convention Against Torture, arguing he would face persecution in Egypt. An immigration judge denied his applications, finding his conviction constituted a particularly serious crime and a terrorism-related offense, and the Board of Immigration Appeals affirmed. Barsoum petitioned the Third Circuit for review, which issued its opinion on December 7, 2018.

The United States Court of Appeals for the Third Circuit denied the petition for review, holding that substantial evidence supported the immigration judge's findings and that the Board of Immigration Appeals correctly affirmed the order of removal.

Whether the immigration judge properly classified Barsoum's prior conviction as a particularly serious crime and a terrorist activity, thereby barring withholding of removal, and whether Barsoum demonstrated a clear probability of future persecution or torture if returned to Egypt.

The case reinforced the strict statutory bars to relief for noncitizens convicted of crimes involving terrorism or national security, underscoring the government's broad authority to deport individuals whose past activities raise security concerns even when the underlying convictions are not recent.