Clark Hill Wins Precedential OCAHO Dismissal, Shaping the Limits of Federal Immigration Enforcement
Clark Hill’s Immigration team, led by Thomas K. Ragland and Ana Sami, secured a decisive victory for Adibahon Jurayeva in a precedential decision issued by the Office of the Chief Administrative Hearing Officer (OCAHO), resulting in the dismissal with prejudice of the government’s enforcement action.
In United States v. Jurayeva, 22 OCAHO No. 1684a (2026), the Department of Homeland Security alleged that the respondent violated federal immigration law by submitting a naturalization application in 2018 with knowledge or reckless disregard of its alleged falsity. Clark Hill moved to dismiss the complaint on statute‑of‑limitations grounds—an argument the Administrative Law Judge squarely adopted.
Ragland and Sami advanced the argument that the government’s enforcement action was barred by the statute of limitations because the alleged misconduct constituted a discrete, non‑continuing act that accrued at the time the naturalization application was filed, and because an enforcement “action” under 28 U.S.C. § 2462 is commenced only when a complaint is filed with OCAHO. The Administrative Law Judge expressly agreed with this position, rejecting the government’s continuing‑violation and delayed‑accrual theories, and holding that issuance of a Notice of Intent to Fine does not toll the statute of limitations. As a result, the court dismissed the complaint with prejudice.
The decision followed amicus briefing that was invited by the Administrative Law Judge and provides authoritative guidance on when immigration‑related document fraud claims accrue and when enforcement actions must be initiated. The ruling significantly constrains delayed federal enforcement efforts and reinforces core statute‑of‑limitations principles in immigration proceedings.
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