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United States v. Manuel Zumba Mejia - Illegal Reentry

The Second Circuit reversed the SDNY's dismissal of illegal reentry charges against Manuel Zumba Mejia, holding that Mejia could not collateral challenge his underlying removal order because he failed to satisfy 8 U.S.C. § 1326(d)'s mandatory exhaustion requirements. The court ruled that Palomar-Santiago (2021) abrogates the prior Sosa framework, and no court may excuse a failure to exhaust administrative remedies under § 1326(d). The case is remanded for further proceedings.