The Legal Aid Society filed a coalitional amicus brief in support of both parties’ petitions for a rehearing en banc in the Fourth Circuit to explain the impact of the Bhaktibhai-Patel v. Garland ruling for practitioners in the Second Circuit. The adoption of the Bhaktibhai-Patel rule has led to applicants filing premature petitions for review before the issues on appeal are ripe, and while those issues still may be withdrawn or transferred. It also has created significant additional work for the parties and may deprive individuals particularly pro se litigants – of meaningful judicial review.