Judge John B. Carle

FY 2018 - 2023, Philadelphia Immigration Court

Published Oct 19, 2023

Attorney General Loretta E. Lynch appointed John B. Carle to begin hearing cases in June 2016. Judge Carle earned a Bachelor of Arts degree in 1990 from the State University of New York at Binghamton and a Juris Doctor in 1993 from the State University of New York at Buffalo Law School. From 2007 to May 2016, Judge Carle served as an assistant chief counsel for the Office of the Chief Counsel, Immigration and Customs Enforcement, Department of Homeland Security. From 2000 through 2007, Judge Carle served as an assistant district attorney for the City of Philadelphia District Attorney’s Office. From 1995 through 2000, Judge Carle served as an assistant district attorney for the Erie County District Attorney’s Office, in Buffalo, N.Y. From 1993 through 1995, Judge Carle served as an associate attorney for Magner, Love & Morris PC, in Buffalo, N.Y. In 2013, Judge Carle joined the faculty of the Villanova University School of Law where he serves as an adjunct professor. Judge Carle is a member of the Pennsylvania Bar.

Deciding Asylum Cases

Detailed data on decisions by Judge Carle were examined for the period covering fiscal years 2018 through 2023. During this period, court records show that Judge Carle decided 885 asylum claims on their merits. Of these, he granted asylum for 374, granted 12 other types of relief, and denied relief to 499. Converted to percentage terms, Carle denied 56.4 percent and granted 43.7 percent of asylum cases (including forms of relief other than asylum).

Figure 1 provides a comparison of Judge Carle's denial rate each fiscal year over this recent period. (Rates for years with less than 25 decisions are not shown.)

Nationwide Comparisons

Compared to Judge Carle's denial rate of 56.4 percent, Immigration Court judges across the country denied 60.6 percent of asylum claims during this same period. Judges at the Philadelphia Immigration Court where Judge Carle decided these cases denied asylum 54.7 percent of the time. See Figure 2.

Judge Carle's asylum grant and denial rates are compared with other judges serving on the same court in this table. Note that when an Immigration Judge serves on more than one court during the same period, separate Immigration Judge reports are created for any Court in which the judge rendered at least 100 asylum decisions.

Why Do Denial Rates Vary Among Judges?

Although denial rates are shaped by each Judge's judicial philosophy, denial rates are also shaped by other factors, such as the types of cases on the Judge's docket, the detained status of immigrant respondents, current immigration policies, and other factors beyond an individual Judge's control. For example, TRAC has previously found that legal representation and the nationality of the asylum seeker are just two factors that appear to impact asylum decision outcomes.

The composition of cases may differ significantly between Immigration Courts in the country. Within a single Court when cases are randomly assigned to judges sitting on that Court, each Judge should have roughly a similar composition of cases given a sufficient number of asylum cases. Then variations in asylum decisions among Judges on the same Immigration Court would appear to reflect, at least in part, the judicial philosophy that the Judge brings to the bench. However, if judges within a Court are assigned to specialized dockets or hearing locations, then case compositions are likely to continue to differ and can contribute to differences in asylum denial rates.

Representation

When asylum seekers are not represented by an attorney, almost all of them (80%) are denied asylum. In contrast, a significantly higher proportion of represented asylum seekers are successful. In the case of Judge Carle, 5.8% were not represented by an attorney. See Figure 3. For the nation as a whole, about 15.7% of asylum seekers are not represented.

Nationality

Asylum seekers are a diverse group. Over one hundred different nationalities had at least one hundred individuals claiming asylum decided during this period. As might be expected, immigration courts located in different parts of the country tend to have proportionately larger shares from some countries than from others. And, given the required legal grounds for a successful asylum claim, asylum seekers from some nations tend to be more successful than others.

The largest group of asylum seekers appearing before Judge Carle came from Guatemala. Individuals from this country made up 24.2% of his caseload. Other nationalities in descending order of frequency appearing before Judge Carle were: Honduras (18.0%), El Salvador (10.7%), Mexico (8.2%), Brazil (6.3%). See Figure 4.

In the nation as a whole during this same period, major nationalities of asylum seekers, in descending order of frequency, were El Salvador (16.6%), Guatemala (15.1%), Honduras (13.8%), Mexico (9.2%), China (6.8%), India (5.1%), Venezuela (3.2%), Ecuador (3.1%), Cuba (2.4%), Nicaragua (2.3%), Brazil (2.0%), Colombia (1.4%), Cameroon (1.4%).