Published Oct 19, 2023
Attorney General William Barr appointed Michelle C. Araneta to begin hearing cases in May2019. Judge Araneta earned a Bachelor of Science in 1975 from Arizona State University, aMaster of Special Education in 1984 from the University of Arizona, and a Juris Doctor in 1989from California Western School of Law in San Diego. From 2000 to 2019, she served as aprosecutor with the Pima County Attorney’s Office in Tucson, Arizona. From 1995 to 1999, sheserved as a prosecutor with the District Attorney’s Office in Riverside, California. From 1991 to1995, she was an associate attorney practicing tax and bankruptcy in Orange County, California.From 1989 to 1991, she worked as a law clerk for the Honorable David N. Naugle. JudgeAraneta is a member of the Arizona State Bar and California Bar.
Detailed data on decisions by Judge Araneta were examined for the period covering fiscal years 2018 through 2023. During this period, court records show that Judge Araneta decided 307 asylum claims on their merits. Of these, she granted asylum for 36, granted 0 other types of relief, and denied relief to 271. Converted to percentage terms, Araneta denied 88.3 percent and granted 11.7 percent of asylum cases (including forms of relief other than asylum).
Figure 1 provides a comparison of Judge Araneta's denial rate each fiscal year over this recent period. (Rates for years with less than 25 decisions are not shown.)
Compared to Judge Araneta's denial rate of 88.3 percent, Immigration Court judges across the country denied 60.6 percent of asylum claims during this same period. Judges at the Miami Immigration Court where Judge Araneta decided these cases denied asylum 85.3 percent of the time. See Figure 2.
Judge Araneta'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.
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.
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 Araneta, 10.7% were not represented by an attorney. See Figure 3. For the nation as a whole, about 15.7% of asylum seekers are not represented.
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 Araneta came from Guatemala. Individuals from this country made up 40.7% of her caseload. Other nationalities in descending order of frequency appearing before Judge Araneta were: Honduras (23.1%), Haiti (15.0%), El Salvador (6.8%), Nicaragua (3.3%). 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%).