Passim

Litigation research in Claude or ChatGPT

These pages say where each policy stands. With the Passim connector, the AI you already use can read the rulings and the circuit decisions behind them, tell you which ones bind where your case is, and link every source.

What your AI can do with Passim

  • Find the law that binds in your circuit. Published circuit decisions and Supreme Court authority, with the passage behind each point.
  • Check how a decision has been treated. ImmCite shows what later decisions did to it, and flags rehearing and certiorari petitions the litigation tracker records.
  • Get changes by email. Subscribers can follow any issue here and get an email when it changes.
  • Use the rest of the library. The INA, the regulations, the USCIS Policy Manual and the FAM, and unpublished BIA and AAO decisions.

A real answer

Asked of Claude with the Passim connector on November 13, 2026. The answer is shortened, and its links open the courts' own copies of the opinions.

I have a bond case in the Eighth Circuit for someone who entered without inspection years ago. Which decisions bind there on detention without bond under section 1225(b)(2)(A), and what is pending above them?

In the Eighth Circuit, Herrera Avila v. Bondi, 170 F.4th 1128 (8th Cir. Mar. 25, 2026), binds. A divided panel held that section 1225(b)(2)(A) requires detention without bond for people who entered without inspection and are later found in the interior, joining the Fifth Circuit's Buenrostro-Mendez v. Bondi, 166 F.4th 494 (5th Cir. 2026). Passim's citator marks Avila "caution" because other circuits disagree, and notes that it still binds in the Eighth Circuit.

Nine circuits have held the other way: the First, Second, Third, Fourth, Sixth, Seventh, Ninth, Tenth and Eleventh. On October 1, 2026 the Supreme Court granted review of the Second Circuit's decision, Cunha v. Freden, 175 F.4th 61, as Rhoney v. Barbosa da Cunha, No. 26-104. Certiorari petitions from the Fifth, Sixth, Seventh and Ninth Circuit cases are also pending.

Until the Supreme Court decides No. 26-104, Avila controls in the Eighth Circuit. Read the opinions, and check the issue page for anything newer, before relying on this.

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