Judge Jon Tigar of the U.S. District Court for the Northern District of California vacated the “Circumvention of Lawful Pathways” rule, finding that the rule violated the Administrative Procedures Act because it was both contrary to law and arbitrary and capricious. Specifically, the court concluded that the rule was contrary to law because it presumed ineligible for asylum noncitizens who entered between ports of entry, using a manner of entry that Congress expressly intended should not affect access to asylum, as well as presumed ineligible noncitizens who failed to apply for protection in a transit country, regardless of whether that country was a safe option.