Valarezo-Tirado petitioned the Third Circuit to review an Immigration Judge’s reinstatement of his order of removal. The Third Circuit vacated the IJ’s decision, ruling that review was impossible because the IJ did not adequately explain the reasons for her decision. The Third Circuit also ruled that Valarezo-Tirado could not show that he was denied the right to counsel. He declined an offer to stop an interview so that he could retain counsel.