Judge Heather Libeu

FY 2020 - 2025*, Santa Ana Immigration Court

*data covers the first 11 months of fiscal year 2025

Published Nov 7, 2025

Heather A. Libeu was appointed as an immigration judge to begin hearing cases in August 2023. Judge Libeu earned a Bachelor of Arts in 2004 from Chapman University and a Juris Doctor in 2007 from the University of Southern California Gould School of Law. From 2021 to 2023, she served an assistant chief counsel, Office of the Principal Legal Advisor (OPLA), U.S. Immigration and Customs Enforcement (ICE), Department of Homeland Security (DHS), in Santa Ana, California. From 2010 to 2021, she served an assistant chief counsel, OPLA, in Los Angeles. From 2009 to 2010, she served as an associate legal advisor, and from 2007 to 2009, she served as Presidential management fellow, OPLA, in Washington, D.C. Judge Libeu is a member of the State Bar of California.

Deciding Asylum Cases

Detailed data on decisions by Judge Libeu were examined for the period covering fiscal years 2020 through the first 11 months of 2025. During this period, court records show that Judge Libeu decided 276 asylum claims on their merits. Of these, she granted asylum for 52, granted 0 other types of relief, and denied relief to 224. Converted to percentage terms, Libeu denied 81.2 percent and granted 18.8 percent of asylum cases (including forms of relief other than asylum).

Figure 1 provides a comparison of Judge Libeu'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 Libeu's denial rate of 81.2 percent, Immigration Court judges across the country denied 58.9 percent of asylum claims during this same period. Judges at the Santa Ana Immigration Court where Judge Libeu decided these cases denied asylum 67.1 percent of the time. See Figure 2.

Judge Libeu'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 (77%) are denied asylum. In contrast, a significantly higher proportion of represented asylum seekers are successful. In the case of Judge Libeu, 14.5% were not represented by an attorney. See Figure 3. For the nation as a whole, about 17.1% 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 Libeu came from Nicaragua. Individuals from this country made up 15.6% of her caseload. Other nationalities in descending order of frequency appearing before Judge Libeu were: Colombia (13.4%), Mexico (11.6%), China (11.2%), Guatemala (9.1%). See Figure 4.

In the nation as a whole during this same period, major nationalities of asylum seekers, in descending order of frequency, were Honduras (11.2%), Guatemala (11.2%), El Salvador (10.9%), Mexico (8.2%), China (5.2%), Venezuela (5.2%), India (5.1%), Ecuador (4.5%), Nicaragua (4.4%), Colombia (4.4%), Brazil (3.1%), Russia (3.1%), Cuba (2.8%).