Judge Sarjo Barrow

FY 2020 - 2025*, Indianapolis Immigration Court

*data covers the first 11 months of fiscal year 2025

Published Nov 7, 2025

Sarjo Barrow was appointed as an immigration judge to begin hearing cases in May 2024. Judge Barrow earned a Bachelor of Science in 2010 from John Jay College of Criminal Justice, The City University of New York, and a Juris Doctor in 2013 from Thomas M. Cooley Law School. From 2019 to 2024, he served as an assistant chief counsel with the Office of the Principal Legal Advisor, U.S. Immigration and Customs Enforcement, Department of Homeland Security, in Baltimore from 2023 to 2024 and in San Francisco from 2019 to 2023. From 2013 to 2019, he was an attorney in private practice in Madison, Wisconsin, including two years as an immigration attorney. Judge Barrow is a member of the State Bar of Wisconsin.

Deciding Asylum Cases

Detailed data on decisions by Judge Barrow were examined for the period covering fiscal years 2020 through the first 11 months of 2025. During this period, court records show that Judge Barrow decided 260 asylum claims on their merits. Of these, he granted asylum for 65, granted 1 other types of relief, and denied relief to 194. Converted to percentage terms, Barrow denied 74.6 percent and granted 25.4 percent of asylum cases (including forms of relief other than asylum).

Figure 1 provides a comparison of Judge Barrow'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 Barrow's denial rate of 74.6 percent, Immigration Court judges across the country denied 58.9 percent of asylum claims during this same period. Judges at the Indianapolis Immigration Court where Judge Barrow decided these cases denied asylum 77.3 percent of the time. See Figure 2.

Judge Barrow'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 Barrow, 10% 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 Barrow came from Venezuela. Individuals from this country made up 19.2% of his caseload. Other nationalities in descending order of frequency appearing before Judge Barrow were: Guatemala (16.9%), Nicaragua (14.2%), El Salvador (9.6%), Honduras (9.6%). 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%).