
    R.L. INVESTMENT LIMITED PARTNERS, Plaintiff-Appellant, and Wanxuan Zou, Plaintiff, v. IMMIGRATION AND NATURALIZATION SERVICE, Defendant-Appellee.
    No. 00-15627.
    United States Court of Appeals, Ninth Circuit.
    Argued and Submitted Nov. 6, 2001
    Filed Nov. 20, 2001
    Ira J. Kurzban, Kurzban Kurzban Weinger & Tetzeli, P.A., Miami, Florida, and Marc Van Der Hout, Van Der Hout & Brigagliano, San Francisco, California, for the plaintiff-appellant.
    John C. Cunningham, Senior Litigation Counsel, Department of Justice, Office of Immigration Litigation, Civil Division, Washington, D.C., for the defendant-appel-lee.
    Before: FERNANDEZ, RYMER, and WARD LAW, Circuit Judges.
   RYMER, Circuit Judge:

We agree with and adopt the well reasoned opinion of the district court. R.L. Inv. Ltd. Partners v. INS, 86 F.Supp.2d 1014 (D.Haw.2000).

R.L. Investment Limited Partners argues for the first time on appeal that the INS’s new rules were impermissibly retroactive, that the Administrative Appeals Office’s (AAO) addition of new grounds for affirming the regional director’s denial of Wanxuan Zou’s petition violates the due process clause, and that the AAO is not an independent adjudicatory body entitled to render rules in an adjudicatory proceeding. However, we decline to consider these arguments because they were not raised in the district court. See Bolker v. Comm’r of Internal Revenue, 760 F.2d 1039, 1042 (9th Cir.1985).

AFFIRMED.  