White House, Sept. 30, 2024 "MEMORANDUM FOR THE SECRETARY OF STATE SUBJECT: Presidential Determination on Refugee Admissions for Fiscal Year 2025 By the authority vested in me as President by the...
BIB Daily presents bimonthly PERM practice tips from Ron Wada , member of the Editorial Board for Bender’s Immigration Bulletin and author of the 10+ year series of BALCA review articles, “Shaping...
Texas v. Mayorkas "In September 2022, after a notice-and-comment period, the Biden administration promulgated a new Rule redefining the term ["public charge"]. In response, the State of...
White House, Sept. 30, 2024 "...I have now concluded that in order to better achieve Proclamation 10773’s goal of enhancing our ability to address historic levels of migration and more efficiently...
This document is scheduled to be published in the Federal Register on 10/01/2024 "This public notice provides information on how to apply for the DV-2026 Program and is issued pursuant to the Immigration...
Juan Antonio v. Barr
"Maria Magdalena Juan Antonio, a native and citizen of Guatemala, appeals from the Board of Immigration Appeals’ (the “Board”) denial of her application for asylum and withholding of removal. In its denial, the Board found that Maria articulated a cognizable particular social group and that the harm she suffered rose to the level of past persecution. It then concluded, however, that the government effectively rebutted her well-founded fear of future persecution by showing changed circumstances: that she was no longer part of her articulated social group and that she could reasonably relocate within Guatemala. On appeal, Maria argues that the Board’s conclusion was not supported by substantial evidence on the record as a whole. We agree with Maria. Therefore, we grant the petition for review, vacate the Board’s decision, and remand for reconsideration consistent with this opinion. ... Matter of A-B- has since been abrogated. See Grace v. Whitaker, 344 F. Supp. 3d 96 (D.D.C. 2018). Grace found that the policies articulated in Matter of A-B- were arbitrary, capricious, and contrary to law. See id. at 126–27 (holding that there is no general rule against claims involving domestic violence as a basis for membership in a particular social group and that each claim must be evaluated on an individual basis under the statutory factors). The district court’s decision in Grace is currently on appeal to the D.C. Circuit. We acknowledge that we are not bound by Grace but find its reasoning persuasive. Because Matter of A-B- has been abrogated, Matter of A-R-C-G- likely retains precedential value. But, on remand, the agency should also evaluate what effect, if any, Matter of A-R-C-G- and Grace have had on the particular social group analysis."
[Hats way off to Margaret W. Wong!]