BIA on Sec. 216 Hardship Clock: Matter of Munroe

Official Headnote: For purposes of establishing an alien’s eligibility for a waiver under section 216(c)(4)(A) of the Immigration and Nationality Act, 8 U.S.C. § 1186a(c)(4)(A) (2012), the relevant period for determining whether an alien’s removal would result in extreme hardship is the 2-year period for which the alien was admitted as a conditional permanent resident. - Matter of Munroe, 26 I&N Dec. 428 (BIA 2014).