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BIA on Niz-Chavez: Matter of Laparra

January 19, 2022 (1 min read)

Matter of Laparra, 28 I&N Dec. 425 (BIA 2022) Interim Decision #4034

"A respondent receives sufficient written notice to support the entry of an in absentia order of removal, even if he or she was served with a noncompliant notice to appear that did not specify the time or place of the hearing, where the respondent was properly served with a statutorily compliant notice of hearing specifying this information. Niz-Chavez v. Garland, 141 S. Ct. 1474 (2021), distinguished. Matter of Pena-Mejia, 27 I&N Dec. 546 (BIA 2019), and Matter of Miranda-Cordiero, 27 I&N Dec. 551 (BIA 2019), reaffirmed."