Pace University, July 19, 2024 "Professor Merton began her legal education career at New York University School of Law, and was a founding faculty member of CUNY Law School, and a Mellon and National...
DHS, July 19, 2024 "Secretary of Homeland Security Alejandro N. Mayorkas today announced the extension and redesignation of Somalia for Temporary Protected Status for 18 months, from September 18...
USCIS, July 18, 2024 "The Immigration and Nationality Act (INA) provides that U.S. citizens may transmit citizenship to their children born outside of the United States in certain circumstances...
Paye v. Garland "The BIA and IJ (collectively, "the agency") did not address whether Paye's escape from Liberia because of systematic ethnic cleansing and genocide of the Krahn people...
We are still waiting for the official Federal Register notice, but on July 17, 2024 the White House issued a Fact Sheet including this statement: "On June 18th, the President announced a new process...
Vasquez-Rivera v. Garland
"Here, the BIA attributed analysis to the IJ that the IJ never undertook. Finding that none of Vasquez-Rivera’s proposed social groups were cognizable, the IJ concluded that her asylum claims failed. With respect to Vasquez-Rivera’s family in particular, the IJ found that Vasquez-Rivera “did not establish that her family was or will be identified as a distinct group.” As a result, the IJ never resolved whether Vasquez-Rivera could prove a nexus between her membership in her family and her persecution. The only reference to the nexus requirement in the IJ’s opinion is with respect to a different particular social group—“Salvadoran women and girls whose parents live outside the country.” There, the IJ found that “even if this [were] a cognizable group, there is no nexus” between Vasquez-Rivera’s claim and this group. But the IJ made no similar finding regarding the family-as-a-particular-social-group claim. So the BIA’s conclusions as to the nexus required to prove asylum for this social group lack support in the record and constitute improper de novo factfinding. See 8 C.F.R. § 1003.1(d)(3)(i). ... [W]e remand to the BIA to apply circuit nexus precedent to Vasquez-Rivera’s asylum claim and claim for withholding of removal based on her membership in her family."
[Hats off to Paul Ben Sion Grotas!]