DHS, June 28, 2024 "Secretary of Homeland Security Alejandro N. Mayorkas today announced the extension and redesignation of Haiti for Temporary Protected Status for 18 months, from Aug. 4, 2024...
Loper Bright Enterprises v. Raimondo What will it mean for immigration litigation? Superlitigator Brian Green says, "The overruling of Chevron opens the door to U.S. federal judges scrutinizing...
OFLC, June 26, 2024 "On November 15, 2021, the Employment and Training Administration issued a Federal Register notice (FRN) informing the public that the Office of Foreign Labor Certification ...
Cyrus D. Mehta and Kaitlyn Box, June 25, 2024 "On June 18, 2024, the Biden administration announced two new immigration initiatives aimed at keeping families together. The first is a “parole...
Alfaro Manzano v. Garland "Petitioner Gerson Eduardo Alfaro Manzano, a native and citizen of El Salvador, preached to the youth of his hometown to convince them to embrace religion instead of joining...
Ramírez Muñoz v. Garland
"We must decide whether Ramírez’s conduct—lying to local authorities about U.S. citizenship—was for a “purpose or benefit under” a particular law. The BIA, relying on its Richmond decision, concluded that Ramírez lied about his citizenship “for the purpose of avoiding removal proceedings.” See In re Richmond, 26 I. & N. Dec. 779, 788 (B.I.A. 2016) (holding that a “purpose” under a law “includes the avoidance of negative legal consequences— including removal proceedings”). The BIA’s interpretation of § 1182(a)(6)(C)(ii)(I) is untenable. We agree with our sister circuit that “the BIA’s construction of the ‘purpose or benefit’ language [is] . . . ‘unmoored from the purposes and concerns’ of the statute.” Castro v. Att’y Gen., 671 F.3d 356, 370 (3d Cir. 2012) (quoting Judulang v. Holder, 565 U.S. 42, 64 (2011)). ... We conclude that Richmond’s construction of “under” is unreasonable and do not afford it any deference. Consequently, we reject Richmond’s derivative holding that “[t]he term ‘purpose’ . . . includes the avoidance of negative legal consequences—including removal proceedings.” ... We therefore grant the petition for review and remand to the agency to either grant Ramírez’s application for adjustment of status or explain, consistent with this opinion, why not."
[Hats way off to Marco A. Jimenez!]