Summary of Recent Published BIA Decisions:
Matter of Munroe, 26 I&N Dec. 428 (BIA 2014); The Board held that when an alien applies for a waiver pursuant to INA § 216(c)(4)(A) (I-751 waiver petition under extreme hardship theory) the only period relevant for the determination of whether the requisite hardship exists is the 2-year period immediately following the alien’s admission as a conditional permanent resident. Any hardship based upon events or facts that followed the initial two-year conditional residency period are irrelevant.
Matter of Bett, 26 I&N Dec. 437 (BIA 2014); The Board held that a Form I-9 (Employment Eligibility Verification Form) is admissible in immigration proceedings on issues of removability and relief from removal.
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