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2010

  • CA9 Finds Past Persecution and Well-Founded Fear in Mongolian Asylum Claim(61 KB - 12/27/2010)
    Over dissent, the court found that the cumulative effect of multiple confrontations and threats by the Communist Secret Police in Mongolia, which caused Petitioner mental anguish and physical paralysis, constituted past persecution. (Javhlan v. Holder, 12/3/10)
    AILA Doc. No. 10122745.
  • CA9 Finds California Misdemeanor False Imprisonment Is Not a CIMT(71 KB - 12/27/2010)
    The court held that misdemeanor false imprisonment in violation of Cal. Penal Code §236 is not categorically a crime involving moral turpitude. (Saavedra-Figueroa v. Holder, 11/5/10)
    AILA Doc. No. 10122737.
  • CA9 Finds California Robbery Is a Crime Involving Moral Turpitude(62 KB - 12/27/2010)
    The court found reasonable the BIA’s determination that robbery under Cal. Penal Code §211 is a crime involving moral turpitude for purposes of INA §212(a)(2)(A)(i)(I). (Mendoza v. Holder, 10/27/10)
    AILA Doc. No. 10122735.
  • CA9 on False Claims to U.S. Citizenship and Continuous Physical Presence(70 KB - 12/27/2010)
    The court found Petitioner ineligible for AOS for presenting a U.S. birth certificate in attempting to enter, and ineligible for cancellation because physical presence was interrupted when he withdrew his application for admission. (Valadez-Munoz v. Holder, 10/28/10)
    AILA Doc. No. 10122734.
  • CA9 Finds Cal. Penal Code §246 Is Not Categorically a Crime of Violence(38 KB - 12/27/2010)
    The court held that shooting at an inhabited dwelling or vehicle in violation of Cal. Penal Code §246 is not categorically a crime of violence as defined under 18 USC §16(b). (Covarrubias Teposte v. Holder, amended 1/20/11)
    AILA Doc. No. 10122732.
  • CA9 Orders CAT Relief, Finding BIA Erred in Conception of CAT Protection(44 KB - 12/22/2010)
    The court ordered CAT relief, finding that BIA erred in its denial on the basis that petitioner could avoid torture by ceasing to exercise her political rights and remanded for consideration of her FGM claim as a separate basis for relief. (Edu v. Holder, 10/26/10)
    AILA Doc. No. 10122245.
  • CA9 Finds Alaska Coercion Conviction Is Not Categorically a Crime of Violence(26 KB - 12/20/2010)
    The court held that a conviction for coercion under Alaska Statute §11.41.530(a)(1) is not categorically an aggravated felony crime of violence as defined under INA §101(a)(43)(F). (Cortez-Guillen v. Holder, 10/5/10)
    AILA Doc. No. 10122074.
  • CA9 Proceeds on Merits of Derivative Asylum Claim Despite Death of Principal (Withdrawn 5/5/11)(45 KB - 12/20/2010)
    Over dissent, the court dismissed the principal asylum applicant’s claim as moot due to his death, but declined to dismiss the derivative’s claim in light of the possible collateral consequences of such action. (Saval v. Holder, 9/23/10)
    AILA Doc. No. 10122073.
  • CA9 Discusses Limitations on Adjustment of Status for K-1 Fiancés(30 KB - 11/29/2010)
    Addressing but rejecting a number of arguments, the court held that Petitioner, who entered the U.S. on a K-1 visa but failed to marry the petitioning fiancé was not eligible for adjustment of status under INA §245. (Kalal v. Gonzales, 3/30/05)
    AILA Doc. No. 10112965.
  • CA9 Reverses Course on “Exceptional Circumstances” (Updated 4/7/11)(112 KB - 4/7/2011)
    On rehearing, the court found that its original opinion interpreted the “exceptional circumstances” safe harbor for aliens removed in absentia too broadly and dismissed the petition for review. Original opinion follows. (Vukmirovic v. Holder, 4/6/11)
    AILA Doc. No. 10112964.
  • CA9 Finds Nevada Assault with a Deadly Weapon is a Crime of Violence(26 KB - 11/29/2010)
    The court held that a conviction for assault with a deadly weapon under Nevada Revised Statutes §200.471 is categorically an aggravated felony crime of violence. (Camacho-Cruz v. Holder, 9/2/10)
    AILA Doc. No. 10112963.
  • CA9 Finds No Jurisdiction to Review IJ’s Decision to Terminate (Amended 5/9/11)(231 KB - 11/29/2010)
    The court distinguished Lolong v. Gonzales and found that it lacked jurisdiction over the petition for review because the IJ’s decision to terminate proceedings resulted in no final order of removal. (Galindo-Romero v. Holder, 9/2/10)
    AILA Doc. No. 10112962.
  • CA9 Finds Jurisdiction to Review the BIA’s Denial of a Motion to Reopen(39 KB - 11/29/2010)
    The court reaffirmed Fernandez v. Gonzalez, finding jurisdiction to review the BIA’s decision on a motion to reopen that presents evidence so distinct from that considered previously as to make the motion a request for new relief. (Garcia v. Holder, 9/1/10)
    AILA Doc. No. 10112961.
  • CA9 Finds Distribution of a “Listed Chemical” is an Aggravated Felony(29 KB - 11/29/2010)
    The court held that a conviction for distributing ephedrine and pseudoephedrine with reasonable cause to believe they would be used to manufacture methamphetamine under 21 USC §841(c)(2) is an aggravated felony drug trafficking crime. (Daas v. Holder, 8/24/10)
    AILA Doc. No. 10112960.
  • CA9 on Personal Use Exception to Controlled Substance Deportability Ground(28 KB - 11/16/2010)
    The court held that INA §237(a)(2)(B)(i) which exempts from removal those convicted of a single offense involving possession of 30 grams or less of marijuana for one’s own use does not apply to persons with more than one drug conviction. (Rodriguez v. Holder, 8/23/10)
    AILA Doc. No. 10111665.
  • CA9 on Exhaustion of Administrative Remedies in Pre-Compean Case(71 KB - 11/16/2010)
    The court found that the application of Compean did not have retroactive effect and that Petitioner failed to exhaust his administrative remedies by not filing a motion to reopen with the BIA before filing a habeas petition. (Singh v. Napolitano, 8/23/10)
    AILA Doc. No. 10111663.
  • CA9 Finds IJ Did Not Err in Reassessing Credibility on Remand(41 KB - 11/16/2010)
    As a matter of first impression, the court held that the IJ’s jurisdiction on remand from the BIA is limited only when the BIA expressly retains jurisdiction and qualifies or limits the scope of the remand to a specific purpose. (Fernandes v. Holder, 8/20/10)
    AILA Doc. No. 10111661.
  • CA9 on Notice “to the Alien” Under INA §203(g)(61 KB - 11/16/2010)
    The court reversed the termination of Petitioner’s immigrant visa for failure to apply within one year. INA §203(g) and 22 CFR §42.67(b) require notice “to the alien” but DOS sent notice only to the attorney and the I-130 petitioner. (Singh v. Clinton, 8/20/10)
    AILA Doc. No. 10111660.
  • CA9 on Right to A-File Documents in Removal Proceedings(237 KB - 11/10/2010)
    The court found that INA §240(c)(2) which provides that the alien “shall have access” to non-confidential A-file documents compelled the government to provide such documents to Petitioner without requiring him to file a FOIA request. (Dent v. Holder, 11/9/10)
    AILA Doc. No. 10111064.
  • CA9 Sets Aside Finding that Asylum Claim Was Frivolous(71 KB - 10/14/2010)
    In a Nepalese asylum case, the court found that the IJ’s adverse credibility finding was supported by substantial evidence, but that the finding of frivolousness was procedurally unsound and not supported by a preponderance of the evidence. (Khadka v. Holder, 8/18/10)
    AILA Doc. No. 10101460.
  • CA9 Discusses Time Calculation for Filing Petition for Review(217 KB - 10/13/2010)
    The day after Thanksgiving is a legal holiday for purposes of calculating time for the filing of a petition for review under Federal Rules of Appellate Procedure 26(a). (Yepremyan v. Holder, 8/10/10)
    AILA Doc. No. 10101361.
  • CA9 Discusses “Unable or Unwilling” Standard for Nongovernmental Persecution(270 KB - 10/13/2010)
    In a Ghanaian religious persecution case, the BIA erred in its “unable or unwilling” analysis by ignoring evidence favorable to Petitioner, misstating Petitioner’s testimony, and treating police reports made by others as irrelevant. (Afriyie v. Holder, 7/26/10)
    AILA Doc. No. 10101360.
  • CA9 on “Grandfathering” Under INA §245(i)(48 KB - 10/8/2010)
    A derivative spouse is only eligible for §245(i) adjustment if he or she is “accompanying or following to join” the principal alien. Status as a mere registrant for the RAW program does not grandfather petitioner into §245(i). (Landin-Molina v. Holder, 09/01/09)
    AILA Doc. No. 10100874.
  • CA9 Interprets “Final Administrative Order” for Motions to Reopen(26 KB - 9/28/2010)
    The denial of a motion to reconsider does not qualify as a “final administrative order of removal” for purposes of the 90-day time limitation on filing motions to reopen under INA §240(c)(7)(C)(i). (Vega v. Holder, 7/19/10)
    AILA Doc. No. 10092869.
  • CA9 Finds California Penal Code §273.5(a) is a Domestic Violence Crime(39 KB - 9/28/2010)
    A conviction for “corporal injury to a spouse/cohabitant” in violation of California Penal Code §273.5(a) is categorically a crime of domestic violence under INA §237(a)(2)(E)(i). (Banuelos-Ayon v. Holder, 7/14/10)
    AILA Doc. No. 10092867.
  • CA9 Remands Motion Claiming Lack of Notice of BIA Decision(35 KB - 9/28/2010)
    The BIA abused its discretion by denying Petitioner’s motion to reissue its underlying decision, without considering the weight of Petitioner’s declaration to rebut the presumption of notice and accompanying change of address. (Hernandez-Velasquez v. Holder, 7/14/10)
    AILA Doc. No. 10092866.
  • CA9 Interprets “Has Been” in the Cancellation of Removal Context(224 KB - 9/24/2010)
    For purposes of INA §240A(a) cancellation, the term “has been” lawfully admitted for permanent residence means that the alien must currently possess LPR status. It does not include a person who held that status but has since lost it. (Padilla-Romero v. Holder, 7/9/10)
    AILA Doc. No. 10092431.
  • CA9 Finds No Judicial Admission of NTA Entry Date in NACARA Case(231 KB - 9/24/2010)
    The government did not make a binding judicial admission about Petitioner’s entry date in the NTA for purposes of NACARA eligibility because it disputed the date during an evidentiary hearing and Petitioner never expressly objected. (Cortez-Pineda v. Holder, 7/2/10)
    AILA Doc. No. 10092430.
  • CA9 Finds §212(k) Refers to Invalid Visas(55 KB - 7/26/2010)
    CA9 found petitioners eligible for §212(k) relief, concluding that their immigrant visas, which were derivative of their mother’s fraudulently-obtained LPR status, fell with the scope of §212(k). (Shin v. Holder, 06/11/10)
    AILA Doc. No. 10072660.
  • CA9 Holds BIA Erred in Finding Application Abandoned for Failure to Timely Submit Subsequent Documentation(22 KB - 7/23/2010)
    CA9 held that BIA misinterpreted 8 C.F.R. § 1003.31(c) and erred in holding petitioner’s failure to timely submit subsequent documentation allowed IJ to deem his entire timely filed, statutorily authorized 212(c) application abandoned. (Casares-Castellon v. Holder, 5/4/10)
    AILA Doc. No. 10072361.
  • CA9 Finds Unborn Child Not a Qualifying Relative under Hardship Provision(21 KB - 7/23/2010)
    CA9 upheld BIA decision that unborn child was not a qualifying relative for cancellation of removal purposes, finding that unborn child did not meet statutory definition of a “child” at time of IJ hearing. (Partap v. Holder, 5/4/10)
    AILA Doc. No. 10072360.
  • CA9 Finds IJ Erred in Denying Continuance and Excluding Testimony(37 KB - 7/22/2010)
    CA9 remanded, finding IJ denied petitioner a full and fair hearing by precluding her from testifying to matters in the psychological evaluation of her child and denying a continuance less than one month after counsel’s initial appearance. (Rendon v. Holder, 05/03/10)
    AILA Doc. No. 10072269.
  • CA9 Finds Petitioners Who Received Fraudulent Green Cards in Conspiracy by Former INS Officer Removable(29 KB - 7/22/2010)
    CA9 denied petition in part, holding that government proved removability of petitioners, who belonged to a group of persons who received fraudulent green cards through the criminal conspiracy of a convicted former INS officer. (Kim v. Holder, 05/03/10)
    AILA Doc. No. 10072267.
  • CA9 Finds California Grand Theft Is an Aggravated Felony(36 KB - 5/25/2010)
    The court found that Petitioner’s conviction for grand theft under California Penal Code §487(a) qualified as an aggravated felony under the modified categorical approach. (Ramirez-Villalpando v. Holder, 4/9/10; amended 7/1/11)
    AILA Doc. No. 10052569.
  • CA9 on the Definition of “Admitted” under § 212(h)(50 KB - 5/25/2010)
    CA9 denied petition, finding that because petitioner was “admitted” as an LPR in the sense of being inspected and authorized at the port of entry, but later convicted, he is barred from § 212(h) relief. (Sum v. Holder, 04/23/10)
    AILA Doc. No. 10052568.
  • CA9 Remands Withholding of Removal Claim for Past Persecution Decision(32 KB - 5/25/2010)
    CA9 remanded in part, finding that the IJ and BIA did not decide whether petitioner’s testimony, if believed, established past persecution. The court held that the IJ erred in making a finding of changed circumstances. (Mutuku v. Holder, 04/09/10)
    AILA Doc. No. 10052567.
  • CA9 on Joint Petition and Good Faith Marriage Requirements(48 KB - 5/25/2010)
    CA9 held that petitioner was not entitled to LPR status, finding IJ and BIA ruling supported by substantial evidence, where wife withdraw her support and INS determined that he had not entered into the marriage in good faith. (Hammad v. Holder, 04/22/10)
    AILA Doc. No. 10052566.
  • CA9 on the Definition of “Admitted” under § 212(h)(34 KB - 5/25/2010)
    CA9 denied petition, finding that because petitioner was “admitted” as an LPR in the sense of being inspected and authorized at the port of entry, but later convicted, he is barred from § 212(h) relief. (Nunez-Reyes v. Holder, 04/23/10)
    AILA Doc. No. 10052565.
  • CA9 Finds Aggravated Felony Provision Does Not Apply to Pre-11/18/88 Convictions(159 KB - 5/25/2010)
    The court held that the aggravated felony ground of removal under INA §237(a)(2)(A)(iii) does not apply to convictions that occurred before November 18, 1988, the date of enactment of the law that created the provision. (Ledezma-Galacia v. Holder, 12/22/10)
    AILA Doc. No. 10052564.
  • CA9 Finds IJ Erred by Considering Her Bond Hearing Notes during Removal Hearing(57 KB - 5/25/2010)
    CA9 granted petition and remanded asylum case, finding that IJ, who presides over the same petitioner’s bond hearing and removal hearing, may not use her notes from the unrecorded bond hearing in reaching her removal hearing decision. (Joseph v. Holder, 04/14/10)
    AILA Doc. No. 10052563.
  • CA9 Remands Asylum Case on China’s Population Control Policy(48 KB - 5/25/2010)
    CA remanded, holding that petitioner suffered persecution for demonstrating other resistance to China’s coercive population control policy and deferred to AG’s INA interpretation in J-S- on spouses of victims of such policies. (Jiang v. Holder, 05/24/10)
    AILA Doc. No. 10052562.
  • CA9 Finds Marriage Fraud Covered By Fraud Waiver(65 KB - 5/25/2010)
    CA9 granted petition and remanded, holding that an alien whose legal status as the spouse of a citizen is later terminated because the marriage was fraudulent is eligible for discretionary relief from removal. (Vasquez v. Holder, 04/19/10)
    AILA Doc. No. 10052561.
  • CA9 Remands, Finding BIA Erred in Denial of CAT Claim(35 KB - 5/21/2010)
    CA9 granted petition, finding that the BIA’s reasoning appears to be at odds with the IJ’s decision, petitioner’s credible testimony, and judicially-noticeable facts. The court remanded to BIA for a clearer explanation of its decision. (Eneh v. Holder, 04/16/10)
    AILA Doc. No. 10052163.
  • CA9 Finds CA Health & Safety Code § 11361(b) Conviction a Removable Offense(25 KB - 5/21/2010)
    CA9 dismissed petition, holding that petitioner’s state conviction under CA Health and Safety Code § 11361(b) qualifies as a controlled substance offense under 8 U.S.C. § 1227(a)(2)(B)(i). (Guerrero-Silva v. Holder, 03/31/10)
    AILA Doc. No. 10052162.
  • CA9 Upholds BIA Finding that “Drug Trafficking Crime” Does Not Require Firearm Use(30 KB - 5/21/2010)
    CA9 denied petition, holding that the use of a firearm is not a necessary element of a “drug trafficking crime” for the purpose of determining whether an alien has been convicted of an “aggravated felony.” (Lopez-Jacuine v. Holder, 04/12/10)
    AILA Doc. No. 10052161.
  • CA9 Grants Withholding of Removal Finding BIA Failed to Apply Disfavored Group Analysis(40 KB - 4/6/2010)
    CA9 granted petition with respect to withholding of removal and remanded holding that on this record Christians are a disfavored group in Indonesia and BIA erred in failing to analyze claim according to disfavored group analysis. (Tampubolon v. Holder, 3/9/10)
    AILA Doc. No. 10040666.
  • CA9 Grants Petition in Part for Remand on Issue of Religious Persecution(87 KB - 4/6/2010)
    CA9 granted petition in part, finding that the court was required to remand to the BIA to address the questions of whether petitioner would be in danger of persecution on account of his religion or would be entitled to other relief. (Tijani v. Holder, 3/11/10)
    AILA Doc. No. 10040669.
  • CA9 Finds Conviction for Receipt of Stolen Vehicle Qualifies as Crime of Moral Turpitude(29 KB - 4/6/2010)
    CA9 denied petition finding that state felony conviction for receipt of a stolen vehicle in violation qualifies categorically as a conviction for an aggravated felony, but not as a crime involving moral turpitude. (Alvarez-Reynaga v. Holder, 2/19/10)
    AILA Doc. No. 10040668.
  • CA9 Affirms Dismissal of Indictment for Illegal Re-entry(45 KB - 4/6/2010)
    CA9 affirmed dismissal of criminal indictment for illegal reentry because government affirmatively and prejudicially misled petitioner as to his statutory right after his removal in absentia to seek to reopen his removal proceedings. (U.S. v. Arias-Ordonez, 3/8/10)
    AILA Doc. No. 10040667.
  • CA9 on Expunged Convictions under the Federal First Offender Act(36 KB - 4/6/2010)
    CA9 held first-time offenders convicted of using or being under influence of controlled substance and granted relief are eligible for same immigration treatment as those whose simple drug possession convictions are expunged under FFOA. (Rice v. Holder, 2/26/10)
    AILA Doc. No. 10040664.
  • CA9 Finds Lack of Jurisdiction to Review BIA Discretionary Denial for Abuse of Discretion(69 KB - 3/30/2010)
    CA9 found lack of jurisdiction to review for abuse of discretion BIA’s discretionary denial of petitioner’s motion to accept untimely brief because there is no meaningful standard against which to judge agency’s exercise of discretion. (Zetino v. Holder, 2/18/10)
    AILA Doc. No. 10033069.
  • CA9 on Burden to Show Conviction of a Disqualifying Controlled Substance Offense(219 KB - 3/10/2010)
    CA9 granted in part and remanded for further proceedings consistent with Sandoval-Lua to permit government to put forth reliable evidence to show petitioner was convicted of disqualifying controlled substance offense. (Esquivel-Garcia v. Holder, 1/28/10)
    AILA Doc. No. 10031065.
  • CA9 Holds Physical Removal of Petitioner by U.S. Does Not Preclude Motion to Reopen(30 KB - 3/10/2010)
    CA9 granted petition, finding that BIA cannot deem a motion to reopen or reissue withdrawn by operation of law when the government removes a petitioner before the BIA has ruled on the motion. (Coyt v. Holder, 1/20/10)
    AILA Doc. No. 10031063.
  • CA9 Applies Modified Categorical on Conviction Relating to a Controlled Substance(28 KB - 3/9/2010)
    CA9 denied petition, finding conviction under Cal. Health & Safety Code § 11379(a), qualifies for removal, so long as substance involved is determined to have been controlled substance under the modified categorical approach. (Hernandez-Aguilar v. Holder, 1/12/10)
    AILA Doc. No. 10030969.
  • CA9 Finds IJ Denied Full and Fair Hearing in Removal Case(37 KB - 3/9/2010)
    CA9 granted petition and remanded with instructions to order a new hearing before the IJ, finding denial of continuance in conjunction with limitations placed on testimony prevented petitioner from full and fairly presenting case. (Rendon v. Holder, 12/2/09)
    AILA Doc. No. 10030968.
  • CA9 Finds Immigration Court Erred by Failure to Serve Counsel of Record with Hearing Notice(40 KB - 3/9/2010)
    CA9 reversed BIA decision that adopted IJ’s in absentia removal order and granted petition, finding that the immigration court erred because it did not serve petitioner's counsel of record with a hearing notice. (Hamazaspyan v. Holder, 12/21/09)
    AILA Doc. No. 10030967.
  • CA9 Finds State Offense for “Unlawful Sexual Intercourse with a Minor” Not Aggravated Felony(36 KB - 3/9/2010)
    CA9 held that the offense of “unlawful sexual intercourse with a minor” under California Penal Code does not meet the definition of “aggravated felony” in 8 U.S.C. § 1101(a)(43)(A), which includes “sexual abuse of a minor.” (Pelayo-Garcia v. Holder, 12/14/09)
    AILA Doc. No. 10030966.
  • CA9 on Corroboration under the REAL ID Act in Asylum Case(40 KB - 3/9/2010)
    CA9 denied petition, finding that the BIA properly required corroboration of petitioner's testimony under the REAL ID Act. (Aden v. Holder, 12/8/09)
    AILA Doc. No. 10030965.
  • On Rehearing CA9 Rules USCIS Unlawfully Imposed Arbitrary Requirements for EB-1(229 KB - 3/4/2010)
    On rehearing, CA9 adopted the arguments of the American Immigration Council’s Legal Action Center, holding that USCIS unlawfully imposed extra-regulatory requirements on a petition for a worker of "extraordinary ability" (EB-1). (Kazarian v. USCIS, 3/4/10)
    AILA Doc. No. 10030420.
  • CA9 Remands Finding Suspended Non-incarceratory Sanction Not “Conviction”(45 KB - 3/4/2010)
    CA9 remanded finding definition of "conviction" 8 U.S.C. §1101(a)(48) does not include criminal judgments whose only consequence is a suspended non-incarceratory sanction. Therefore, petitioner has not been shown to be subject to removal. (Retuta v. Holder, 01/7/10)
    AILA Doc. No. 10030464.
  • CA9 Finds Material Witnesses for Government Do Not Constitute Protected Social Group(28 KB - 3/4/2010)
    CA9 denied application for asylum, withholding of removal and relief under CAT, finding that material witnesses for the government do not constitute a protected social group (Velasco-Cervantes v. Holder, 01/27/10)
    AILA Doc. No. 10030463.
  • CA9 Finds Failure to Consider Country Conditions Constitutes Reversible Error in CAT Case(35 KB - 3/4/2010)
    CA9 granted petition as to CAT relief application and remanded finding failure to consider evidence of country conditions constitutes reversible error and IJ and BIA erred by construing “government acquiescence” too narrowly. (Aguilar-Ramos v. Holder, 02/4/10)
    AILA Doc. No. 10030462.
  • CA9 Remands for Determination on Additional Types of Evidence under Nijhawan Standard(48 KB - 3/4/2010)
    CA9 upheld removal order for Akio Kawashima and remanded with respect to Fusako Kawashima for BIA to determine what additional types of evidence may be considered in light of Supreme Court’s holding in Nijhawan v. Holder. (Kawashima v. Holder, 01/17/10)
    AILA Doc. No. 10030461.
  • CA9 Applies Categorical Approach and Holds Indecent Exposure Not a Crime of Moral Turpitude(96 KB - 2/12/2010)
    CA9 applied the categorical approach and held that indecent exposure under California law is not categorically a crime of moral turpitude. (Nunez v. Holder, 02/10/2010)
    AILA Doc. No. 10021261.
  • CA9 on Federal Jurisdiction in Extreme Hardship I-751 Waiver Cases(46 KB - 1/13/2010)
    CA9 concluded that IIRIRA does not bar the court from reviewing whether the respondent has demonstrated “extreme hardship” and is thus eligible for an I-751 waiver of the joint filing requirement to remove the conditions on residence. (Singh v. Holder, 01/08/10)
    AILA Doc. No. 10011361.
 
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