EOIR Policy Memo (PM) 25-34 Conflicting Precedents of the Board of Immigration Appeals

EOIR Acting Director Sirce E. Owen issued Policy Memo (PM) 25-34, "Conflicting Precedents of the Board of Immigration Appeals." In it, she notes that the Board of Immigration Appeals (BIA) does not have an established procedure for resolving conflicts between BIA precedents. In the absence of such guidelines, immigration judges "have to apply their best judgment and traditional legal tools or methods of analysis to adjudicate cases before them where Board precedent is in conflict” and "should clearly articulate in the decision why one line of precedent was chosen over the other."