Friday, December 28, 2018

USCIS Releases New Policy on Treatment of Extension Petitions in Certain NIV Categories

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On October 23, 2017, the United States Citizenship and Immigration Services released a new Policy Memorandum (PM-602-0151) titled “Rescission of Guidance Regarding Deference to Prior Determinations of Eligibility in the Adjudication of Petitions for Extension of Nonimmigrant Status” [PDF version]. The new Policy Memorandum instructs USCIS officers who are adjudicating extension petitions that they should apply the same level of scrutiny to extension petitions that they apply to initial petitions in certain nonimmigrant visa categories. PM-602-0151 reverses guidance from a 2004 Policy Memorandum that instructed USCIS officers to defer to prior determinations in most case where the petitioner and beneficiary and underlying facts remained the same.

To learn about the new guidance in detail, please visit our full article which explains the new policies and how they differ from the 2004 policies [see article].

We have also uploaded the USCIS news release on the subject in English [PDF version] and Spanish [PDF version].

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Thursday, December 27, 2018

Certain Form I-765 Applicants May Apply for Social Security Number/Card Along With Employment Authorization

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On October 2, 2017, the United States Citizenship and Immigration Services (USCIS) issued a news release for those applying for employment authorization [PDF version].

Thanks to a new information-sharing agreement between the USCIS and the Social Security Administration (SSA), certain foreign nationals in specific categories or classifications may apply for employment authorization and a Social Security Number all on the updated Form I-765, Application for Employment Authorization.

The USCIS explains that foreign workers in certain categories in classifications need both an employment authorization document and a Social Security Number to work lawfully in the United States. Prior to the information-sharing agreement between the USCIS and the SSA, these foreign workers would have to apply for an employment authorization document on the Form I-765 and then file additional paperwork with the SSA to obtain a Social Security Number.

The updated Form I-765 contains questions that will allow employment authorization document applicants to apply for a Social Security Number or a replacement card. The USCIS will transmit the information provided by the applicant in response to these questions to the SSA for processing. Accordingly, such applicants will not need to make a separate trip to a Social Security Office. The USCIS advised that applicants who receive their employment authorization document and also applied for a Social Security Number or a replacement card on the Form I-765 should expect to receive their Social Security Card within two weeks after receiving the employment authorization document.

When filing forms with the USCIS, it is always important to carefully follow the form and filing instructions. An individual with case-specific questions or a more complicated case may consult with an experienced immigration attorney for guidance.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Government Brings Civil Denaturalization Charges Against Four Individuals

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Introduction


On November 6, 2017, the U.S. Department of Justice (DOJ), the U.S. Department of State (DOS), and the U.S. Department of Homeland Security (DHS) announced that the United States Government filed civil complaints in the District of Minnesota against four individuals who are alleged to have fraudulently procured U.S. citizenship [PDF version]. The individuals face potential civil denaturalization.

DOJ Press Release


According to the complaint, a purported husband and wife along with their two purported children “unlawfully, knowingly, and fraudulently represented to immigration officials that they were a family” in order to gain admission into the United States through the Diversity Immigrant Visa Program. These four individuals were subsequently able to procure naturalization as a result of their fraudulent representations to immigration officials.

The DOJ described each of the four individuals and the allegations against them.

First, charges were brought against Fosia Abdi Adan, a native of Somalia who applied for and received a diversity visa on January 10, 2001. The complaint alleges that she fraudulently claimed that she was married to Jama Solob Kayre, which was a fictitious identity used by the second individual of the four charged, Ahmed Mohammed Warsame. The pair falsely claimed to have three children together, two of which were admitted into the United States as derivatives and charged along with their purported parents. Adan and Kayre, who were not, in fact, married, nevertheless procured a divorce in Minnesota soon after Adan was admitted for lawful permanent residency. Adan was naturalized on August 16, 2006, and she continued to falsely represent herself as the parent of her two purported children throughout the naturalization process. The complaint alleges that she was never lawfully admitted for permanent residence because she had engaged in “alien smuggling” as defined in the Immigration and Nationality Act (INA), and was therefore never eligible for naturalization.

Warsame received a beneficiary diversity visa under a fictitious name and based on his purported marriage to Adan. Throughout the diversity visa application process, he falsely claimed that he was married to Adan and that they had three children together. He was naturalized on September 13, 2006. Throughout the naturalization process, he continued to falsely claim that he had been married to Adan and that he was the parent of the two purported children from the marriage who were admitted as derivatives. He was naturalized under his fictitious name, but had his name changed to his real name during the naturalization process.

The first of the “children” charged was Mustaf Abdi Adan. He went by the name Mohamed Jama Solob when he applied for and received a beneficiary diversity visa as the fictitious child of Adan. Throughout the diversity visa process, he fraudulently claimed that Adan was his mother and Warsame was his father. He was naturalized under his fictitious name on July 24, 2013, but had his name changed to his real name at the time of his naturalization.

The second of the “children” charged was Faysal Jama Mire, who went by the name Mobarak Jama Solob when he applied for and obtained a beneficiary diversity immigrant visa as the fictitious child of Adan. Throughout the diversity visa application process, he fraudulently claimed that he was the child of Adan and Warsame. He was naturalized on April 14, 2010, under his fictitious name but had his name changed to his real name at the time of naturalization.

Additional Information in Washington Times Report


A report in the Washington Times by Stephen Dinan adds more information about the allegations [link].[1] According to the report on the complaint, the four individuals were in fact cousins. The purported husband, Warsame, is alleged to have been married to another woman in Somalia who was in fact pregnant at the time he applied for a derivative diversity visa. Adan and Warsame had claimed to have three children, but only two were granted diversity visas.

According to the Washington Times report, Warsame, after his divorce from his fake wife, filed visa petitions for his real wife and children. In order to help evade scrutiny, Warsame allegedly fabricated a fictitious first husband for his real wife and claimed that his actual children were his step-children. According to the story, the United States Citizenship and Immigration Services (USCIS) approved petitions for “some of Mr. Warsame's family…” However, DNA testing of Warsame's real family members revealed the fr and caused the USCIS to carefully scrutinize the entire case.

Statements from Government Officials


The DOJ news release provided statements from Government officials on the charges. We will replicate some of the interesting points from the statements.

Attorney General Jeff Sessions stated that:

The current immigration system is easily abused by fraudsters and nefarious actors, and that's certainly true of the Diversity Immigrant Visa Program. If the fraud is not detected and swift enforcement actions are not taken, chain migration only multiplies the consequences of abuse.

Here, Attorney General Sessions touches on two of his immigration priorities. As Attorney General, he has focused on combating immigration fraud, and as a Senator, he was critical of the diversity visa program. The last part of his statement notes that if one individual is admitted based on fraud, he or she may be able to subsequently petition for family members, which appears to have may have happened in the instant case. His views on the issues mirror concerns addressed in the RAISE Act proposal, which he supported [see opinion blog].

Acting Secretary of Homeland Security Elaine Duke stated that “[f]raudulently obtained citizenship is an affront to our American values, the rule of law, and all those who honestly attained their immigration status.”

The Assistant Secretary of State for Consular Affairs, Carl Risch, stated that “[d]eterring, detecting, and investigating U.S. passport and U.S. visa fraud are essential to protecting the integrity of consular processes and safeguarding our national security.”

Conclusion


The charges represent an interesting civil denaturalization case. The DOJ has publicized several denaturalization cases over the past several months [see blog]. To learn more about civil denaturalization and criminal denaturalization in general, please see our growing collection of articles on site [see category]. Please also see our article on an interesting recent Supreme Court decision involving criminal denaturalization (note that the instant charges are civil) [see article].

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

  1. Dinan, Stephen. “More fraud in Diversity Visa Lottery as feds move to strip citizenship from four Somalis.” The Washington Times. Nov. 6, 2017. washingtontimes.com

Lawyer website: http://myattorneyusa.com

Wednesday, December 26, 2018

U.S. Embassy in Mumbai to No Longer Process IR5, IR1, IR2, CR1, and CR2 Cases

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The Department of State (DOS) announced that beginning on April 1, 2018, the U.S. Embassy in New Delhi will no longer process the following visa cases:
  • IR5 (parent of U.S. citizen at least 21 years of age);
  • IR1 (spouse of U.S. citizen);
  • IR2 (child of U.S. citizen);
  • CR1 (spouse of U.S. citizen — conditional status); and
  • CR2 (child of U.S. citizen — conditional status).

Interviews scheduled on or after April 1, 2018 for applicants in the above categories will take place at the U.S. Consulate General in Mumbai. No visa processing in the above five cases will be processed at the U.S. Embassy in New Delhi. Applicants will receive a letter from the National Visa Center that will specify the location of the visa interview and provide further details about interview preparation.

Visa applicants looking for more case-specific information on preparing for the interview and other issues may consult with an experienced immigration attorney.

We have posted the DOS press release on the visa processing change involving the U.S. Embassy in New Delhi titled “Mission India Immigrant Visa Processing Consolidation” for your convenience [PDF version].

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Tuesday, December 25, 2018

E-Verify to Transfer Case Data to New Interface in March 2018

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On March 18, 2018, the United States Citizenship and Immigration Services (USCIS) announced that later in March 2018 E-Verify will transfer all of its case data to a new interface [PDF version]. Accordingly, prior to the transfer “all open cases much reach a final case result and be closed.”

What does this mean in effect? The USCIS explains that all open cases that have not been accessed for more than 365 days will be closed by E-Verify. Such closed cases will remain accessible to employers as completed or historical cases.

Cases that are open, have not been completed, and have been accessed within the previous 365 days will remain open for the employer to continue processing.

Cases that have received a final result will be closed when the USCIS transfers case data to a new E-Verify interface. However, these cases will also remain accessible to employers as completed or historical cases.

The USCIS encourages users to complete and close their cases prior to the deployment of the new E-Verify interface. For guidance on how to properly close an E-Verify case, the USCIS refers users to the following references:

  • E-Verify Quick Reference Guide for Employers (Pages 17-19) [PDF version];
  • E-Verify User Manual 4.1 Close Case [PDF version];
  • E-Verify User Manual 4.2 Case Alerts [PDF version]; and
  • E-Verify User Manual 4.1.1 Case Closure Statements [PDF version].

See also: E-Verify User Manual 4.0 Case Resolution: “To complete the E-Verify case process, every case must receive a final case result and be closed. E-Verify guides you through the process after you receive a final case result.”

It is important for employers to comply with applicable laws and regulations regarding employment verification. Employers with case-specific questions about using E-Verify cases or other employment authorization issues may consult with an experienced immigration attorney.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Monday, December 24, 2018

DOS Update on NIV Applications by Nationals of Russia and Turkey

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We recently reported on the suspension of nonimmigrant visa services in Russia [see article] and Turkey [see article].

On October 19, 2017, representatives from the American Immigration Lawyers Association (AILA) asked a U.S. Department of State (DOS) liaison whether the DOS had designated alternative posts for nationals of Russia and Turkey to apply for nonimmigrant visas [PDF version].

In both cases, the DOS did not indicate that it had designated any posts for Russian and Turkish nationals. Instead, it stated that “[f]or [nonimmigrant visas], the absence of any designation of alternative posts generally allows applicants to apply wherever they are physically present.”

We will continue to update the website with more information regarding the situation for nonimmigrant visas in Russia and Turkey. Those with case-specific questions should consult with an experienced immigration attorney for guidance.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Friday, December 21, 2018

New USCIS Website Homepage

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On March 15, 2018, the United States Citizenship and Immigration Services (USCIS) updated the design of its website homepage [PDF version]. The USCIS made the changes to the USCIS website homepage based on user-feedback, search queries, and by talking to applicants in person and at two USCIS field offices. The changes to the USCIS website are designed to make it easier for users to access important tools, search for information, and find multilingual resources. In one interesting note, the new homepage prominently features information about President Donald Trump's “Buy American, Hire American” Executive Order, which we have discussed on our site [see article].

Please see the news release [see here] for more information about the design changes to the USCIS website homepage.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

USCIS Launches Pilot Redesigned Processing Times Webpage

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On March 22, 2018, the United States Citizenship and Immigration Services (USCIS) announced that it had “launched a pilot to test a redesigned processing times webpage” [PDF version].

The redesigned processing times webpage pilot will test the following four forms:
  • Form N-400, Application for Naturalization;
  • Form I-90, Application to Replace Permanent Resident Card;
  • Form I-485, Application to Register Permanent Residence or Adjust Status; and
  • Form I-751, Petition to Remove Conditions on Residence.

The redesigned processing times webpage posts data in an easier-to-read format for users. Furthermore, the pilot is testing “a new way of collecting data and calculating the processing times for some forms.” The USCIS describes the latter as “automated, more accurate, and allow[ing] USCIS to post data on processing times within two weeks, compared to six weeks under the old methodology.”

The redesigned processing times webpage displays processing times in a range for each form based on the date on which the USCIS receives the form. The low end processing time for the pilot displays the time it takes the USCIS to complete 50 percent of cases, whereas the high end processing time shows the time it takes the USCIS to complete 93 percent of cases. The USCIS explained that “[t]he high end for non-pilot forms will be adjusted by 30 percent above current cycle times to reflect the time it takes to complete a majority of the cases.”

The USCIS will seek feedback during the pilot for the redesigned processing time webpage and look to expand the pilot to cover additional forms in the future.

Applicants, petitioners, and requestors may make an “outside normal processing time” case inquiry regarding a case that is pending longer than the high end of the processing time range by either making a service request [PDF version] on the USCIS website or by calling the USCIS Contact Center at 1-800-375-5283 (information current as of March 26, 2018).

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Thursday, December 20, 2018

Nielsen v. Preap: Supreme Court Grants Cert in New Mandatory Detention (236(c)) Case

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Introduction


On March 19, 2018, the Supreme Court of the United States granted certiorari in Nielsen v. Preap, Docket No. 16-1363 [PDF version]. The case is on appeal by the Government from the decision of the United States Court of Appeals for the Ninth Circuit in Preap v. Johnson, 831 F.3d 1193 (9th Cir. 2016) [PDF version]. The Supreme Court will consider whether an alien who has been released from criminal custody but who was then was not immediately taken into immigration custody by the Department of Homeland Security (DHS)is exempt from mandatory detention under section 236(c) of the Immigration and Nationality Act (INA). In this article, we will briefly examine the Ninth Circuit decision and what the Supreme Court's decision to take the case may mean going forward.

The Supreme Court recently reversed the Ninth Circuit in a separate immigration detention case involving a different section 236(c) question in Jennings v. Rodriguez, 583 U.S. __ (2018). Please see our full article to learn more about that decision [see article].

Questions Presented


The Supreme Court will consider the following question in Nielsen v. Preap [PDF version]:

Whether a criminal alien becomes exempt from mandatory detention under [section 236(c) of the INA] if, after the alien is released from criminal custody, the Department of Homeland Security does not take him into immigration custody immediately.

Section 236(c) of the INA is a mandatory detention provision. The statute requires the Attorney General to take into custody any alien who is subject to one of the mandatory detention grounds “when the alien is released, without regard to whether the alien is released on parole, supervised release, or probation, and without regard to whether the alien may be arrested and imprisoned again for the same offense.”

The Supreme Court will consider whether an alien becomes exempt from such mandatory detention if the DHS fails to take him or her into custody at the time he or she is released, but rather leaves a gap in time between the alien's release from criminal custody and his or her immigration arrest.

Interestingly, the Court did not agree to hear the question of whether courts have jurisdiction over the respondent's appeals. The Ninth Circuit found that it had jurisdiction, as did many other courts that have heard similar claims. Although it arose in a different context, jurisdiction over section 236(c) detention claims was discussed in a concurring opinion in Rodriguez [see article].

Decision Below


In Preap v. Johnson, a three-judge panel of the Ninth Circuit held that the section 236(c) mandatory detention provision “applies only to those criminal aliens who are detained promptly after their release from criminal custody, not to those detained long after.” 831 F.3d at 1206. The Court found that the use of the word “when” in the statutory phrase “when the alien is released” entailed “some degree of immediacy.” Id. at 1203-04 (internal citation omitted). Because the Ninth Circuit determined that the statutory language was unambiguous, it did not proceed to the second step of Chevron analysis to determine whether the DHS's differing interpretation of the statute was reasonable. Id. at 1203 n.14.

Other Decisions on the Issue


On May 18, 2001, the Board of Immigration Appeals (BIA) held in Matter of Rojas, 23 I&N Dec. 117 (BIA 2001) [PDF version], that an alien is subject to mandatory detention even if he or she is not taken into immigration custody immediately after release from incarceration. The Board has never overruled this precedent, and it remains good law outside of the Ninth Circuit.

In Castaneda v. Souza, 810 F.3d 15 (1st Cir. 2015) (en banc) [PDF version], the full six-judge panel of the First Circuit sitting en banc split evenly on the question resolved by the Ninth Circuit in Preap v. Johnson. As a result of the split, the First Circuit left intact a district court decision that interpreted section 236(c) as requiring the DHS to detain an alien immediately upon his or her release from detention, but this decision did not create binding precedent. It is worth noting that the Ninth Circuit decision in Preap v. Johnson borrowed heavily from the decision of Judge David J. Barron in Casteneda.

In Gordon v. Lynch, 842 F.3d 66 (1st Cir. 2016) [PDF version], a three-judge panel of the First Circuit rejected the imposition of a class-wide bright line rule of 48 hours for the DHS to detain an alien after his or her release from criminal custody. However, the First Circuit remanded for consideration in the first instance of what would constitute a “reasonable custody gap.”

However, notwithstanding the decisions of the Ninth and First Circuits, several other Circuits have upheld the Government's reading of section 236(c) as not requiring immediate detention. The Ninth Circuit noted that this included the decisions in Lora v. Shanahan, 804 F.3d 601, 612 (2d Cir. 2015) [PDF version]; Sylvain v. Att'y Gen. of United States, 714 F.3d 150, 157 (3d Cir. 2013) [PDF version]; Hosh v. Lucero, 680 F.3d 375, 380-81 (4th Cir. 2012) [PDF version]; and Olmos v. Holder, 780 F.3d 1313, 1322 (10th Cir. 2015) [PDF version]. 831 F.3d at 1196. Outside of the circuit courts, the Ninth Circuit noted in Preap v. Johnson, most district courts that have considered the question have rejected the Government's position. Id.

Although the Supreme Court does not state why it grants certiorari any given case, it is likely that the growing circuit split on this issue played a role in the Court's decision to do so in Preap v. Johnson and reflects a perceived need to provide a uniform rule on the meaning of “when” in section 236(c).

Conclusion


The question of whether an alien is subject to section 236(c) mandatory detention if there is a gap between his or her release from criminal custody and the ensuing arrest and detention by DHS is a significant one, for section 236(c) is a broad mandatory detention provision. Although most circuit courts that have decided the issue have sided with the Government, the Ninth Circuit is by far the largest circuit in terms of both the number of individuals under its jurisdiction and the number of immigration cases that arise in its jurisdiction. Accordingly, the Supreme Court's ultimate decision on the issue will reach a significant number of immigration cases regardless of the decision. In conjunction with the recent Jennings v. Rodriguez decision, which may itself return to the Supreme Court in the foreseeable future, the grant of cert in Preap suggests that several justices have an interest in resolving issues relating to the INA's mandatory detention provisions.

We will update the website with more information on the proceedings in Nielsen v. Preap as it becomes available.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Wednesday, December 19, 2018

USCIS Publishes New Form I-864 P, HHS Poverty Guidelines for Affidavit of Support (03/01/18)

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The United States Citizenship and Immigration Services (USCIS) released the new edition of the Form I-864P, HHS Poverty Guidelines for Affidavit of Support. The new edition of the Form I-864P is dated 03/01/18. The HHS poverty guidelines took effect for immigration purposes on that same day. We have uploaded it on site for reference purposes only [PDF version].

The Form I-864P lists the HHS poverty guidelines. The poverty guidelines are mainly relevant in the context of affidavits of support for overcoming the presumption of public charge [see article] and for fee waivers of USCIS forms [see article] and reduced fee requests for naturalization applications [see article]. To read about the new HHS poverty guidelines, please see our full blog on site [see blog].

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Thursday, December 13, 2018

Deputy Attorney General Rosenstein Writes Op-Ed On Idea For Immigration Appellate Court

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On December 6, 2018, Deputy Attorney General Rod Rosenstein published an interesting op-ed in the Wall Street Journal titled “Impose Boundaries on Immigration Law.”[1]

In general, appeals of administrative decisions filed by the Board of Immigration Appeals (BIA) go directly to the Federal appellate court having geographic jurisdiction over the area in which the immigration case arose. For example, appeals in cases arising in New York are handled by the United States Court of Appeals for the Second Circuit, appeals in cases arising in New Jersey are handled by the United States Court of Appeals for the Third Circuit, and appeals in cases arising in California are handled by the United States Court of Appeals for the Ninth Circuit. We cover the jurisdiction of the Federal circuit courts in a separate article [see article].

In his op-ed, the Deputy Attorney General argued that the current system has several flaws:
  • The Nationality Clause of the United States Constitution vests in Congress the power “To establish a uniform rule of naturalization.” The Immigration and Nationality Act “takes up only a single chapter of the United States Code.” However, “each circuit court may interpret the law differently.” As a result, “[a] uniform interpretation emerges only in the rare event that the Supreme Court hears an immigration case.” Accordingly, “despite the constitutional mandate to establish a uniform rule, the system often produces divergent results.”
  • “In 2018, about 56% of all BIA appeals, or about 2,700 cases, were filed in the Ninth Circuit…” DAG Rosenstein identified this as a problem because he described the Ninth Circuit as “the jurisdiction most willing to grant lengthy temporary stays of removal.” For example, he criticized the Ninth Circuit's recent decision in Barajas-Romero v. Lynch, 846 F.3d 351 (9th Cir. 2017) [PDF version], which he described as “reject[ing] the 13-year old legal standard used by the Board of Immigration Appeals and all other federal courts to evaluate eligibility for withholding of removal…”
  • Immigration cases make up a large portion of the federal docket and lead to significant case backlogs. DAG Rosenstein noted that “In fiscal 2018, there were 4,795 appeals of BIA decisions filed in the federal courts of appeals. At the end of the year there were approximately 8,276 immigration appeals pending.” Immigration appeals “account for some 86% of all administrative agency appeals pending before circuit courts.” Because of the large number of immigration appeals, “Alien cases routinely languish for well over a year, several years if the court requires oral argument.” He added that nearly a quarter of the Ninth Circuit's cases are immigration appeals and about 13% of the Second Circuit's caseload were appeals of BIA decisions.
Having identified these problems, DAG Rosenstein suggested giving a single circuit court subject-matter jurisdiction over all BIA appeals. As we explain in our article on the jurisdiction of the federal circuit courts, twelve of the thirteen circuit courts have geographic jurisdiction. The United States Court of Appeals for the Federal Circuit is the only circuit court which currently has subject-matter jurisdiction, meaning it hears all appeals from around the country in designated areas set forth in 28 U.S.C. 1295 [PDF version]. DAG Rosenstein suggested a similar scheme for BIA appeals. Referencing the Federal Circuit, he argued that this proposal for immigration appeals, if implemented, would have the following benefits:
  • It would “restore uniformity and promote efficiency by consolidating all immigration appeals in a specialized court of immigration appeals.” This would avoid “confusion and delay” that results from having twelve Federal appellate courts interpret the same provisions of the INA. The judges sitting on a specialized immigration appellate court would “gain expertise in specialized areas of the law, resulting in greater clarity and consistency in its rulings.”
  • “It would also help relieve the appellate dockets, which are swamped by immigration cases.”
  • It would also ensure that courts sitting in specific geographic areas do not have a disproportionate effect on the immigration laws.
  • In sum, “This would promote prompt adjudication of aliens' claims and fulfill Congress's duty to establish 'a uniform Rule of Naturalization.'”
DAG Rosenstein suggested that Congress could either create an entirely new circuit court having subject-matter jurisdiction over BIA appeals or expand the subject-matter jurisdiction of the Federal Circuit.

In his op-ed, DAG Rosenstein alludes to the fact that the changes he is proposing would have to be enacted by Congress. Similarly to proposals to break up the Ninth Circuit [see blog], it is unlikely that Congress will seriously contemplate DAG Rosenstein's proposal in the near future. However, the proposal is worth keeping in mind for future discussions about immigration reform. It is possible that President Donald Trump and/or members of Congress will push the issue as part of a broader legislative package on immigration.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.
  1. Rosenstein, Rod. “Impose Boundaries on Immigration Law.” The Wall Street Journal. (Dec. 6, 2018.) https://www.wsj.com/articles/impose-boundaries-on-immigration-law-1544139768
Lawyer website: http://myattorneyusa.com

President Trump Nominates William Barr To Be Next Attorney General

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On December 7, 2018, President Donald Trump announced that he will nominate William P. Barr to succeed Jeff Sessions as the Attorney General of the United States [PDF version].

Barr served as the 77th Attorney General of the United States during the administration of former President George H.W. Bush from November 26, 1991 to January 20, 1993. He had previously served as Deputy Attorney General for one year. Since his first stint as U.S. Attorney General, Barr has worked in private practice.

Over the coming weeks, we will examine Barr's record from his first service as Attorney General for an understanding of how he may handle immigration issues if he is ultimately confirmed for the position a second time. The position of Attorney General is important in the immigration context for a variety of reasons, including the fact that the immigration courts and Board of Immigration Appeals (BIA) are part of the Department of Justice (DOJ), and the DOJ is responsible for defending the positions of the United States in federal court.

Matthew Whitaker will continue to serve as Acting Attorney General while Barr's nomination is pending before the United States Senate.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Tuesday, December 11, 2018

December 2018 Visa Bulletin and Adjustment of Status Filing Charts

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Introduction


On November 8, 2018, the U.S. Department of State published the Visa Bulletin for December 2018 [PDF version]. The Visa Bulletin for December 2018 — like all other visa bulletins — contains final action dates and dates for filing for the family-sponsored and employment-based preference categories for that month. Just five days after the publication of the December Visa Bulletin, the United States Citizenship and Immigration Services (USCIS) published good news for both family-sponsored and employment-based adjustment of status hopefuls, requiring both to use the filing dates for determining eligibility to apply for adjustment of status in December in lieu of the more restrictive final action dates [PDF version].

In this article, we will review the relevant charts, news, and notes from the December 2018 Visa Bulletin, with a focus on adjustment of status applicants.

If you are not familiar with the Visa Bulletins, please see our primer on the subject [see article]. For a discussion of the distinction between final action dates and filing dates, please see our article on that issue [see article]. Finally, to read about visa bulletins from past fiscal years, please see our index [see index].

Family-Sponsored Cases in the December 2018 Visa Bulletin


The USCIS is requiring family-sponsored adjustment of status applicants to use the dates for filing from the December 2018 Visa Bulletin. This marks the fifteenth straight month in which family sponsored applicants have been required to use the more favorable filing dates.

In order to be eligible to file for adjustment of status in December 2018, the applicant's priority date must be earlier than the applicable filing date cutoff for his or her family-sponsored preference category and chargeability area on the December 2018 Visa Bulletin. In family-sponsored cases, an applicant's filing date is generally the date on which the immigrant visa petition was properly filed on his or her behalf with the USCIS. Finally, in order to be eligible to apply for adjustment, the applicant must be otherwise eligible for adjustment of status under the applicable statutes and regulations.

Below are the family-sponsored filing dates from the December 2018 Visa Bulletin [see here].

For reference purposes, bellow are the final action dates from the December 2018 Visa Bulletin [see here].

Employment-Based Cases in the December 2018 Visa Bulletin


The USCIS is requiring employment-based applicants to use the filing dates from the December 2018 Visa Bulletin. This is a welcome change for the employment-based categories, which had been required to use the final action dates for ten out of twelve months in fiscal year 2017 and all of fiscal year 2018.

In order to be eligible to file for adjustment of status in December 2018, the applicant's priority date must be earlier than the applicable filing date cutoff for his or her family-sponsored preference category and chargeability area on the December 2018 Visa Bulletin. Determining the filing date in employment-based cases tends to depend on the type of petition in question. In cases where labor certification was required, the filing date is generally the date on which the labor certification application was accepted for processing by the U.S. Department of Labor (DOL). In cases where labor certification was not required, the priority date is generally the date on which the immigrant visa petition was properly filed on the beneficiary's behalf, much like family-sponsored cases. Separate from the visa bulletin dates, an applicant must be otherwise eligible to file for adjustment of status under the statutes and regulations.

Before continuing, there are two important notes about the Employment Fourth Preference Certain Religious Workers (SR) and the Employment Fifth Preference Categories (I5 and R5). These three categories require renewal by Congress to continue beyond December 7, 2018. If Congress does not extend the programs, no new visas will be able to be issued in these categories after December 7, 2018. The SR date would become unavailable on December 7, 2018, and the I5 and R5 dates would become unavailable on December 8, 2018. Extensions of these categories are tied to the broader effort to pass legislation to fund the government more broadly. It is possible that the categories will be allowed to lapse for a short period, but even in such a case, the lapse would likely be temporary. Individuals seeking visas in these categories — whether through consular processing or adjustment of status — should consult with their immigration attorneys for updates on the situation. We will update the website as more information becomes available.

Below are the employment-based filing dates from the Visa Bulletin for December 2018 [see here].

For reference purposes, below are the employment-based final action dates from the Visa Bulletin for December 2018 [see here].

Conclusion


Beneficiaries of approved preference petitions should stay abreast of the immigrant visa bulletin so that they will be ready to take action when it comes time to apply for a visa. This is especially important for adjustment of status applicants because they are required to actually apply for adjustment of status. An experienced immigration attorney can help immigrant visa applicants navigate the entire process both in consular processing and adjustment of status cases.

We will update this article with more information about SR, I5, and R5 cases if they are allowed to temporarily lapse.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Friday, December 7, 2018

Immigration Aspects of New Trump Memorandum on Cuba Policy

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On June 16, 2017, President Donald Trump issued a memorandum to his administration titled “Strengthening the Policy of the United States Toward Cuba.” On October 20, 2017, the memo was published in the Federal Register (FR) at 82 FR 48875 [PDF version]. In this post, we will examine in brief the provisions of the memo that implicate U.S. immigration policy. We will also reference more recent and related developments involving immigration and Cuban nationals. Those who are interested in learning about what the memo has to say regarding U.S. policy toward Cuba generally, including on travel to Cuba, may read the memo as published in the Federal Register (see above link).

In section 2(e) of the memo, President Trump stated that it is the policy of the executive branch to not reinstate the “Wet Foot, Dry Foot” policy, taking the position that it had “encouraged untold thousands of Cuban nationals to risk their lives to travel unlawfully to the United States.” The Wet Foot, Dry Foot policy had been rescinded by the administration of President Barack Obama weeks before President Trump took office [see blog]. The new memo makes clear that the Trump Administration will not reinstate the policy. In section 3(j), President Trump directed the Secretary of State and the Secretary of Homeland Security to “continue to discourage dangerous, unlawful migration that puts Cuban and American lives at risk.”

In section 2(d) of the memo, President Trump stated that it would be the policy of the executive branch to support the Cuban people through various means. Among the items on the list was his statement that it would be the policy of the executive branch to support the expansion of lawful travel for Cubans.

However, subsequent to the issuance of the memo, the United States removed most of its embassy staff out of Cuba due to mysterious attacks that caused American diplomatic employees to suffer neurological impairment and hearing loss. Accordingly, the Embassy in Havana is not issuing visas as of the writing of this article. Nevertheless, Cubans may still seek visas to lawfully enter the United States at posts outside of Cuba.

In section 2(f) of the memo, President Trump stated that it would be the policy of the executive branch to enforce final orders of removal against Cuban nationals in the United States. Notably, Cuba has been identified as a country that has been recalcitrant in accepting the return of its nationals subject to final orders of removal [see blog].

The memo thus provides a few interesting updates on the Trump Administration's policy toward Cuba regarding immigration. It suggests that the Trump Administration will look to handle immigration from Cuba in the same manner it handles immigration issues involving other foreign nationals, continuing a shift from the Obama Administration in this area. This notably includes the decision to not bring back the “Wet Foot, Dry Foot” policy and to work to enforce final orders of removal against Cuban nationals subject to such orders in the United States. However, because of the complicated diplomatic situation between the United States and Cuba, the situation remains in flux. We will continue to update the website with information of interest for Cuban nationals in the U.S. immigration context. Those with specific questions should consult with an experienced immigration attorney for guidance.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Thursday, December 6, 2018

Ukrainian Government Requests that U.S. Adoptive Parents Submit Required Post-Adoption Reports

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On October 2, 2017, the U.S. Department of State issued a notice reminding adoption service providers and adoptive parents of Ukrainian children to comply with Ukraine's post-adoption reporting requirements [PDF version].

The DOS explained that under the Ukrainian Family Code, all adoptive parents of Ukrainian children are required to provide post-adoption reports in each of the three years after an adoption is finalized. Subsequently, the adoptive parent must provide one report every three years until the adoptive child obtains the age of eighteen.

The report must include information on the child's:

  • General welfare;
  • Education;
  • Upbringing; and
  • Health.

The report form may be found on the Ukrainian Ministry for Foreign Affairs' website. Post-adoption reports may be submitted either by email or my regular mail to the Ukrainian Embassy or Consulate in the adoptive family's jurisdiction.

The Ukrainian government informed the DOS that there are currently over 1,500 outstanding post-adoption reports that have not been submitted by U.S. adoptive parents of Ukrainian children. In response to the high number of outstanding post-adoption reports, the Ukrainian Ministry of Social Policy commenced a commission to review its intercountry adoption policy. The DOS stated that since this review began, prospective adoptive parents have reported process delays.

The DOS strongly advised adoptive parents of children from Ukraine to cooperate with Ukraine's post-adoption reporting requirements. The DOS stated that “[y]our cooperation in filling these mandatory reports will help ensure that intercountry adoptions can continue with Ukraine.”

In the case of Ukraine, it appears that U.S. parents seeking to adopt children from the Ukraine may already be facing delays due to the high number of post-adoption reports that have yet to be submitted. In addition to being required under Ukrainian law, it is very important for adoptive parents of children from Ukraine to comply with post-adoption reporting requirements in order to ensure that U.S. parents will continue to be able to adopt children from Ukraine. The reporting requirements are hardly arduous, and complying with them will go a long way toward the placement of Ukrainian children in the future in homes in the United States.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Wednesday, December 5, 2018

Overview of Border Security Statistics for FY 2017

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On December 5, 2017, the United States Customs and Border Protection (CBP) published the Southwest Border Migration statistics for fiscal year 2017 [PDF version]. The Department of Homeland Security (DHS) also released national border security statistics. The fiscal year ran from October 1, 2016 to September 30, 2017. In this blog, we will examine the CBP statistics including thoughts on the numbers from leading figures at the Department of Homeland Security (DHS).

Sharp Decrease in Apprehensions at the Southwest Border


In total, 303,916 aliens were apprehended at the Southwest Border in FY 2017. This represented a decrease of 111,900, or 24%, from the 415,816 apprehensions in FY 2016. As we will see later in the post, the overall number of apprehensions in FY 2017, of which 98% occurred along the Southwest Border, were the lowest since FY 1971.

The following chart breaks down the number of apprehensions in FY 2017 by month [see here].

The early months of FY 2017 saw an unusually high number of apprehensions relative to recent trends. However, after the inauguration of President Donald Trump, the number of apprehensions decreased sharply, with April representing the lowest number in years [see blog]. After the nadir in April, the number of apprehensions gradually increased each month through the end of the fiscal year, which is generally expected to occur during the summer months. Nevertheless, the monthly totals remained lower than they have generally been in previous years.

It is worth noting that the number of unaccompanied alien children and family units apprehended at the border increased sharply starting in June and peaking in August 2017.

Lower than Average Number of Inadmissibles at the Border


In FY 2017, 111, 275 individuals presented themselves at ports of entry on the Southwest Border and were deemed inadmissible. Although low, the number of inadmissibles at the border was not as far out of step with recent annual trends as was the number of apprehensions. The 111,275 inadmissibles in FY 2017 was a sharp decrease from the 150,825 in FY 2016, but it was nearly identical to the 114,486 in FY 2015 and slightly more than the 90,601 in FY 2014.

The following chart breaks down the number of inadmissibles in FY 2017 by month [see here].

The trend line for inadmissibles was similar to that for apprehensions. There was a significant drop-off in the number of inadmissibles during February, the first full month of the Trump Administration. The two months that saw the fewest number of inadmissibles were March and April, with March seeing the fewest at 4,393 [see blog]. From May on, the number increased each month through the end of the fiscal year. Similarly to the apprehensions, unaccompanied alien children and family units comprised a larger proportion of total inadmissibles as the overall number increased during the course of the summer.

Apprehension and Inadmissibles Statistics from FY 2012 to FY 2017


The following, courtesy of the CBP, are the month-by-month statistics for apprehensions and inadmissibles at the Southwest Border over the previous six fiscal years [see here].

From October to January, FY 2017 saw more apprehensions and inadmissibles in each month than during the same period of any of the five previous fiscal years. However, beginning with President Trump's first full month in office, FY 2017 had the fewest combined apprehensions and inadmissibles during each month in the same sample through the end of the fiscal year. The numbers in March, April, May, and June were dramatically lower than in any of the corresponding months in the previous five fiscal years. However, in September 2017, the number of inadmissibles and apprehensions was, while lower, closer to the numbers recorded in September in FY 2012 through FY 2015.

National Statistics and Comments from DHS


The DHS discussed the statistics in a year-end press release [PDF version].

Above, we discussed statistics for the Southwest Border only. Overall, the DHS reported that nationwide there were 310,531 apprehensions by the CBP and 216,370 inadmissible cases. This represented a 23.7% decrease from FY 2016. The DHS noted that there was an especially sharp decrease from January 21, 2017 — President Trump's first full day in office — through April 2017. It added that April 2017 “was the lowest month of border enforcement activity on record” [see blog].

The Acting Deputy Commissioner of CBP, Ronald Vitiello, noted the “historic low numbers” of apprehensions in FY 2017. However, he expressed concern “about the later month increases of unaccompanied minors and minors with a family member.” Furthermore, he also expressed concerns “about the significant uptick in the smuggling of opioids and other hard narcotics … which generally increase when illegal border crossing spike.”

The CBP also expressed concern with the increase of family unit and unaccompanied alien children apprehensions and inadmissible cases over the latter months of FY 2017. To this effect, it stated that it “continues to be concerned about steady increase in the flow of unaccompanied children and family units from Central America, as transnational criminal organizations continue to exploit legal and policy loopholes to help illegal aliens gain entry and facilitate their release into the country.”

Lowest Number of Apprehensions Overall in 45 Years


Not only were the 310,531 apprehensions a stark decrease from FY 2016, but it also represented the fewest apprehensions in 45 years since the 302,517 in FY 1971 [PDF version]. Although there has been spikes, the trend in apprehensions has been positive over the past decade. Between FY 1983 and FY 2006, all but four years saw at least 1,000,000 apprehensions at the Southwest Border. Since FY 2007, the highest number was 876,704 in FY 2007. Prior to FY 2017, the low-water mark was 337,117 apprehensions in FY 2015, nearly 8% more apprehensions than the new low in the past fiscal year.

Analysis


It is clear that the number of apprehensions and inadmissibles decreased sharply when President Trump initially took office, and decreased dramatically in the spring. This downtick is interesting since many of the policies set forth in President Trump's January 25, 2017 executive orders on border security and interior enforcement and the implementing memoranda from February 20, 2017, have yet to be fully implemented [see article]. For example, the Trump Administration has not been able to make meaningful progress on a border wall nor has it announced or fully implemented new policies regarding expedited removal or unaccompanied alien children. Interestingly, the Department of Justice (DOJ) has been active in announcing new policies to increase prosecutions for alien smuggling and move immigration judges to locations in close proximity to the Southwest Border [see article].

While the border security statistics are promising, especially regarding apprehensions at the Southwest Border, it is important to note that it is unknown whether the trend is sustainable. For example, the summer months of FY 2017 saw disproportionately large increases in the number of apprehensions and inadmissibility determinations for family units and unaccompanied alien children. Furthermore, the number of drug trafficking cases did not decrease in numbers commensurate with the decrease in illegal border crossings and, in fact, increased in some months.

It is also worth considering, going forward, how much of the decrease in illegal border crossings and inadmissibility determinations was due to actual policy changes by the Trump Administration, and how much of it was due to perceived or feared policy changes. In either case, the position of the Trump Administration going forward and the manner in which it seeks to implement new policies in President Trump's executive orders will likely have a key role in whether the number of illegal border crossings continues to decrease or returns to pre-Trump levels. Another issue that bears watching is whether Congress passes a legislative replacement for the outgoing Deferred Action for Childhood Arrivals (DACA) program, and which, if any, new border security and interior enforcement measures accompany it.

We will continue to update the website with information about interesting immigration enforcement statistics and important developments in immigration law and policy during the Trump Administration going forward.

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.

Lawyer website: http://myattorneyusa.com

Tuesday, December 4, 2018

USCIS Not Considering Changes to Extensions of H1B Stay Beyond 6-Year Limit

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On December 30, 2017, McClatchy DC Bureau reported that the Trump Administration was considering a draft memorandum that would reinterpret the language of AC21 [see category] to stop granting extensions of stay beyond the 6-year limit for H1B visa-holders with pending immigrant visa petitions.[1] I learned about this news because many individuals on Quora, a popular question and answer site, asked questions about the report.

In response to the questions, I urged caution against overreacting to the report. First, I stated that “whatever whoever says on the subject at this point is not even a conjecture but pure speculation.”[2] After reading a few other reports on the issue, I noted that “the provision allowing for H1B extensions beyond the six-year limit originates in the statute…” and that, while I could see less drastic changes to the implementation of the AC21 provision, changes of the sort discussed in the report would likely require Congressional action in any case.[3]

Unsurprisingly, prudence proved to be the best course. On January 9, 2018, the United States Citizenship and Immigration Services (USCIS) responded to McClatchy by stating that it “is not considering a regulatory change that would force H-1B visa holders to leave the United States by changing our interpretation of section 104(c) of AC-21, which provides for H-1B extensions beyond the 6 year limit.”[4] Furthermore, the USCIS added that any suggestion that it was considering such a change was “absolutely false.”

It is worth noting that McClatchy stands by its original report, suggesting that the Trump Administration had only reversed course on the proposal due to external pressure that mounted after its reporting. However, for reasons that I addressed in response to questions about the original report, the news that the USCIS is ultimately not considering this proposal is unsurprising.

The USCIS statement will come as a relief to those who would have been negatively affected by the draft memo as described in the original McClatchy report. However, this entire story highlights why it is important to be cautious about jumping to conclusions about potential changes in immigration policy based on reports citing to anonymous sources about draft memoranda. To be sure, reports can end up being accurate (for example, several outlets reported that the Trump Administration would rescind the Deferred Action for Childhood Arrivals (DACA) program before the official announcement was made). Yet other reports that had caused panic turned out to be all smoke and no fire. Some readers may recall the report last year that the Trump Administration was seriously considering a draft memo that would have dramatically expanded the definition of “public charge.”[5] In truth, while outlets did obtain a draft memo, it is highly likely that it was never seriously considered by the upper levels of the White House or the DHS.

With reports such as these, it is important to remember that the existence of a “draft memo” does not necessarily mean that something is seriously under consideration. The White House, much less the DHS, contains a large bureaucracy. Many proposals are drafted by many people, and more memos and ideas are discussed than the few that make it high up the chain of command and receive serious consideration by the people who count. For this reason, we should always respond to reports with caution and consider all available information. In the end, nothing is known for sure until the relevant agency makes an official announcement on the matter.

Those who are concerned about how a potential change may affect them are well-advised to consult with an experienced immigration attorney for case-specific guidance.

Finally, while my colleagues and I will often answer questions on sites such as Quora and Avvo, I would like to remind you that our own site includes a form for submitting a quick legal question. If you have a quick legal question about a specific issue, please us our form to ask our experienced immigration attorneys [see form].

Please visit the nyc immigration lawyers website for further information. The Law Offices of Grinberg & Segal, PLLC focuses vast segment of its practice on immigration law. This steadfast dedication has resulted in thousands of immigrants throughout the United States.
  1. Ordonez, Franco. “DHS weighs major change to H-1B foreign tech worker program.” McClatchy DC Bureau. Dec. 31, 2017. http://www.mcclatchydc.com/news/politics-government/white-house/article192336839.html
  2. Segal, Alexander. “Re; Is DHS planning to stop the H-1B extension beyond six years using an I-140?” Quora. Jan. 2, 2017. https://www.quora.com/Is-DHS-planning-to-stop-the-H-1B-extension-beyond-six-years-using-an-I-140
  3. Segal, Alexander. “Re; What would be the impact of this news that DHS is thinking of not giving H-1B extensions for those whose green cards are pending? They are thinking of automatically deporting H-1B holders after their 6 years?” Quora. Jan. 2, 2017. https://www.quora.com/What-would-be-the-impact-of-this-news-that-DHS-is-thinking-of-not-giving-H-1B-extensions-for-those-whose-green-cards-are-pending-They-are-thinking-of-automatically-deporting-H-1B-holders-after-their-6-years
  4. Ordonez, Franco. “Under pressure, Trump team backs off proposal to cull foreign tech workforce.” McClatchy DC Bureau. Jan. 8, 2017. http://www.mcclatchydc.com/news/politics-government/white-house/article193665104.html
  5. Hauslohner, Abigail and Janell Ross. “Trump administration circulates more draft immigration restrictions, focusing on protecting U.S. jobs.” Washington Post. Jan. 31, 2017. https://www.washingtonpost.com/world/national-security/trump-administration-circulates-more-draft-immigration-restrictions-focusing-on-protecting-us-jobs/2017/01/31/38529236-e741-11e6-80c2-30e57e57e05d_story.html
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