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Immigration Law

Castro-Tum Overruled: Matter of Cruz-Valdez

Matter of Cruz-Valdez, 28 I&N Dec. 326 (A.G. 2021)

(1) Matter of Castro-Tum, 27 I&N Dec. 271 (A.G. 2018), is overruled in its entirety.

(2) While rulemaking proceeds and except when a court of appeals has held otherwise, immigration judges and the Board should apply the standard for administrative closure set out in Matter of Avetisyan, 25 I&N Dec. 688 (BIA 2012), and Matter of W-Y-U-, 27 I&N Dec. 17 (BIA 2017).