Immigration Law

Recent Posts

CA9 on Motions to Reopen: Chandra v. Holder
Posted on 12 May 2014 by Daniel M. Kowalski

"We join our sister circuits and hold that a petitioner’s untimely motion to reopen may qualify under the changed conditions exception in 8 C.F.R. § 1003(c)(3)(ii), even if the changed country conditions are made relevant by a change in... Read More

CA5 on Birth Abroad at U.S. Military Base: Thomas v. Lynch
Posted on 10 Aug 2015 by Daniel M. Kowalski

"Thomas, who was born on a United States military base located in what is now Germany, argues that he is not removable because he is a United States citizen by virtue of the Fourteenth Amendment. For the following reasons, we DENY the petition for... Read More

OCAHO Reduces I-9 Fine from $54K to $27K - USA v. PM Packaging
Posted on 2 Jul 2015 by Daniel M. Kowalski

"[t]he proposed penalty of $53,762.50 is close to the maximum permissible of $55,000. Our case law consistently holds that penalties so close to the maximum should be reserved for more egregious violations than have been demonstrated here. See United... Read More

CA9 on Persecution: Sumolang v. Holder
Posted on 25 Jul 2013 by Daniel M. Kowalski

"Can a parent applying for asylum or withholding of removal show that she has been persecuted based on suffering or harm inflicted on her child? That question arises here because the strongest evidence supporting the claims of the petitioner, Berawati... Read More