Immigration Law

Recent Posts

Unpub. BIA Guatemalan Asylum Victory (Dec. 27, 2017)
Posted on 16 Jan 2018 by Daniel M. Kowalski

Camiel Becker writes: " I am writing to share a recent BIA win by Becker & Lee LLP attorney Melissa Phatharanavik . The case involves a Guatemalan man who was granted withholding of removal due to police corruption in Guatemala. An Immigration... Read More

CA4 on Asylum, Changed Circumstances - Romero Zambrano v. Sessions
Posted on 6 Dec 2017 by Daniel M. Kowalski

Romero Zambrano v. Sessions, Dec. 5, 2017 - "This Court agrees with the logic of the Ninth, Second, and Sixth circuits. New facts that provide additional support for a pre-existing asylum claim can constitute a changed circumstance. These facts may... Read More

CA2 on 'Changed Circumstances,' Asylum: Lin v. Holder
Posted on 21 Aug 2014 by Daniel M. Kowalski

"The statute states that an otherwise untimely asylum application “may be considered . . . if the alien demonstrates to the satisfaction of the Attorney General . . . the existence of changed circumstances which materially affect the applicant’s... Read More

Third Circuit on changed circumstances, jurisdiction: Nbaye
Posted on 21 Nov 2011 by Daniel M. Kowalski

"We have concluded that although we cannot decide the case on the basis that there has been a change in power in Guinea, our precedents and 8 U.S.C. § 1252(b)(4)(A) on the one hand and the seemingly appropriate way to proceed in this matter... Read More

Unpub. BIA Asylum Victory, 'Changed Personal Circumstances' - Matter of Chen
Posted on 14 Feb 2013 by Daniel M. Kowalski

"While we agree with the Immigration Judge that "changed personal circumstances" do not, in and of themselves, constitute an exception to the filing deadline for asylum, we recognize that changed personal circumstances may form the basis... Read More

CA9 on India, Changed Conditions: Singh v. Holder
Posted on 22 May 2014 by Daniel M. Kowalski

Majority: "The IJ and the BIA determined that the government showed that there has been a fundamental change in circumstances such that Singh’s life or freedom would not be threatened on account of his race, religion, nationality, membership... Read More