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BIA on 204(c) (unpub.)

"To the extent that the beneficiary's former spouse may not have been legally free to marry her at the time of their marriage, the Director should address the applicability of section 204(c) of the Act in such an instance. We note that section 204(c) of the Act does not apply to fraud based...

BIA on Togo, Asylum: Matter of K-G-H- (Unpub.)

Charles Shane Ellison writes: "[The BIA] reversed IJ finding that a fundamental change in circumstances had occurred in Togo such that would rebut the presumed well-founded fear of an asylum applicant who had suffered past persecution. The BIA also found that even if such a change existed, the IJ...