Velázquez v. Bondi, No. 23-929 (U.S. Apr. 22, 2025)

• voluntary departure; service on the weekend; 60 day departure period; jurisdiction; INA § 242(a)(1); “days”; presumption that Congress legislates in harmony with what came before it

Matter of A-A-R-, 29 I&N Dec. 38 (BIA 2025)

• CAT deferral; former MS-13 members; state exception policy in El Salvador; experts; prison conditions; sharing criminal information with El Salvador; State Department reports; acquiesce and willful blindness; intent to torture; standard of review

Zhou v. Bondi, No. 24-3866 (6th Cir. Apr. 23, 2025)

• jurisdiction to review ineffective assistance of counsel motion to reopen; INA § 237(a)(1)(H) waiver; prejudice; discretion

Hussen v. Bondi, No. 23-1047 (4th Cir. Apr. 22, 2025)

• marriage during removal proceedings; prima facie standard for motion to reopen; clear and convincing evidence; reopening as an important safeguard; Muslim marriage; Matter of Velarde; credibility; Ethiopia

Oscar v. Bondi, No. 23-3858 (9th Cir. Apr. 23, 2025)

• offer of firm resettlement; prima facie case; exceptions – government consciously restricted residence; Haiti; Chile

Mendez Nolasco v. Bondi, No. 23-1947 (1st Cir. Apr. 23, 2025)

• non LPR cancellation of removal; exceptional and extremely unusual hardship; standard of review; inability of children to speak Spanish; Recinas; factors in the aggregate

Chanchavac Garcia v. Bondi, No. 24-1296 (1st Cir. Apr. 24, 2025)

• non-LPR cancellation of removal; special needs and loss of educational opportunities; BIA failure to consider evidence and explain analysis

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