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Admin Closure is Back - Matter of Castro‑Tum, 27 I&N Dec. 271 (A.G. 2018), is overruled entirely.


Matter of Cruz-Valdez, 28 I&N 271 (AG 2021)


Today, July 15, 2021, the Attorney General has issued a decision in 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).

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