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Article: How to Challenge Gang Designations in Asylum Cases By Beau Baumann and Stephen Yale-Loehr*

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  • Article: How to Challenge Gang Designations in Asylum Cases By Beau Baumann and Stephen Yale-Loehr*

    How to Challenge Gang Designations in Asylum Cases

    by


    A familiar story plays out every week in U.S. immigration courts. A Latinx male has a removal hearing. The young man presents a plausible case for asylum or restriction on removal (better known as withholding of removal). To defeat the young man’s claims, the government produces a report alleging that he is a member of a gang. The report originated in a so-called “fusion” center. [1] The report is short on detail but invariably determines that the young man’s tattoos and social media accounts indicate gang membership. [2] The report relies on the immigrant’s red hat with the letter “B” on the front (never mind that it is a Chicago Bull’s hat). [3]

    Although gang membership is irrelevant to the young man’s claim, his testimony that he is not a gang member destroys his credibility in the eyes of the immigration judge. Alternatively, the immigration judge will deny the young man asylum as a matter of discretion on the basis of his purported gang membership. [4] Even if the young man is successful before the immigration judge, the government will appeal to the BIA. [5]

    The use of gang databases and gang designations is not new. Municipalities, states, and federal fusion centers have built a network of gang databases that are used in both the criminal and immigration systems. [6] Over the last ten years, immigration advocates have written about the use of gang designations in the contexts of both the deferred action for childhood arrivals (DACA) program and bond for detained immigrants. [7] While the Obama administration used gang designations in the immigration system, the Trump administration’s innovation is the use of these designations in asylum and withholding proceedings across the country.

    At the start of the current administration, the use of gang designations in asylum and withholding proceedings was obscured by the use of gang designations in the context of pre-trial bond. Over the last two years, Immigration and Customs Enforcement (ICE) has launched a series of raids targeting suspected gang members. In one such raid, “Operation Matador,” ICE officials arrested 475 alleged gang members in New York. [8] Some of the alleged gang members were unaccompanied minors, meaning that the government had to place them in the “least restrictive setting that is in the best interest of the child” under the Trafficking Victims Protection Reauthorization Act (TVPRA). [9] The Office of Refugee Resettlement initially determined that the plaintiffs were not threats to the public, and they were subsequently released. [10] Later, the government alleged that the plaintiffs were gang members, [11] and used these designations to rearrest the plaintiffs and transport them to a secure facility in California. [12] The American Civil Liberties Union later sued on behalf of minors swept up in Operation Matador. [13] The court issued a preliminary injunction after concluding that the government’s procedures did not justify rearresting and detaining the plaintiffs. [14]

    Increasingly, gang designations are playing a role in asylum and withholding proceedings. In a nationwide poll of immigration attorneys conducted by the Immigrant Legal Resource Center (ILRC), forty-three percent of respondents had at least one asylum or withholding case that involved a gang designation. [15] More anecdotally, unpublished and redacted opinions discussing gang designations have been slowly dripping out of the BIA and the immigration courts. [16] The ILRC has discussed these cases with practitioners and concluded that the gang designations are especially damaging in asylum cases because of how they impact the noncitizen’s credibility. [17] If a noncitizen attempts to contest a gang designation, an immigration judge will often defer to the government’s representations and find that the noncitizen lacks credibility.

    The rise of gang designations in asylum and withholding cases is troubling because of a reoccurring fact in the literature: gang designations and gang databases are fundamentally unreliable. [18] The spike in the use of gang designations across a variety of immigration contexts is directly related to the rise of a national network of gang databases. [19] Immigration designations are often made by local police, who then filter data up to local gang databases, state fusion centers, and other federal agencies like the Department of Homeland Security (DHS). [20]

    Unfortunately, almost every portion of this web is riddled with errors. The Chicago Police Department’s gang database was recently revealed to be prone to errors. [21] An audit of California’s gang database revealed that twenty-three percent of the database’s designations were unsupported, that hundreds of designations were improperly maintained, and that seventy percent of designated juveniles received no notice from the state. [22] Gang reports produced by federal “fusion centers” have also come under scrutiny. [23]

    The inaccuracies of gang designations have several downstream effects. First, the errors from gang designations disproportionately affect immigrants and young men of color. [24] Because immigrant communities are disproportionately affected, designations have become a key tool for DHS and ICE. [25] Second, gang designations perpetuate the harmful stereotype of the criminal immigrant. [26] Both effects are immutable and flow from the fact that defining gang membership is a notoriously difficult and subjective enterprise. [27]

    Gang designations in asylum and withholding cases are often difficult to challenge in immigration courts. Gang designations are often supported by form documents that rely on social media posts, tattoos, and clothing. [28] One redacted designation report alleged that a Latinx noncitizen was a member of MS-13. [29] This report was only supported by (1) a picture of the noncitizen with a Chicago Bull’s hat, (2) a picture of the noncitizen wearing Nike Cortez shoes, (3) a Boston police officer’s assessment, and (3) a social media post where the noncitizen appears to be making a “peace” hand gesture. [30] A comparison with other reports indicates that it was largely a form document. [31] Despite the weakness behind many gang designations, many are used to deny asylum and withholding of removal. [32]

    A new program started by the Trump administration exacerbates issues surrounding gang designations. On July 8, 2019, ProPublica published an article alleging that federal officials are relying on a transnational gang database to detain noncitizens at the border and separate families. [33] According to ProPublica, officials at the border use data collected by Salvadoran police and military officials to detain purported gang members. In one case, an erroneous gang designation in the system caused U.S. authorities to separate a man from his two children and detain him in a maximum-security facility. [34]

    The scope of this transnational gang database is unknown because the government has hidden it from the public. The database is instead managed by a fusion center called Grupo Conjunto de Inteligencia Fronteriza (GCIF). [35] ProPublica later reported that GCIF had expanded the database into Guatemala, Mexico, and Honduras. [36] Immigration advocates now must navigate not only the complex web of domestic databases and fusion centers, but also the GCIF database and foreign designations. The GCIF database will likely become an important fixture in asylum proceedings.

    Several characteristics of asylum and withholding proceedings create difficult, but navigable, barriers. Because these are civil proceedings, the Constitution’s Confrontation Clause is not a proper basis for excluding designation reports that rely on unnamed and vague third party testimony. Additionally, immigration judges may be unfamiliar with the inaccuracies that plague gang databases and will accordingly give designations undue weight. Furthermore, the DHS has repeatedly introduced gang designations in cases involving persons with borderline competency issues. [37] These individuals have the additional burden of cognitive issues when testifying that they do not belong to a gang.

    Despite these hurdles, immigration attorneys have successfully countered gang designations in several cases. The goal of attorneys should either be to (1) exclude gang designations or (2) bolster their client’s denials of gang membership so that an immigration judge will not make an adverse credibility finding. Although the Federal Rules of Evidence do not apply in immigration courts, immigration attorneys have experimented with challenging the introduction of gang-related evidence. [38] For tips on excluding gang reports and for a helpful guide to the mechanics of challenging gang designations in immigration court, attorneys should review the toolkit produced by CUNY School of Law’s Immigrant & Non-Citizen Rights Clinic (INRC). [39]

    The following routes for challenging gang designations have emerged in a few cases and may supplement the approaches outlined by the INRC.

    First, there are federal privacy regulations that, if violated by a gang database, may weaken a designation submitted by the government. In a redacted case from the Boston Immigration Court, immigration judge Mario Sturla granted the respondent’s application for adjustment of status despite the government’s submitted gang designation. [40] Judge Sturla’s opinion was influenced by the expert testimony of Professor Thomas Nolan, who pointed out that the relevant gang database used for the designation did not comply with 28 C.F.R. § 23. [41] That regulation governs the communication of information having to do with criminal charges. It was implemented to assuage concerns that “the collection and exchange of intelligence data necessary to support control of serious criminal activity may represent potential threats to the privacy of individuals.” [42] The regulation specifically requires that designations in gang databases be supported by “reasonable suspicion or criminal predicate.” [43] Professor Nolan testified that there was no evidence supporting the gang designation’s conclusory assessment and that the government’s designation was entitled to very little weight. [44] For instance, the government concluded that the respondent was a gang member because he had a “503” tattoo, but the government failed to explain the connection between the tattoo and gang membership. [45] Ultimately Judge Sturla accepted Professor Nolan’s testimony, concluding that the gang designation was unreliable. [46] Even though the regulation was promulgated for the criminal context, it was successfully used to suggest that DHS’s reliance on the relevant gang database in an immigration case was unreliable.

    Second, criminologists are increasingly being used as expert witnesses to combat gang designations. Criminologists can support an 28 C.F.R. § 23 argument (like Professor Nolan, as discussed above) or they can combat the evidence of gang affiliation directly. In a DACA case, for instance, an expert named Martin Flores testified that the government incorrectly evaluated a noncitizen’s tattoos. [47] In that case, the court gave Mr. Flores’ testimony significant weight. However, experts who can accurately attest to gang membership are rare. The same issues that make gang databases unreliable—the fluid nature of gangs and the subjective criteria for evaluation—mean that true experts are rare, limiting the availability of expert testimony.

    Third, reports detailing the inaccuracies of gang databases area increasingly available and can be used to argue that gang designations arising from certain gang databases should be excluded. Public audits of gang databases are available at the state and local level. [48] They are usually produced by neutral public officials and have uniformly found massive errors. Where possible, immigration attorneys should submit these reports and audits to immigration judges to contextualize the issues surrounding gang databases.

    Fourth, consider a procedural due process challenge to the use of hearsay gang designations. While the Federal Rules of Evidence do not apply in immigration proceedings, the use of hearsay to support a gang designation could be so extreme as to be fundamentally unfair and thus violate due process. [49]

    Fifth, consider requiring the government to provide proof of the reliability of the gang allegation report in immigration court. Both the immigration statute and some federal courts have recognized that immigrant respondents have the right to cross-examine adverse witnesses in certain situations. [50] Also, immigration judges have regulatory authority to issue subpoenas for documents and witnesses. [51] Immigration judges may be reluctant to issue such subpoenas, but you have a right to ask for them.

    The impact of these reports will be greater depending on how direct they are. For instance, a case turning on a designation from California should cite the CalGang audit. [52] If no government-produced reports are available that apply to the relevant gang database, media reports may provide an alternative (although we suspect that these press findings will be less impactful). [53] Immigration attorneys should also support the grassroots movements across the country for more audits and studies of error-rates such as the CalGang-specific audit performed by the state. [54] These efforts are churning out an increasing number of reports that will be useful in a variety of immigration contexts.

    With these options in mind, it is important to recognize that gang designations are likely to play an outsized role in several immigration contexts for the foreseeable future—at least, until more systematic litigation is successful. Although many of these tools have been successful in isolated cases, immigration judges are very likely to admit gang designations. [55] This reality is precisely why immigration attorneys must systematically litigate the inherent flaws in gang designations. In the DACA context, a federal court in Washington state recently held that DHS’ reliance on gang designations with little or no evidence was arbitrary and capricious under the Administrative Procedure Act (APA). [56] Given that gang databases have been shown to be error-prone in most studies, reliance on them when deporting nonimmigrants may reflect an absence of the “reasoned decisionmaking” required by a line of cases in the immigration context. [57] Reliance on such gang databases may also fail the “clear and convincing” evidence requirement in removal proceedings. [58]

    The designations produced by the new GCIF database may be especially susceptible to challenges. In one case, a GCIF designation caused U.S. authorities to separate a man from his family and detain him in a maximum-security facility for months. [59] In that case, the man’s family in El Salvador tracked down his criminal record and discovered that there was an active gang member with the same name. [60] When the man’s attorney discovered this information, the government made no attempt to support the gang designation, apparently not wanting to shed light on this still secretive program. [61] Usually, the government continues to use designations when they are challenged in immigration court. The government’s surrender in this case indicates that DHS is not eager to litigate the still-secretive database, perhaps because foreign designations will not be entitled to the same deference as domestic ones. For that reason, litigation focusing on the accuracy of foreign designations may be especially effective.

    Until the DHS’ reliance on erroneous gang designations is challenged directly, immigration attorneys must continue to explore new ways of combating such designations.

    Copyright © 2019 Beau Baumann and Stephen Yale-Loehr. All rights reserved. This article originally appeared in 24 Bender's Immigr. Bull. 1169 (Oct. 1, 2019).



    [1] See Nat’l Security Council, National Strategy for Information Sharing: Successes and Challenges in Improving Terrorism-Related Information Sharing (2007), https://georgewbush-whitehouse.archi...ing/index.html (describing the trend towards “fusion centers,” whose purpose is to “develop . . . national networks that promote . . . the adoption of vertical information sharing between federal, state and local agencies.”; U.S. Dep’t of Homeland Sec., Fusion Centers, https://www.dhs.gov/fusion-centers (“Fusion Centers are state-owned and operated centers that serve as focal points in states and major urban areas for the receipt, analysis, gathering and sharing of threat-related information between State, Local, Tribal and Territorial (SLTT), federal and private sector partners.”).

    [2] See, e.g. , Matter of [name not provided], File No. A205-734-146 (BIA Dec. 17, 2018) (discussing a gang designation supported by the clothes the respondent was wearing and the accusations of an anonymous source), available at https://drive.google.com/file/d/1P-r...ew?usp=sharing.

    [3] See Jonathan Blitzer, How Gang Victims Are Labelled As Gang Suspects, The New Yorker (Jan. 23, 2018), https://www.newyorker.com/news/news-...-gang-suspects (“One student was . . . detained by ICE because he posted a Salvadoran flag on his Facebook page; another was caught wearing a Chicago Bulls T-shirt to school.”); Sarah Betancourt, Boston Police Face Lawsuit Over Listing Hats and Selfies as Gang Symbols , The Guardian (Nov. 21, 2018), https://www.theguardian.com/us-news/...grants-lawsuit (“For [the] Boston police department, the Chicago Bulls hat was a sign.”).

    [4] See Matter of V-A-C- (BIA Nov. 15, 2017) (reversing an immigration judge who used discretion to deny a designated gang member’s cancellation of removal)), available at https://drive.google.com/file/d/1olk...ew?usp=sharing.

    [5] See Immigr. Legal Resource Ctr., Understanding Allegations of Gang Membership/Affiliation in Immigration Cases 1 (2017), available at https://www.ilrc.org/sites/default/f...y-20170509.pdf (noting that immigrants with gang designations have become an enforcement priority for the Department of Homeland Security).

    [6] See Beau J. Baumann & Greg Mina, Note, Clowning Around With Final Agency Action, 28 Cornell J. L. & Pub. Pol’y 329, 330–31 (2019) (describing the rise of interconnected gang databases under the post-9/11 national security apparatus).

    [7] See, e.g. , Katherine Conway, Fundamentally Unfair: Databases, Deportations, and the Crimmigrant Gang Member , 67 Am. U. L. Rev. 269 (2017) (describing the system of gang designations used by the Obama and Trump administrations to target alleged gang members); K. Babe Howell, Fear Itself: The Impact of Gang Affiliation on Pre-Trial Detention , 23 St. Thomas L. Rev. 620 (2011) (impact on pre-trial detentions); Rebecca A. Hufstader, Note, Immigration Reliance on Gang Databases: Unchecked Discretion and Undesirable Consequences , 90 N.Y.U. L. Rev. 671 (2015) (impact in the context of DACA).

    [8] See Preston Huennekens, Operation Matador Nabs 475 Gang Members in N.Y. City Area, Ctr. For Immigr. Studies (Apr. 4, 2018), https://cis.org/Huennekens/Operation...s-NY-City-Area.

    [9] Trafficking Victims Protection Reauthorization Act. Pub. L. No. 110–457, § 235, 122 Stat. 5044, 5074–82 (2008) (codified at 8 U.S.C. § 1232).

    [10] See Saravia v. Sessions, 280 F. Supp. 3d 1168, 1179 (N.D. Cal. 2017).

    [11] See id. at 1178–80.

    [12] See id.

    [13] Saravia v. Sessions, 905 F.3d 1137 (9th Cir. 2018).

    [14] Id.

    [15] Immigrant Legal Resource Ctr., Deportation By Any Means Necessary: How Immigration Officials are Labeling Immigrant Youth as Gang Members 7 (2018), available at https://www.ilrc.org/deportation-by-any-means-necessary [hereinafter ILRC Report].

    [16] See, e.g. , Matter of [name not provided], File No. A205-734-146 (BIA Dec. 17, 2018) (discussing a gang designation in the bond context), available at https://drive.google.com/file/d/1P-r...w?usp=sharing; Matter of V-A-C- (BIA Nov. 15, 2017) (evaluating an immigration judge’s reliance on the respondent’s designation as an “active criminal gang member”), available at https://drive.google.com/file/d/1olk...ew?usp=sharing.

    [17] ILRC Report, supra note 15, at 8.

    [18] See, e.g. , Joshua D. Wright, The Constitutional Failure of Gang Databases, 2 Stan. C.R. & C.L. 115 (2005).

    [19] See Baumann & Mina, supra note 6, at 330.

    [20] See id.

    [21] City of Chicago Office of Inspector General, Review of the Chicago Police Department’s “Gang Database” 2 (2019), https://igchicago.org/wp-content/upl...ase-Review.pdf (“Over 15,000 individuals designated as gang members by CPD had no specific membership listed and no reason provided for why the individual was listed as a gang member.”).

    [22] California State Auditor, The CalGang Criminal Intelligence System 2, 4 (2016), https://www.auditor.ca.gov/pdfs/reports/2015-130.pdf.

    [23] See Baumann & Mina, supra note 6, at 330–33 (discussing legal challenges to a federal fusion center’s decision to label fans of a heavy metal ban as gang members).

    [24] Sean Garcia-Leys et al., Univ. Cal. Sch. L. Immigrant Rights Clinic, Mislabeled: Allegations Of Gang Membership and Their Immigration Consequences 1 (2016), available at https://drive.google.com/file/d/1UXC...ew?usp=sharing (“This high risk of error is corroborated by the fact that these allegations are overwhelmingly made against African-Americans and Latinos.”).

    [25] See Mick Dumke, Chicago’s Inspector General Finds the City’s Gang Database is Riddled with Errors , ProPublica (Apr. 11, 2019), https://www.propublica.org/article/c...general-report (noting that immigration authorities have accessed the Chicago Police Department’s gang database 32,000 times over the last ten years).

    [26] See Conway, supra note 7, at 272–73 (linking trends in immigration enforcement with the stereotype of the “crimmigrant”).

    [27] See, e.g. , Vasquez v. Rackauckas, 734 F.3d 1024, 1046 (9th Cir. 2013) (“Determining whether an individual is an active gang member presents a considerable risk of error. The informal structure of gangs, the often-fleeting nature of gang membership, and the lack of objective criteria in making the assessment all heighten the need for careful factfinding.”).

    [28] Blitzer, supra note 3 (detailing officials’ focus on Chicago Bulls hats and social media posts); see also CUNY School of Law Immigrant & Non-Citizen Rights Clinic, Swept up in the Sweep: The Impact of Gang Allegations on Immigrant New Yorkers 21 (2018), https://www.law.cuny.edu/wp-content/...rt_Final-1.pdf (“These allegations are seldom corroborated by independent evidence and thus the evidence presented raises serious reliability issues in any court of law.”) (internal citation omitted).

    [29] See ILRC Report, supra note 15, Appendix B.

    [30] Id.

    [31] See New York Civil Liberties Union et al., Stuck with Suspicion: How Vague Gang Allegations Impact Relief & Bond for Immigrant New Yorkers 3, 15 (2019), available at https://www.nyclu.org/sites/default/...c-report_0.pdf (giving a formula that gang designations seem to invariably follow).

    [32] An immigration judge can deny an asylum case on several grounds, including a lack of credibility or as a matter of discretion. While an immigration judge cannot deny withholding of removal as a matter of discretion, ICE allegations of an applicant’s gang involvement in their home country could convince the judge to deny the applicant withholding of removal because there are “serious reasons to believe” that the immigrant has committed a “serious non-political crime outside of the United States.” INA 241(b)(3)(B)(iii), 8 U.S.C. § 1231(b)(3)(B)(iii); Matter of E-A-, 26 I. & N. Dec. 1 (BIA 2012).

    [33] Melissa del Bosque, Immigration Officials Use Secretive Gang Databases to Deny Migrant Asylum Claims , ProPublica (July 8, 2019), https://www.propublica.org/article/i...-asylum-claims.

    [34] Id. (“An attorney in Texas recently discovered that her Salvadoran client had been falsely accused of being in the MS-13 gang based on intelligence from the center. The man was jailed in a maximum-security facility . . . for six months, and his two children were taken away.”).

    [35] See id.

    [36] Melissa del Bosque, The Case That Made an Ex-ICE Attorney Realize the Government was Relying on False “Evidence” Against Migrants , ProPublica (Aug. 13, 2019), https://www.propublica.org/article/l...ainst-migrants).

    [37] See, e.g. , Matter of [name redacted] (IJ Mario Sturla, Boston, Mass. June 22, 2018), available at https://drive.google.com/file/d/1sPH...ew?usp=sharing) (last visited Sept. 1, 2019) (finding that a noncitizen’s gang designation was not sufficiently supported by the evidence) (on file with authors) [hereinafter Matter of [name redacted]).

    [38] Maya Leszczynski et al., CUNY School of Law, Evidentiary Objections to Challenge Commonly Introduced Evidence Used in Support of Gang Allegations (July 2019), https://www.law.cuny.edu/wp-content/...tions_2019.pdf.

    [39] CUNY School of Law, Toolkit to Challenge Gang Allegations against Immigrant New Yorkers , https://www.law.cuny.edu/academics/c...rkers-toolkit/.

    [40] See Matter of [name redacted], supra note 37, slip op. at 30–31.

    [41] Id. at 29 (discussing the expert testimony of Professor Thomas Nolan).

    [42] 28 C.F.R. § 23.20; see also Benjamin E. Rosenberg, Statutory and Constitutional Limitations on the Preservation of Evidence , 4 Va. J. Crim. 116, 126–29 (2016) (discussing when 28 C.F.R. § 23 applies and what limitations it places on the government).

    [43] 28 C.F.R. § 23.20(c).

    [44] Matter of [name redacted], supra note 37, slip op. at 30-31.

    [45] Id.

    [46] See id. at 29.

    [47] Medina v. U.S. Dep’t of Homeland Sec., 313 F. Supp. 3d 1237, 1250 (W.D. Wash. 2018).

    [48] See, e.g. , City of Chicago Office of Inspector General, supra note 21; California State Auditor, supra note 22.

    [49] See generally Charles Gordon et al., Immigration Law and Procedure § 71.02[3][b] (discussing procedural due process requirements in removal proceedings).

    [50] INA § 240(b)(4)(B); 8 U.S.C. § 1229a(b)(4)(B); see also Karroumeh v. Lynch, 820 F.3d 890, 897 (7th Cir. 2016) (finding that respondent’s procedural right to cross-examination was violated where government failed to make a “reasonable effort” to secure a witness’ presence in court for cross-examination); Ching v. Mayorkas, 725 F.3d 1149, 1158 (9th Cir. 2013) (finding that due process required a hearing with an opportunity for the respondent to confront the witness against her); Murphy v. INS, 54 F.3d 605, 611 (9th Cir. 1995) (“Most prejudicial to [the respondent], there was no testifying witness subject to cross-examination to verify the source of the information…. [W]ithout the officer’s testimony on cross-examination, the statement is subject to speculation and hardly worthy of full evidentiary weight”) (citations omitted).

    [51] 8 C.F.R. § 1003.35(b).

    [52] See California State Auditor, supra note 22.

    [53] See, e.g. , Alice Speri, NYPD Gang Database Can Turn Unsuspecting New Yorkers Into Instant Felons , The Intercept (Dec. 5, 2018), https://theintercept.com/2018/12/05/nypd-gang-database/.

    [54] See California State Auditor, supra note 22.

    [55] See Leszczynski et al., supra note 38, at 4 (“Generally, immigration judges tend to admit almost all of the evidence introduced.”).

    [56] Medina v. U.S. Dept. of Homeland Sec., 313 F. Supp. 3d 1237, 1250 (W.D. Wash. 2018).

    [57] Id. at 1246 (citing Judulang v. Holder, 565 U.S. 42 (2011); Inland Empire-Immigrant Youth Collective v. Duke, 2017 U.S. Dist. LEXIS 203307 (C.D. Cal. Nov. 20, 2017)).

    [58] INA § 240(c)(3)(A), 8 U.S.C § 1229a(c)(3)(A) (in removal proceedings the government “has the burden of establishing by clear and convincing evidence that, in the case of an alien who has been admitted to the United States, the alien is deportable. No decision on deportability shall be valid unless it is based upon reasonable, substantial, and probative evidence.”).

    [59] del Bosque, supra note 36.

    [60] Id.

    [61] Id.

    Reprinted with permission.


    About The Author

    Beau J. Baumann graduated from Cornell Law School in 2019 and is a law clerk at Weil, Gotshal & Manges LLP in New York City. In 2020, he will clerk for federal court judges Scholer and Barker in Texas.

    Stephen Yale-Loehr is co-author of Immigration Law and Procedure, the leading twenty-one-volume immigration law treatise, published by LexisNexis. He is also Professor of Immigration Practice at Cornell Law School and of counsel at Miller Mayer LLP in Ithaca, New York.


    The opinions expressed in this article do not necessarily reflect the opinion of ILW.COM.

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