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Jeffrey S. Chase | Opinions/Analysis on Immigration Law

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Jeffrey S. Chase | Opinions/Analysis on Immigration Law: Jeffrey S. Chase | Opinions/Analysis on Immigration Law

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A Reason Not to Pretermit?: 2d Circuit Rejects BIA's CAT Reversal

On October 8, the U.S. Court of Appeals for the Second Circuit published an opinion worthy of our interest. I will discuss the court’s opinion, the larger issue it highlights, and why it should give pause to Immigration Judges considering whether to pretermit CAT applications without a hearing pursuant to a new agency policy.

In Villalta Martinez v...

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Nexus Update: Matter of M-R-M-S- is Vacated

On August 26, 2025, the U.S. Court of Appeals for the Tenth Circuit issued its decision in O.C.V. et. al. v. Bondi.1 This case was the direct appeal of the BIA’s precedent decision in Matter of M-R-M-S-2. In O.C.V., the Tenth Circuit thus vacated the Board’s precedent decision itself. In doing so the Tenth Circuit stated: “We agree with Pet...

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Gender is a Particular Social Group

Introduction

In a decision that came as no surprise to anyone, the Board of Immigration Appeals (minus several excellent judges who were removed from their jobs by the current administration without explanation) issued a precedent decision on July 18 holding that a particul...

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When Are Future Predictions Clearly Erroneous? Matter of A-A-R-
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Proposed Asylum Bar Regs Are At Odds With International Law (And Why That Matters)
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