Castro-Tum Overruled

Today, Attorney General Garland issued an opinion 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).

This is a VERY big deal — making administrative closure, once again, available around the country.

Don’t know what administrative closure is? This TRAC Report offers an excellent summary, with all the skinny about the now-overruled Castro-Tum.

-KitJ