In a decision earlier this week, the Ninth Circuit resolved tension between its case law and the Board of Immigration Appeals' case law on whether a grant of family unity benefits qualified as admission for the purpose of cancellation of removal for lawful permanent residents.  In 2005, the Ninth Circuit had determined that a grant of family unity benefits would qualify as an admission in any status, as required in the cancellation statute, in its decision in Garcia-Quintero v. Gonzales.  In 2010, the Board of Immigration Appeals published its decision in Matter of Reza-Murillo, in which it came to the opposite conclusion.  In its decision this week, the Ninth Circuit deferred to Matter of Reza-Murillo, finding that the Board of Immigration Appeals' interpretation of the word "admitted" to require a "lawful entry after inspection and admission" (a procedural regularity not required to be granted family unity benefits) to be reasonable.

The full text of Medina-Nunez v. Lynch can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2015/06/08/14-70657.pdf

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