The Board of Immigration Appeals has sustained DHS's appeal from an order terminating proceedings after an immigration judge excluded a Form I-213 and Form I-94 offered to prove a lawful permanent resident's alienage, finding the certifying USCIS official lacked authority to authenticate the records.
The Board held that a Form G-24 certification signed by a District Records Manager properly authenticates such documents where an accompanying delegation memorandum shows the Secretary of Homeland Security's statutory custodial authority was validly conferred on that official, and remanded for the immigration judge to consider the documents in assessing removability.
The full text of Matter of Momplaisir can be found here: https://www.justice.gov/eoir/media/1455811/dl?inline