Second Circuit Weighs in on 212(h) Waivers for Aggravated Felons

The Second Circuit, in Husic v. Holder, is the latest court to find that an individual who is admitted to the United States in a status other than lawful permanent residence and later adjusts status to lawful permanent residence is not barred from seeking a 212(h) waiver (which waives the immigration consequences of certain criminal convictions) because of a conviction for an aggravated felony.  Husic was admitted to the United States on a tourist visa, and later adjusted his status to lawful permanent residence.  He was convicted of an aggravated felony and placed in removal proceedings, where he argued that he could seek a 212(h) waiver for his conviction.  The Second Circuit, in finding that an individual who enters the United States and later adjusts status is not an individual who has "previously been admitted to the United States as an alien lawfully admitted for permanent residence," joins seven other circuit courts in reaching this interpretation of the aggravated felony bar to 212(h) waivers.  The 8th Circuit is currently the only circuit court to dissent from this  majority view.

You can read the full decision here: http://www.ca2.uscourts.gov/decisions/isysquery/7f8fdc38-cdd6-46e2-8835-896bbfa2dc71/1/doc/14-607_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysquery/7f8fdc38-cdd6-46e2-8835-896bbfa2dc71/1/hilite/

USCIS Announces TPS Re-Registration for Salvadorans

Yesterday, USCIS announced that TPS benefits for citizens of El Salvador would be extended for an additional 18 months, effective March 10, 2015.  The re-registration period will run from January 7, 2015 to March 9, 2015.

For more information on the extension of TPS benefits for Salvadorans, you can go to USCIS's website: http://www.uscis.gov/humanitarian/temporary-protected-status-deferred-enforced-departure/tps-designated-country-el-salvador/temporary-protected-status-designated-country-el-salvador

USCIS Announces TPS Re-Registration for Syrians

USCIS announced re-registration for Syrians who currently hold Temporary Protected Status.  TPS will be extended for Syrians until September 30, 2016.  

For more information on TPS for Syrians, you can view the USCIS website: http://www.uscis.gov/humanitarian/temporary-protected-status-deferred-enforced-departure/tps-designated-country-syria/temporary-protected-status-designated-country-syria

Texas Stalking is not a Crime of Violence under the Sentencing Guidelines

Today, the Fifth Circuit addressed whether a conviction under Texas Penal Code 42.072 (stalking) qualifies as "force offense" type of crime of violence under the federal sentencing guidelines.  The court concluded that the offense, which criminalizes behavior that another person fears is threatening bodily injury, does not fall under the category of crimes of violence.  The court relied on prior Fifth Circuit precedent that determined that one can cause bodily injury without the use of attempted use of physical force and thus, the threat of bodily injury can occur in the absence of a threat to use physical force.  Though this case arose in the context of federal sentencing, the rationale could be persuasive for arguing that a stalking conviction is not a crime of violence for immigration purposes under 8 USC 16(a).  

You can find the complete decision in United States v. Rodriguez-Rodriguez here: http://www.ca5.uscourts.gov/opinions/pub/13/13-51021-CR0.pdf

New Year's Resolution

As a person, I (like everyone else) try to make new year's resolutions every year: to eat healthier, to go to the gym more often, to spend more time with my friends and family, to volunteer more in my community, etc.  But this year, I'm making a new year's resolution as an attorney, too.  A large part of my practice is appellate work, and I've been blessed to build relationships with my own clients, as well as with other attorneys who refer appellate clients to me and who seek my assistance with their appeals.  Thus far, I've confined my work to cases arising in the Ninth Circuit, where I am most familiar with the governing law.  To stay updated, I visit the Ninth Circuit's website almost daily, and blog about new case law.  In 2015, I will expand my efforts to all circuits.  I have already bookmarked the websites of other circuits, and will try to keep on top of new decisions impacting immigration cases, and blog about them with the same regularity that I write about Ninth Circuit cases.  By doing this, I hope to sharpen my skills as an appellate attorney and better serve my clients (both non-citizen and attorneys alike).  Wish me luck in my new endeavor!

TPS as an Admission for Adjustment of Status

This week, a federal district court in Pennsylvania ruled that Temporary Protected Status (TPS) can serve as an admission for adjustment of status purposes, so long as the TPS beneficiary disclosed his or her prior unlawful entry on the TPS application.  This decision accords with a developing trend in this area of the law.  The Sixth Circuit, in Flores v. USCIS, previously came to the same conclusion, as did a district court in Washington in Ramirez v. Dougherty.  The issue is currently pending before the Ninth Circuit.

This positive trend would be a terrific leap forward for TPS beneficiaries, many of whom have lived in the United States for more than a decade, and who are married to U.S. citizens.  Decisions from courts of appeals (like the Flores decision) could allow these individuals to apply for their green cards from inside the United States, saving them the hardship of being separated from their family while they seek a green card abroad at a U.S. consulate.

The text of the Eastern District of Pennsylvania's decision in Medina v. Beers can be found here: http://www.legalactioncenter.org/sites/default/files/docs/lac/district%20court%20decision.pdf

Second-Degree Robbery in Washington is Categorically a Theft Offense Aggravated Felony

In this case, the Ninth Circuit addressed "whether a defendant convicted of second-degree robbery under section 9A.56.190 of the Revised Code of Washington and sentenced to prison
for at least one year has been convicted of an aggravated felony."  The court reiterated its long-standing definition of a theft offense as a crime that requires (1) the taking of (2) property (3) without consent (4) with the intent to deprive the owner of rights and benefits of ownership.

The State of Washington defines second-degree robbery as the taking of personal property from the person of another or in his or her presence against his or her will, when accompanied by the use of force or the fear of injury.  The court noted that though the statute does not
explicitly provide that specific intent to steal is an element of the crime, the state courts have so held.  Thus, it summarized the elements of Washington second-degree robbery as (1) taking (2) personal property (3) from another person or from another’s immediate presence (4) against his or her will (5) by force or threatened force (6) with the specific intent to steal.  This definition, the court concluded, covered the full range of conduct included in the generic definition of a theft offense.  Therefore, the crime was a categorical match for the generic definition, and because the defendant had been sentenced to the required one year term of imprisonment listed in the theft aggravated felony definition, he had been convicted of an aggravated felony.

The full text of United States v. Alvarado-Pineda can be read here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/12/19/13-50528.pdf

When is a case ripe for a circuit court appeal? The Ninth Circuit weighs in....

It's very common for an immigrant seeking asylum in Immigration Court to also apply for withholding of removal and protection under the Convention Against Torture (all three forms of relief are contained in one application).  Sometimes, an individual who isn't eligible for asylum (i.e. someone who filed for this relief more than one year after their last entry into the United States and cannot convince a judge that they meet one of the exceptions to the filing deadline) will be granted withholding of removal.  The individual, however, may not agree with the Immigration Judge's decision that he did not timely-file his asylum application or demonstrate an exception to the filing deadline.  An appeal to the Board of Immigration Appeals on this could follow.  During the pendency of the appeal, the immigrant's background checks (completed prior to the grant of withholding of removal) may expire.  If the Board of Immigration Appeals affirms the denial of asylum, but remands the case for further background checks, is the removal order final?  Is it now time to appeal to the appropriate circuit court of appeals?

The Ninth Circuit, recognizing that its prior case law was contradictory regarding this point, revisited the issue in Abdisalan v. Holder, earlier this week.  They answered the above-posed question in the negative, stating that "[w]hen the BIA remands to the IJ for any reason, no final
order of removal exists until all administrative proceedings have concluded."  

Abdisalan, like my hypothetical immigrant above, was denied asylum based on a failure to demonstrate that she had filed her asylum application within one year of her last entry.  With regard to this issue, the Ninth Circuit stated that it was remanding her case to address the open question of whether "a pre–REAL ID Act asylum applicant’s credible and uncontradicted testimony regarding her date of entry meets the statutory 'clear and convincing evidence' standard."  It will be interesting to see if Abdisalan's case climbs the appellate ladder again while this issue is litigated.  

The full text of Abdisalan v. Holder can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/12/15/10-73215.pdf

Nevada Conspiracy to Commit Burglary is not a Conspiracy Aggravated Felony

Earlier this week, the Ninth Circuit addressed whether a conviction for violating Nev.
Rev. Stat. §§ 199.480 and 205.060(1) (conspiracy to commit burglary) could qualify as a conspiracy aggravated felony.  The court determined that it could not because Nevada's conspiracy statute does not require a defendant to take an "overt act" in furtherance of the conspiracy.  The court rejected the Government's argument that it should look to the common-law definition of conspiracy, which does not require proof of an overt act by the defendant. Instead, the court looked at how the majority of jurisdictions define conspiracy in the modern era. This approach is mandated by the Supreme Court's decision in Taylor v. United States, which states that the generic definition of a crime should be based on the "contemporary usage of the term."  Because the majority of jurisdictions do require an overt act, the court found that the generic definition must also include this element.  Since Nevada's statute does not include this element, it is not a match to the generic definition, and it does not qualify as an aggravated felony.

The full text of the Ninth Circuit's decision in United States v. Garcia-Santana can be read here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/12/15/12-10471.pdf

Educating the Community about Administrative Relief

Yesterday, I traveled to a church in Glendale, where I met with a pastor and a group of congregants who are very interested in immigration issues and in welcoming new immigrants to our community.  I gave them a presentation on some of the highlights of President Obama's November 20, 2014, announcement regarding executive action on immigration.  

I also talked with them about how important it was to be on the watch for notario fraud.  In many parts of Latin America, notarios are actually individuals with legal training (much different than notary publics in the United States).  Many immigrants seek their assistance in the United States, not understanding the difference in educational backgrounds between the American and Latin American counterparts.  The results are often disastrous, with many individuals subsequently being deported from the United States as a result of a notario's shoddy work.  Our neighbors, our friends, our churchmates - these are the people who have waited so long to come out of the shadows, and they will be the targets of unscrupulous individuals seeking to take advantage of them.  

I encourage everyone to educate themselves and anyone they know about who benefits from these programs, when the applications will be available, and how to know if someone is trying to victimize you with a scam.  The American Immigration Lawyers Association has put together some great materials on administrative relief and notario fraud.

You can read their materials on administrative relief here: http://www.aila.org/content/default.aspx?bc=6755|37861|47963

You can read their materials on notario fraud here: http://www.stopnotariofraud.org/

In addition, if you belong to any group (i.e. a religious congregation, a social club, etc.) in the Los Angeles area that has members who you think could benefit from learning about the administrative relief programs and the dangers of notary fraud, please don't hesitate to contact me.  I will be happy to speak with them!

Vargas-Cervantes v. Holder -- The Ninth Circuit Addresses 212(h) Waivers

Last week, the Ninth Circuit issued a very interesting opinion on 212(h) waivers.  To me, it's interesting mostly because I think it conflicts with another recent Ninth Circuit case.  A 212(h) waiver has additional requirements (namely, that a beneficiary not be convicted of an aggravated felony and that he have been residing lawfully in the US for 7 years before the initiation of removal proceedings) for individuals previously admitted to the US as lawful permanent residents.  In Negrete-Ramirez, a 2014 Ninth Circuit decision, the court determined that the aggravated felony bar only applies to those individuals who entered the US as lawful permanent residents, not to those who adjust to lawful permanent residence after entry into the US.  I assumed, after reading Negrete-Ramirez, that the same interpretation would apply to the 7-year residency requirement.  Nevertheless, in Vargas-Cervantes, the Ninth Circuit applied the 7-year residency requirement to an individual who adjusted status after entry into the US.  

I'll be interested to see if a petition for rehearing is granted in the Vargas-Cervantes case.

The text of Vargas-Cervantes can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/11/19/10-73384.pdf

The text of Negrete-Ramirez can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/01/21/10-71322.pdf

Executive Action is Here!

Pursuant to the President's speech last night, the Department of Homeland Security (DHS) has released detailed memos regarding administrative relief for millions of immigrants in the United States.  The highlights include:

1) Expanding the DACA program to anyone brought to the United States before the age of 16 (regardless of their current age) who entered the United States on or before January 1, 2010.  The deferred action and work authorization will now be granted for 3 years, instead of 2 years.  The program will not benefit those who are included in the DHS's updated enforcement priorities (see below for more information on these priorities).  Applications under the expanded DACA program will be considered on a case-by-case basis beginning no later than 90 days from the date of the announcement (November 20, 2014).  Applications fees will continue to be $465.

2) Creating the Deferred Action for Parents (DAP) program for the parents of US citizens and lawful permanent residents. DAP eligibility requires that these parents have been continuously residing in the United States since January 1, 2010, be present in the United States on November 20, 2014 and on the date that they request deferred action, and have had no lawful immigration status on November 20, 2014.  DAP participants will receive deferred action and employment authorization for 3 years.  Like the expanded DACA program, DAP will not include individuals who are listed in the DHS's enforcement priorities.  Applications under the new DAP program will be considered on a case-by-case basis beginning no later than 180 days from the date of the announcement (November 20, 2014).  The application fee will be $465. 

3) Expanding the Provisional Waiver program (also called the 601A program) to children (both minor and adult) and spouses of lawful permanent residents and to the adult children of U.S. citizens.  This program allows beneficiaries to apply for a waiver of their unlawful presence before they leave the United States, minimizing the amount of time they are separated from their families when applying for their permanent residence at a consulate.

4) Changes to Employment-Based Immigration: The program proposes changes to the way employment-based green cards are distributed.  It also proposes extending the time that students with science-, math-, engineering-, and technology-related degrees may engage in Optional Practical Training (OPT) after graduation, and potentially expanding the types of degrees that graduates can hold when requesting OPT.  This is an important step in helping non-citizen graduates of American universities contribute their skills to the American economy.  Additionally, the program should improve the ability of talented and educated individuals to obtain immigration status without an employer sponsor.  Some of these reforms are targeted at helping inventors, researchers, and founders of start-up enterprises.  Finally, the reforms include a directive that USCIS should clarify the standards for certain employment-based visas and to clarify when someone who is waiting for an employment-based visa to become available can change employers without endangering their green card process.

5) Finding ways to make the naturalization process more accessible to lawful permanent residents.

6) Ending Secure Communities - a program linking local law enforcement databases and Immigration and Customs Enforcement (ICE) apprehension efforts.   Secure Communities has engendered grave mistrust of local law enforcement within the immigrant community.  The program has become very unpopular with local politicians and police, who suffered from strained relations with the immigrant members of their community.  A new program will be developed, with an emphasis on prioritizing the apprehension of individuals who come within the ambit of the DHS's new enforcement priorities.

7) Increasing the effectiveness of border security efforts.

8) Expanding parole-in-place and deferred action for undocumented parents, children, and spouses of individuals seeking to enlist in the armed forces.

9) Possible pay raises for ICE officers

10) Revised enforcement priorities for ICE, which are now divided into three classifications.  Priority 1 consists of individuals who are suspected of terrorism or espionage, individuals apprehended at ports of entry trying to illegally enter the US, individuals convicted of gang-related offenses, and those convicted of felonies or aggravated felonies.  Priority 2 consists of individuals who have been convicted of 3 or more misdemeanors, individuals convicted of a significant misdemeanor (i.e. domestic violence, DUI, burglary, sexual abuse, drug trafficking, firearms possession) who were sentenced to 90 days or more of jail time, individuals who illegally entered or reentered the US and who have not been continuously present in the US since January 1, 2014, and individuals who have abused the visa and visa waiver programs.  Priority 3 consists of individuals who were issued a final order of removal on or after January 1, 2014.

A summary of the programs with links to more detailed descriptions of many of the President's actions can be found on the USCIS website: http://www.uscis.gov/immigrationaction

Details about the benefits for relatives of those seeking to enlist in the military can be found here: http://www.dhs.gov/sites/default/files/publications/14_1120_memo_parole_in_place.pdf

USCIS Extends Temporary Protected Status to Sierra Leone, Liberia, and Guinea

In light of the Ebola virus breakout, USCIS is extending TPS to citizens of Sierra Leone, Liberia, and Guinea, who are residing in the United States as of today's date (November 20, 2014).  See the full announcement here: http://www.uscis.gov/news/dhs-announces-temporary-protected-status-designations-liberia-guinea-and-sierra-leone#.VG4JCgRRiTQ.gmail

What a great start to what I hope will be a historic day for immigration reform! 

EXECUTIVE ACTION IS COMING TOMORROW AT 5 PM PST!

The media is reporting that President Obama will make his announcement regarding executive action on immigration tomorrow at 5 pm PST.  I wait with baited breath, as I'm sure so many others do.

http://www.whitehouse.gov/blog/2014/11/19/tune-president-addresses-nation-immigration-reform?cache

Ninth Circuit Addresses Motions to Reopen for Individuals Seeking Adjustment of Status before USCIS

The Ninth Circuit has determined that the Board of Immigration Appeal's decision in Matter of Yauri is not entitled to deference, and that the Board has jurisdiction to reopen removal proceedings using their sua sponte authority when an arriving alien seeks to adjust their status before USCIS.  It awaits to be seen if the Board determines that such circumstances rise to the level of "exceptional circumstances" required for a sua sponte reopening.

The most interesting part of the decision was the broad language used by the Ninth Circuit.  The court stated that the Board has broad power to grant a motion to reopen in any case for the
purpose of affording an alien the opportunity to pursue relief from removal before another agency.  I think it's an open (and very interesting!) question whether executive relief (i.e. DACA, prosecutorial discretion) constitutes "relief from removal before another agency."  If so, I'd say there's a new argument that the courts can (and perhaps should!) start granting MTRs for the purpose of applying for DACA and PD.  Let's keep our fingers crossed!

The full decision (Singh v. Holder) can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/11/13/09-73798.pdf

Executive Action to be Announced Soon?

Several media installations report that the Obama administration could be announcing executive action on immigration as soon as next week!  Fox news is reporting a 10 point plan, which expands Deferred Action for Childhood Arrivals to a wider range of people who came to the United States as children, offer deferred action to the parents of U.S. citizens and green card holders, end Secure Communities (a program that facilitates the sharing of information between local law enforcement authorities and immigration authorities), expand visas for workers in high-tech industries, expand parole for the parents of US citizens, and expand the provisional waiver program to include the spouses and children of lawful permanent residents.  I'm particularly excited about this last possibility -- I've worked on a number of provisional waivers during my career, and I really love them.  They give me the chance to really get to know my clients, understand their daily lives, and convince the immigration authorities that they deserve to live in the United States as green cards.  I hope that these reforms will be announced soon, so that I can help those immigrants in my community who will benefit from them!

Here's a link to an article on Fox News about the possible reforms: http://www.foxnews.com/politics/2014/11/13/obamas-immigration-plan-10-executive-actions-being-weighed-by-president/

Ninth Circuit Issues Long-Awaited Decision in Almanza-Arenas!

Crimmigration gurus unite! OK -- that might just be me.  Today the Ninth Circuit issued a long-awaited decision in Almanza-Arenas v. Holder.  The court determined that section 10851(a) of the California Penal Code (vehicle theft) is not a crime involving moral turpitude because it does not require a permanent taking.  Rather, the language "with the intent to either permanently or temporarily deprive" defined alternative means of committing the same crime, but did not define alternative elements of that crime.  

While this, on its own, would have been a nice result for immigrants with California convictions, the Ninth Circuit went a step further, and overruled its previous decision in Young v. Holder, which stated that an inconclusive record of conviction was insufficient to meet a non-citizen's burden or proving his eligibility for immigration benefits.  In plain(er) English, when a conviction contains alternative elements, some of which match the definition of a crime involving moral turpitude and some of which do not, a non-citizen no longer must conclusively prove that he was not convicted of the elements that do not constitute a crime involving moral turpitude in order to qualify for cancellation of removal.  Instead, if the criminal record is unclear about which elements he was convicted of, he is eligible for immigration relief.  For those of you who aren't super crimmigration nerds like me, you'll have to take my word for this: Almanza-Arenas will have widespread, positive impact on immigration cases throughout the Ninth Circuit.  It's a good day for immigration attorneys and their clients with criminal histories who are fighting removal proceedings and trying desperately to remain in the United States with their loved ones!

The full text of the decision can be read here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/11/10/09-71415.pdf

Ninth Circuit addresses two Arizona criminal statutes

We're less than one week into the month, but the Ninth Circuit seems to be on an Arizona crimmigration binge, issuing two decisions in as many days that address the immigration consequences of Arizona convictions.  

On November 5, 2014, the court issued a decision in Ibarra-Hernandez v. Holder, addressing the Arizona statute criminalizing the "taking of the identity of another."  This statute, which criminalizes the use of both fictitious and real identities, is not categorically a crime involving moral turpitude.  It is, however, also divisible.  Thus, the court proceeded to the modified categorical approach and examined Ibarra-Hernandez's plea transcript, which indicated that she used the social security number of a real person to obtain employment.  The court construed this act was a form of theft involving fraud, and therefore, a crime involving moral turpitude.  The court did recognize that the use of a fictitious person's identity would not be a crime involving moral turpitude.  Nonetheless, a potentially harsh result for an undocumented individual individual who uses another person's identity to work, but causes him or her no economic harm (and perhaps even improving his or her future social security income!)

The next day, the Ninth Circuit issued its decision in Leal v. Holder, taking up the Arizona statute defining felony endangerment.  Leal argued that the reckless mens rea needed to sustain a conviction,  which included recklessness based on voluntary intoxication, was insufficient to demonstrate moral turpitude.  The court disagreed, finding that the harmful behavior criminalized by the statute (conduct that creates a substantial, actual risk of imminent death to another person) was severe enough to make up for the lower level of mens rea.  The court concluded that the statute was categorically a crime involving moral turpitude.

The full text of Ibarra-Hernandez v. Holder can be viewed here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/11/05/11-70739.pdf

The full text of Leal v. Holder can be viewed here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/11/06/12-73381.pdf

Lai v. Holder: The Ninth Circuit Addresses the Credibility Standards Applied to Asylum Applications

This week, the Ninth Circuit Court of Appeals issued a new decision (Lai v. Holder) on the credibility standards that Immigration Judges must apply to asylum applications.  Credibility analyses are usually very fact-intensive, and often, it's difficult to discern any larger legal lessons that can be applied to future cases.  But in this instance, I was struck by several very interesting points that the court made, which I think will have value in future cases.

Though not critical to the outcome of this particular case, the court recognized a concern that immigration attorneys have been dealing with for decades: the difficulty of communicating effectively through a translator.  In a footnote, the court hypothesized that general, compound questions, such as "Is your application true, correct, and complete?" are not always precise enough to elicit accurate information from non-native English speakers, especially those communicating through translators.  This is a reflection  of the reality that immigration attorneys face each time they try to communicate with a client who does not speak the same language: translators sometimes paraphrase or abbreviate questions, and the client's response will reflect only their understanding of the translated question.  This, unfortunately, can give the impression that the client is providing incomplete or evasive responses.

In addition, the court built on its prior case law recognizing that a person's testimony will be his or her fullest and most complete narrative of events, often more detailed than their asylum application or their declaration.  In this instance, the applicant testified during cross-examination about the arrests of his wife and a fellow church member - events that he learned about after coming to the United States.  These events were not included in his declaration, but the Ninth Circuit was not disturbed by this, recognizing that an asylum applicant's declaration will likely center around events that he personally experienced, and not events that impacted third parties.

Finally, the court addressed an argument that I have seen the Department of Homeland Security put forth many times in asylum proceedings - namely, that a person who was able to leave his or her country of origin without incident must not really be the target of government harm in that country.  The Ninth Circuit disregarded this argument, stating that an individual's apparent ability to leave his or her country of origin without problems is not sufficient on its own to determine that the individual's testimony was not credible.  It's good to see the court finally put this argument, often raised in Immigration Court, to bed.

The full text of Lai v. Holder can be found on the Ninth Circuit's website: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/11/04/10-73473.pdf

Volunteering in Tijuana

I spent my first day as a solo practitioner providing free legal consultations to people in Tijuana, Mexico.  The legal fair was held at Casa Del Migrante, an organization serving deportees and refugees.  At least half a dozen attorneys from Southern California made the trip.  As always, I was amazed at the breadth of knowledge my colleagues possess, and the compassion that they constantly display.

Almost everyone I spoke with had suffered the traumatic consequences of a removal order. Some of them had been deported only a few weeks ago.  Many of them still had family in the United States, including young, U.S.-citizen children.  Thinking about their broken families was heartbreaking, but hearing their resolve to find a way to continue supporting their relatives, even from Mexico, was inspiring.  Some of them will be able to apply for lawful immigration status sometime in the future; a few are even able to apply now.  Many of them just needed to know what their options were, even if those options did not include a return to the United States.  I hope my advice will help some of them to plan for their futures.