Watson v. Holder, Jr., No. 09-0657 (2d Cir. 2011)
Annotate this CasePetitioner, a native of Jamaica, sought review of an order of the Board of Immigration Appeals ("BIA") affirming the decision of an immigration judge denying his motion to terminate the removal proceedings brought against him, after his criminal convictions, on the grounds that he had not derived U.S. citizenship through the naturalization of his father. At issue was whether petitioner had been "legitimated" under Jamaican law within the meaning of 8 U.S.C. 1101(c)(1) even though his parents never married, with the result that he had obtained derivative citizenship as a consequence of the naturalization of his father. The court remained unsure as to the precise definition the BIA had adopted for determining whether a "child" had been "legitimated" under the law of a particular jurisdiction for purposes of section 1101(c)(1). The court was also unclear as to the legal and/or logical basis for the BIA's interpretation. Accordingly, the court remanded to the BIA to address these two issues and the petition for review was granted.
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