Liu v. Holder, No. 14-1159 (1st Cir. 2015)
Annotate this CasePetitioner, a native and citizen of China, was ordered removed in absentia. Petitioner filed a pro se motion to reopen, which the Immigration Judge (IJ) denied. Almost fourteen years after he was ordered removed, Petitioner filed a motion to rescind the in absentia removal order and a motion to reopen his removal proceedings to apply for asylum and related relief. The IJ denied Petitioner’s motions as untimely and numerically barred. The Board of Immigration Appeals (BIA) dismissed Petitioner’s appeal. The First Circuit denied Petitioner’s petition for review, holding (1) Liu waived his argument that he exercised the requisite due diligence to warrant equitable tolling; and (2) the BIA and IJ acted within their discretion in determining that Petitioner did not qualify for the changed country conditions exception for filing motions to reopen.
The court issued a subsequent related opinion or order on November 20, 2015.
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