Santos-Quiroa v. Lynch, No. 15-1685 (1st Cir. 2016)
Annotate this CaseIn 1994, Petitioner crossed the U.S.-Mexican border in violation of United States law. The day after he entered the country, Petitioner was served an Order to Show Cause charging him as being deportable. An Immigration Judge (IJ) found Petitioner deportable. Petitioner later filed a second motion to reopen the deportation proceedings. The motion was granted. In 2014, Petitioner applied for suspension of deportation and voluntary departure, arguing that he was eligible for suspension of deportation because the law in effect in 1994 required a noncitizen to be continuously physically present in the United States for seven years before applying for suspension of deportation and that he easily met this requirement. An IJ concluded that the so-called “stop-time” rule applied retroactively to Petitioner because his deportation proceedings remained pending on the date the stop-time rule went into effect and that the stop-time rule cut off Petitioner’s physical presence after one day, rendering him ineligible for suspension of deportation. The Board of Immigration Appeals (BIA) dismissed Petitioner’s appeal. The First Circuit denied Petitioner’s petition for review, holding that the BIA’s interpretation of the stop-time rule was reasonable and that the BIA properly applied the stop-time rule to Petitioner.
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