17. Department of Justice · Notable
Withdraw or overturn every immigration decision of AG Garland
Printed page 567 17. Department of Justice
“Examine and consider the appropriateness of withdrawing or overturning every immigration decision rendered by Attorney General Garland (and any successor Attorney General during President Biden’s term).”
What has happened
- Partially done
Matter of Negusie vacated the stay Attorney General Garland entered in 2021 and made the 2020 Attorney General opinion — that the persecutor bar has no duress exception — the operative one again. Three of Attorney General Garland's immigration certifications have now been undone; others he issued, among them Matter of Cruz-Valdez, Matter of A-C-A-A-, Matter of B-Z-R- and Matter of Coronado Acevedo, still stand, so the examination the Quote asks for has not run to every decision.
- Partially done
The Attorney General began undoing her predecessor's certifications. Matter of S-S-F-M- overruled Matter of A-B-, 28 I&N Dec. 307 (A.G. 2021), restoring the 2018 and January 2021 A-B- decisions and overruling Matter of A-R-C-G- by extension; Matter of R-E-R-M- & J-D-R-M- overruled Matter of L-E-A-, 28 I&N Dec. 304 (A.G. 2021), restoring the 2019 decision. Both bind immigration judges and the Board in all pending and future cases.
Research log
What was searched, and what didn’t count as evidence
Research notes
Read the Attorney General/Board precedent volumes at justice.gov/eoir/volume-29 for the window’s A.G. decisions; the three above are the only ones reversing a Garland certification.
- Action
- withdraw
- Object
- Attorney General Garland's immigration decisions
- ID
- 1572