The Second Circuit has applied the CSPA’s age reduction formula to minor child of lawful permanent resident whose petitioning parent naturalized. The court determined that in this situation, the number of days the petition was pending should be subtracted from the beneficiary’s biological age to determine if the beneficiary is still under 21, and therefore, became an immediate relative when the parent naturalized.

The full text of Cuthill v. Blinken can be found here:

https://www.ca2.uscourts.gov/decisions/isysquery/3b5d5ef5-41d1-46ae-adab-dc59deb7d0e1/7/doc/19-3138_opn.pdf#xml=https://www.ca2.uscourts.gov/decisions/isysquery/3b5d5ef5-41d1-46ae-adab-dc59deb7d0e1/7/hilite/

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