The Board of Immigration Appeals has determined that the controlling circuit law in Immigration Court proceedings for choice of law purposes is the law governing the geographic location of the Immigration Court where venue lies, namely where jurisdiction vests and proceedings commence upon the filing of a charging document, and will only change if an Immigration Judge subsequently grants a change of venue to another Immigration Court.

The full text of Matter of Garcia can be found here:

justice.gov/eoir/page/file/1576116/download

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