The First Circuit has determined that the Board of Immigration Appeals can use its sua sponte authority to reopen for a non-citizen to pursue NACARA relief, rejecting the argument that a motion to reopen under 8 C.F.R. § 1003.43(e)(1) is the only available means for reopening for NACARA relief.

The full text of Mancia v. Garland can be found here:

http://media.ca1.uscourts.gov/pdf.opinions/22-1599P-01A.pdf

Comment