Sample Brief Seeking Termination of Removal Proceedings Based on SIJS Approval

The goal of this resource is to provide practitioners who represent Special Immigrant Juvenile Status, or SIJS, beneficiaries with ideas for advocating in immigration court to prevent the removal of SIJS beneficiary clients who are awaiting a current priority date. This sample brief provides arguments for seeking termination of removal proceedings or, in the alternative, a continuance or transfer to the status docket for respondents with approved I-360 SIJS petitions who are awaiting a current priority date. It is written for a respondent who is charged on the Notice to Appear under INA § 212(a)(6)(A)(i) for being present without admission or parole; however, some of the arguments could be adapted for respondents with certain other charges under the INA. The arguments in this sample brief are merely ideas; we would welcome your feedback on this resource as well as your additions to or improvements of it.

This sample document is not legal advice. Nor is it a substitute for independent research and analysis of legal authority in a given jurisdiction or investigation into local practices. CLINIC may share or distribute non-identifying information collected from this webform for training, advocacy, or other purposes.

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