USCIS’s fraud investigation zeal rendering the Howard Memo obsolete.

Sunday, October 23rd, 2011

United States Citizenship and Immigration Services, at least in San Diego, where I practice Immigration Law, in its zeal to investigate fraud and to find reasons to deny cases it adjudicates, is putting in doubt the worthwhileness of using the Howard Termination process to resolve cases for people who find themselves in removal proceedings. The Howard Termination process is based on an October 6, 2005, memorandum, the Howard Memo, from Mr. William J. Howard, Immigration and Custom Enforcement’s (ICE) principal legal…

Immigration bureaus still having trouble coordinating on policy implementation.

Sunday, May 15th, 2011

For years before it actually happened in 2003, many immigration-law pundits advocated for the division of the former Immigration and Naturalization Service (INS) into different components. The idea was that the cultures of benefit granting and enforcement were incompatible. When the Department of Homeland Security (DHS) was created in 2003, the immigration functions of the INS were moved from the Department of Justice (DOJ) and given to the new DHS. Within DHS, INS functions were, like a dream come true…