A week of reinventing the wheel in a system too complicated to administer.

Sunday, May 17th, 2015

Time and time again immigration lawyers like to tell you how complicated the immigration laws are.  Often the motivation for saying this is to encourage people to hire a lawyer. While hiring a lawyer may help to avoid the procedural pitfalls of trying to obtain benefits from immigration agencies, the biggest problem is that the immigration laws are too complicated for the agencies themselves to administer. Lawyers have a hard time stopping the decision makers from making their stupid mistakes….

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…