Volume Nineteen, Number One

SHUSTERMAN’S IMMIGRATION UPDATE is the Web’s most popular e-mail newsletter regarding U.S. immigration laws and procedures with over 40,000 subscribers located in more than 150 countries. It is written by a former INS Trial Attorney (1976-82) with over 35 years of experience practicing immigration law.

Published by the Law Offices of Carl Shusterman, 600 Wilshire Blvd, Suite 1550, Los Angeles, California, 90017. Phone: (213) 623-4592 xO.

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Client Reviews

Newsletter US Immigration Update January 2014

TABLE OF CONTENTS:

1. What are the Chances for Immigration Reform in 2014?
2. CSPA Oral Arguments before the Supreme Court
3. Shusterman’s Upcoming Immigration Law Seminars
4. Employers: Time to Get Ready for H-1B Filing Season
5. Success Story: From Humanitarian Parolee to Permanent Resident 
6. Trivia Quiz: Immigrant Painters
7. State Department Visa Bulletin for January 2014
8. Immigration Government Processing Times
9. US Army Offers Expedited Pathway to Citizenship
10. Winner of Our December 2013 Trivia Quiz!

NEWS FLASHES:

• • EOIR’s New Facebook and Twitter Pages – The Executive Office for Immigration Review (EOIR) has created a Facebook page to better update the public on important news, events, and announcements. You can also follow EOIR on their Twitter page.

• • ICE Removal Numbers for FY 2013 – ICE has released its annual report on the number of immigrants removed from the United States. According to the Enforcement and Removal Operations (ERO), ICE removed 368,644 individuals in Fiscal Year 2013 (FY2013)., down from 409,849 in FY2012.

• • Immigration “How-To” Videos – Our 50+ “How-To” Immigration Videos have been viewed over 550,000 times. Subjects include the comprehensive immigration reform (CIR) bill, how to obtain a green card, how to become a U.S. citizen, how to win your case in immigration court and how to select an immigration attorney. Our video Green Cards through Marriage  has been viewed over 180,000 times. We encourage you to take advantage of this free resource.

• • Jeh Johnson Confirmed as DHS Chief– On December 23, Jeh Johnson was sworn-in as the new Secretary of the Department of Homeland Security (DHS).

• • Mayorkas Sworn-In as DHS Deputy Secretary – On December 23, Alejandro Mayorkas was sworn-in as the new Deputy Secretary of the Department of Homeland Security (DHS). This ends Mayorkas’ service as Director of USCIS.

• • Online Immigration Guide for IMGs – In recent years, about one fourth of U.S. medical residents are International Medical Graduates (IMGs). The immigration process for IMGs can differ based on their current immigration status, country of origin, job offer, and more. To help IMGs, potential employers, and recruiters navigate this complicated process, we offer a free online guide with a variety of resources.

• • Possible TPS for Philippines following Yolanda – Following the major destruction in the Philippines caused by Super Typhoon Yolanda, discussions have been underway to place the Philippines under Temporary Protected Status (TPS). This TPS designation would allow eligible Filipinos to stay and work in the US for a certain period of time to help finance relief efforts.

• • USCIS Approves 10,000 U Visas for 5th Straight Year – For Fiscal Year 2014, USCIS approved 10,000 U visas, for victims of certain crimes who have suffered mental and physical abuse and are willing to help law enforcement agencies to prosecute crimes. This marks the 5th straight fiscal year that the maximum has been reached.

• • USCIS FOIA Processing Guide – In response to a Freedom of Information Act (FOIA) request submitted by Shawn Musgrave, USCIS has released its USCIS FOIA/Privacy Act Processing Guide dated September 27, 2013.

• USCIS’ Updated Processing Times – On December 19, USCIS updated the processing times for the various types of cases that it processes at its field offices, service centers, and the National Benefits Center as of October 31.

1. What are the Chances for Immigration Reform in 2014?

Even though a bipartisan majority in the Senate passed a Comprehensive Immigration Reform bill in June 2013, the House of Representatives was unable to pass a bill addressing this important issue by the end of the year.

This is very unfortunate given that both the Senate and the House seem to agree that our immigration system is broken and in need of repair. The Senate bill would, among other things, strengthen both border and interior enforcement, make E-Verify mandatory for all employers, and increase employment-based immigration to benefit our economy.

The House leadership and the vast majority of its membership seem to be in broad general agreement with these concepts. The House, wisely in my view, would limit the vast amounts of money devoted to border enforcement in the Senate bill, and focus on results instead.

Why then, couldn’t the House pass an immigration reform bill in 2013?

The answer lies in the Pathway to Citizenship.

Even though the Senate bill makes such a pathway extremely long and difficult, the House opposes the concept in principle. Given this, is there any hope that Comprehensive Immigration Reform will become law in 2014? I remain optimistic.

Why?

The results of the 2012 Presidential election were a learning experience for the Republican party. Opposition to immigration reform and calls for “self-deportation” were deeply offensive to the Hispanic and Asian communities and resulted in over 70% of these communities voting to re-elect the President.

Also, despite the fact that President Obama has deported a record of almost 2 million people in the first 5 years of his presidency, there are still over 11 million undocumented persons living in the U.S. Enforcement alone is clearly not the answer to this problem.

As a result, individual states have moved well ahead of the federal government on this issue. For example, prior to the 2012 elections, only 3 states allowed the undocumented to obtain drivers licenses. After the election, this total increased dramatically. California, Colorado, Connecticut, Illinois, Maryland, New Mexico, Oregon, Utah, Vermont, Washington and the District of Columbia all passed such laws in order to increase highway safety. Also, a number of states joined California and Texas in permitting undocumented students to attend state universities without having to pay out-of-state tuition.

It is getting increasingly difficult to ignore the problem.

I fully expect GOP leaders in the House to propose a broad legalization program for the undocumented in 2014, albeit one that includes a Pathway to Citizenship only for a small minority, probably DREAMers. Then the Senate and the House will, hopefully, be able to work out a compromise CIR bill and send it to the President for his signature. It will be far from perfect, but it will allow our broken legal immigration system to be vastly improved in a way that will greatly benefit our economy and the lives of millions of immigrants.

2. CSPA Oral Arguments before the Supreme Court

On December 10, 2013, the Supreme Court of the United States heard oral arguments concerning who benefits from the “Retention of Priority Date” clause of the Child Status Protection Act (CSPA).

Hopefully, in the next few months, this matter will be settled once and for all, and sons and daughters of parents who immigrated years ago will, at last, be permitted to rejoin their families in the U.S.

Government’s Argument

The government, having lost in the Court of Appeals, first addressed the Court:

“The Board of Immigration Appeals reasonably interpreted Section 1153(h)(3) when it ruled that creation of a new petition by a new petitioner did not qualify as automatic conversion of an existing petition to an appropriate family-sponsored category…”

However, various Justices let the government know that they were not persuaded:

Justice Ginsburg: “What about all the time this one child has been waiting? It gets no credit for that?”

Justice Alito: “…your reading of this statute gives (h)(3) a very, very narrow scope.”

Justice Breyer: “…it’s just unlikely that Congress meant (3) to apply to a…little molecule when there’s the whole ocean.”

Justice Sotomayor: “It would have been much, much simpler to say this is limited to F2A beneficiaries than to write it the way they did and say this is to everybody who ages out.”

Justice Kagan: “…it seems as though you shouldn’t be entitled to Chevron deference on that question, given what Wang said about it.”

The government attempted to counter each of the above statements. It argued that the Court recognized that “deference is particularly appropriate in immigration contexts.”

The government expressed concern about delays to persons waiting in the F2B line, but when questioned by Justice Breyer, it revealed that it was impossible to calculate how much of a delay that these persons would experience if the respondent’s prevailed in this lawsuit.

Chevron Test

The issue in this case is whether the Court must give “Chevron deference” to an administrative decision interpreting a law, in this case, the Board of Immigration Appeals (BIA) decision in Matter of Wang. Here, the Court uses the following two-step test:

Step 1 – “First, always, is the question whether Congress has spoken directly to the precise question at issue. If the intent of Congress is clear, that is the end of the matter; for the court as well as the agency must give effect to the unambiguously expressed intent of Congress.”

Step 2 – [I]“f the statute is silent or ambiguous with respect to the specific question, the issue for the court is whether the agency’s answer is based on a permissible construction of the statute.” Chevron U.S.A. v. NRDC, 467 U.S. 837, 842–843 (1984).

Respondent’s Argument

When it was his turn to address the Court, Mark Fleming, the attorney arguing the matter on behalf of the immigrant families, stated:

“The government began at Step 2 of Chevron, but I would submit that this case can and should be resolved at Step 1. The government is asking this Court to read the statute in a highly disfavored way such that it is not harmonious but at war with itself, and nothing in the language requires that…”

“…provision (h)(3) consists of one sentence, and that sentence consists of two parts separated by a comma. Before the comma, the language sets forth one and only one eligibility criterion. After the comma, the language sets forth two things that shall be done if the eligibility criterion is satisfied. Now, importantly, the government does not contend that there is any ambiguity in the language before the comma. Everyone agrees that it contemplates and includes all derivative beneficiaries. There’s no dispute about that. And a bedrock rule at the Step 1 inquiry is that the Court reads the statute as a harmonious whole. That goes double when we’re talking about a single sentence. So if there is a possible reading of this sentence that is harmonious with the clear opening clause that applies to all derivative beneficiaries under Step 1 of Chevron, that is the reading the Court gives to the statute.” 

_____________________________________________________________________________________

Section 203(h)(3) – RETENTION OF PRIORITY DATE – If the age of an alien is determined under paragraph (1) to be 21 years of age or older for the purposes of subsections (a)(2)(A) and (d), the alien’s petition shall automatically be converted to the appropriate category and the alien shall retain the original priority date issued upon receipt of the original petition.
____________________________________________________________________________________
Justices Kennedy and Scalia questioned how “automatic conversion” would operate. Justice Scalia was concerned that respondent’s interpretation of the clause would permit an adult son or daughter to immigrate to the U.S. over his or her parent’s objections.

Mr. Fleming explained that in the highly unlikely event that the parent did not want his son or daughter to join him in the U.S., he could refuse to sign an affidavit of support and they would not be able to immigrate.

Justice Kagan: “Based on — another understanding of Chevron is sometimes Congress writes confusing statutes that point in two different directions at once, and then there’s a choice. Does the Court make the best of it or does the agency make the best of it? And the agency knows a lot about the subject matter, and especially this agency, and so irrespective of whether Congress meant to delegate something in some very self-conscious way, this is a confusing statute, it’s a kind of the muddle. The agency gets to do it.”

Mr. Fleming responded that it was clear that (h)(3) applies to all derivative beneficiaries, and that it was very possible for the agency to interpret the words “retention” and “automatic conversion” in a matter which would implement the intent of Congress. Furthermore, “retention” and “automatic conversion” are deemed separate and distinct benefits by the statute. Even if the agency decided that automatic conversion was not possible in selected cases, the son or daughter would still be able to “retain” the priority date of the original F3 or F4 petition.

Justice Scalia: “Well, this is all upside down. I thought it’s the agency that we deferred to. If it can be read in the way the agency wants, we affirm the agency’s position.” 

In response to a comment by Justice Scalia that the two benefits, retention and automatic conversion, were conjunctive, not disjunctive, Mr. Fleming revealed that the government had, despite its arguments, been denying automatic conversion, but not retention, to F2A derivative beneficiaries from the date that CSPA was enacted (August 6, 2002) until 6 days before the government submitted its reply brief. This, he said, demonstrated that retention and automatic conversion can, and have been, implemented as separate benefits.

Justice Scalia remained unpersuaded.

Mr. Fleming ended his argument by declaring that even under Step 2 of Chevron, the BIA decision failed to draw a rational line between 2B beneficiaries, treating those with familial relationships with permanent residents more favorably than those with relationships with both U.S. citizens and permanent residents.

Government’s Reply

“The Respondents were trying to put far too heavy a burden on the government in the Chevron deference case. So long as the agency has arrived at a reasonable reading of this very complicated statute, the agency is entitled to deference here.”

“The government also expresses its concern with the possibility that a derivative beneficiary could “have a priority date somehow in their pocket that they could walk around with and use 20 years later when somebody filed a different petition on their behalf, an employment petition…”

Chief Justice Roberts: “Well, it’s not so odd to say they’ve got a priority date in their pocket when the statute says the original priority date – they’ll retain the original priority date.”

Conclusion

While it is impossible to predict the final outcome of a case based solely on the oral arguments, I remain cautiously optimistic that the Supreme Court will ultimately agree with both the 5^th and the 9^th Circuit Courts of Appeals that the statute is unambiguous and that there is no need to defer to the flawed BIA decision in Matter of Wang. A decision may be forthcoming as early as February or March.

As recognized by many of the Justices, the government is arguing for a very restrictive reading of CSPA. Yes, the DOJ instead portrays itself as the defender of those in the F2B line and categorizes our clients as “line-jumpers”.

What the DOJ conveniently overlooks is that CSPA created (h)(1) to allow all qualifying derivative beneficiaries who would, in the past, have “aged-out” and lost their place in line to immigrate together with their parents in a particular preference category. Under the government’s reasoning, why are they not “line-jumpers”? Congress simply made a policy decision to give sons and daughters who have waited for years in line for permanent residence together with their parents credit for their wait, and not send them to the back of the line. It is clear that (h)(3) extends this same credit to unmarried sons and daughters of permanent residents.

Could it be that the DOJ simply disagrees with these policy decisions?

If so, they should lobby Congress, not the Supreme Court, to change the law.

3. Shusterman’s Upcoming Immigration Law Seminars

• AILA Annual Conference on Immigration Law
  Marriott Copley Place and Westin Copley Place
  Boston, MA
  June 21, 2014
  Topic: “Forever (Under) 21: The Latest on CSPA & K-2 Ageouts”

4. Employers: Time to Get Ready for H-1B Filing Season

In 2013, the number of cap-subject H-1B petitions filed during the first week of April far exceeded the number of H-1Bs available.  Many companies were unable to hire all of the foreign-born professional workers that they desired.  Even for employers who filed their petitions that week, the petitions had to be selected according to a lottery system.

With the economy picking up, there is little doubt that there will be another H-1B lottery this year.

What can employers do to prepare?

1)      Remember that there is a limit of 85,000 H-1B petitions which can be approved during the fiscal year.  Of these, 20,000 are reserved for persons with advanced degrees from a university in the United States.  Employers are more likely to have to have their petitions approved for these advanced-degreed professionals, even if the position being offered only requires a Bachelor’s degree or its equivalent.

2)      Employers which are “cap-exempt” do not have to worry about H-1B quotas.  They can sponsor H-1B employees year round and pay less in filing fees.  These employers include: (a) institutions of higher education; (b) non-profit entities which are “related to” or “affiliated with” an institution of higher education; (c) non-profit research organizations; and (d) government research organizations.

3)      An H-1B petition cannot be submitted to the USCIS until a Labor Condition Application (LCA) has been approved by the U.S. Department of Labor (DOL).  Last year, the processing times for LCAs became elongated.  Therefore, it may be wise to file your LCAs in January or February even though this may shave off a few months from the usual 3-year H-1B initial validity period.

4)      Is the prospective employee a citizen of any of the following countries – Canada, Mexico, Australia, Singapore or Chile?  If so, you may be in luck.  Canadian and Mexican professionals may be employed right away in Trade NAFTA (TN) status.  Similarly, professionals who are citizens of Australia may be employed in E-3 status.  Finally, the U.S. has Free Trade Agreements with both Singapore and Chile.  Professionals from these countries are entitled to “H1-B1” status.  They are guaranteed a certain amount of visas each year, and this amount has yet to be reached.

5)      Do you want to obtain an H-1B visa for a physician who has obtained a J waiver?  If so, you are in luck.  Physicians with J waivers are not subject to the H-1B cap.

6)      If you wish to hire a professional who is currently working in H-1B status for another cap-subject employer, he is exempt from the cap, and can start working for you as soon as you file an H-1B petition on his behalf even though the petition has yet to be approved.

If you are an employer and have additional questions about H-1B visas or any other employment-based matter, please do not hesitate to call Attorney Raj Iyer of our law firm at (213) 623-4592 or contact him via e-mail at raj@shusterman.com  Individuals who have questions should schedule a legal consultation (by phone, Skype or in-person) with either Raj or myself.

5. Success Story: From Humanitarian Parolee to Permanent Resident

This month’s success story discusses one family’s struggle to escape violence abroad and to join their son in the United States.

Escaping from the extreme violence and social turmoil in Iraq, Ali’s family crossed the border and found shelter in a U.N. refugee camp in Syria. Ali was the first of his family to come to the U.S., and he became a citizen through his service in the U.S Army. Concerned for his mother and sister’s welfare, Ali filed I-130 immigration petitions for them as soon as he was naturalized.

While Ali’s mother qualified as an immediate relative as a parent of a U.S. citizen, his sister was placed in the 4^th preference category.  After an I-130 was approved on her behalf, Ali’s mother immediately applied for an immigrant visa through consular processing. While an immediate relative can immigrate to the U.S. in a short period of time, it takes over a decade for a sibling to do so.

Since Ali’s sister was only 13 years old, it was unthinkable for his mother to come to the U.S. and leave her behind. It was clear that we had to find a way to bring Ali’s sister to the U.S. as soon as possible.

As public security deteriorated in Syria, hostility began to increase against Iraqi refugees. Many Iraqis, including Ali’s family, received death threats. Fearing for Ali’s sister’s life if she were left alone in Syria, we decided to apply for humanitarian parole on her behalf.

Humanitarian parole is granted sparingly to bring someone who is otherwise inadmissible into the United States for a temporary period of time due to a compelling emergency.

We made the following arguments: (1) Ali was a highly decorated veteran who was trying to provide a safe haven for his family in the U.S.; (2) He had submitted immigrant visa petitions for his mother and sister who had fled Iraq and were living in a U.N. refugee camp; and (3) While Ali’s mother could be granted an immigrant visa within a short period of time, she did not want to leave her 13-year-old daughter alone in a dangerous situation.

The U.S. government granted Ali’s sister’s application for humanitarian parole for a period of two years – a huge relief to her family.

As soon as Ali’s mother was granted permanent residence, both she and her daughter came to the U.S. We immediately submitted an I-130 petition on behalf of Ali’s mother for her daughter under the F2A category (child of a permanent resident), which was a much shorter wait than the F4 category which she had been placed in as a result of Ali’s I-130 petition on her behalf.

A few months before Ali’s sister’s parole was due to expire, we began to prepare an application for an extension of her stay. We began gathering new evidence to show that it was still unsafe for her to return to Syria on her own. However, there was no guarantee that an extension would be granted by the government.

Then, by a stroke of luck, the F2A category became current on August 1, 2013! Since she was legally in the U.S., Ali’s sister was able to apply for adjustment of status without having to request for an extension of her humanitarian parole.

We immediately submitted her application for adjustment of status in case the F2A numbers retrogressed which they did shortly thereafter. Her application was processed smoothly and quickly, and a few months later she received her green card!

The family is overjoyed that they are able to remain in the U.S. together. Ali’s mother and sister look forward to the day when they can become U.S. citizens.

We couldn’t be more delighted!

Read more of our Immigration Success Stories.

6. Trivia Quiz: Immigrant Painters

Quiz Removed

7. State Department Visa Bulletin for January 2014

In the January 2014 Visa Bulletin, the family 2A category (spouses and children of permanent residents) remains September 13, 2013 for the fourth month in a row.
The other family-based worldwide categories moved incrementally forward, between 3 and 5 weeks. The dates for persons born in the Philippines failed to advance in both the 1st category (unmarried sons and daughters of U.S. citizens) and the 2A category.

For persons born in Mexico, all of the family-based categories remain frozen except the 4th preference category which inched ahead by a single week.
The chart below tells the story in more detail:

FAMILY CATEGORIES

Categories	Worldwide	China (PRC)	Mexico	Philippines
1st	12-08-06	12-08-06	9-22-93	7-1-01
2A	9-8-13	9-8-13	9-1-13	9-8-13
2B	6-1-06	6-1-06	4-1-94	5-1-03
3rd	4-15-03	4-15-03	6-1-93	2-1-93
4th	10-1-01	10-1-01	11-1-96	7-1-90

The worldwide EB-1, EB-2, EB-4 and EB-5 priority dates all remain current.

China EB-2 moves forward by 1 month.

The worldwide EB-3 category advances another 6 months to April 1, 2012 with the exception of the Philippines which moves forward 5 weeks and India which remains frozen in time.

After retrogressing over 3 1/2 years late in 2013, India EB-2 also fails to move forward.

The chart below tells the story in more detail:

EMPLOYMENT CATEGORIES

Categories	Worldwide	China (PRC)	India	Mexico	Philippines
1st	Current	Current	Current	Current	Current
2nd	Current	12-8-08	11-15-04	Current	Current
3rd	4-1-12	4-1-12	9-1-03	4-1-12	2-15-07
Unskilled	4-1-12	4-1-12	9-1-03	4-1-12	2-15-07
4th	Current	Current	Current	Current	Current
Religious	Current	Current	Current	Current	Current
5th	Current	Current	Current	Current	Current

8. Immigration Government Processing Times

We link to the most recent immigration waiting times for each of the four USCIS Service Centers, the National Benefits Center and the Administrative Appeals Office. We also link to the processing times of all of the 83 USCIS District Offices and Sub-offices. We link to the Labor Department’s page entitled “Processing dates for labor certification applications”. Finally, we link to the State Department’s “Visa Wait Times” page.

Read more…

9. US Army Offers Expedited Pathway to Citizenship

The following is a message that we recently received from Captain Adam S. Davies, US Army:

(Additional information regarding the MAVNI program is available on our website.)

“The U.S. Army has recently initiated a recruiting program called Military Accessions Vital to the National Interest (MAVNI). The MAVNI program allows certain legal, non-citizens to commission into the Army Officer Corps if they are Healthcare Professionals licensed in the United States. There are annual and specific specialty caps, and applications will no longer be accepted once these caps are met.

“Applicants must enlist for either three years on Active Duty or six years in the Selected Reserve.

“The program is currently in effect until May of 2014. Healthcare Professionals must be board certified to U.S. standards prior to their enlistment.

“Potential applicants should review the program criteria and available specialties.

“If a potential applicant meets these criteria and holds one of the available specialties, the first step is to introduce themselves to their local recruiters by requesting an information packet.

“Applicants will be contacted by their local recruiter to begin the application process. The process will include an initial interview, CV review, medical history review, Live Scan, physical fitness testing, English oral proficiency interview, and other standardized testing. Applicants will also go through security screenings to ensure zero negative history.

“Once complete, applications go before an Army review board. Those applicants selected by the board will be enlisted by their local Military Entrance Processing Station (MEPS). The enlisted member will then serve two “drill” weekends with an Army reserve unit, regardless of whether their endstate is with the Regular Army or the Army Reserve. After the drill weekends are completed, Commanding Officers will provide the applicants a memorandum acknowledging their service.

“Applicants are to include that memo with their required citizenship documentation to INS. Once an applicant is sworn in as a U.S. citizen, the Army can commission them as an Officer, and they can begin practicing their specialty.

“The entire process should take 6 to 8 months.

“An applicant’s visa must not expire until they’ve sworn in as a citizen, so in some cases extensions will need to be requested.

“Applicants in the grace period of their visa may process for enlistment, but must enlist prior to the end of the grace period.

“MAVNI applicants are eligible for the same financial and other incentives that are authorized for their particular specialty.”

10. Winner of our December 2013 Immigration Trivia Quiz!

Quiz Removed

Below is the message we received from the winner:

“1) Freddie Mercury, born in Zanzibar ( now Tanzania), Queen, “We are the champions”

2) Gene Simmons, born in Israel, Kiss, “Deuce”

3) Neil Young, born in Canada, Crosby, Stills, Nash, and Young, “Ohio”

Bernard, born in France, immigrated in 1992.  US citizen since 2004. Subscribed to your newsletter years ago. Married to Nicaraguan immigrant since 2005. We have two children. She entered without inspection so needs I-601A. I recognized these singers, just didn’t know Neil Young was from Canada.”

Congratulations, Bernard! I look forward to assisting you!

Carl Shusterman
Certified Specialist in Immigration Law, State Bar of California
Former Immigration and Naturalization Service (INS) Attorney (1976-82)
Served as Member of AILA Board of Governors (1988-97)
Law Offices of Carl Shusterman, 600 Wilshire Blvd., Suite 1550
Los Angeles, CA 90017, Phone: (213) 623-4592 x0, Fax: (213) 623-3720

“…there are a number of members of Congress who have primaries and when those primaries are done, they may be more inclined to address the issue of comprehensive immigration reform.”

– Senator John McCain (R-AZ)

Newsletter US Immigration Update January 2014 – Quick Links

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Disclaimer: This newsletter is not intended to establish an attorney-client relationship. All information contained in this newsletter is generalized. Any reliance on information contained herein is taken at your own risk.