Jin Bo Zhao v. Immigration and Naturalization Service

We consider here the level of diligence required by a petitioner to merit “equitable tolling” of the regulatory requirements for timeliness and numerosity of motions to reopen immigration decisions.

Petitioner Jin Bo Zhao, a native and citizen of the People’s Republic of China (“China”), seeks review of two separate orders of the Board of Immigration Ap peals (“BIA” or the “Board”) denying his motions to reopen the Board’s earlier order affirming the decision of Immigration Judge Charles M. Honeyman (the “IJ”) that denied Zhao’s application for asylum, withholding of removal, and voluntary…