J-O-A

Cite as

29 I&N Dec. 672

(BIA 2026) Interim Decision #4202 Matter of J-O-A-, Respondent Decided June 4, 2026 U.S. Department of Justice Executive Office for Immigration Review Board of Immigration Appeals (1) The respondent’s conviction for health care fraud under

18 U.S.C. § 1347

is for a particularly serious crime. (2) Given the absence of any direct encounters with the criminals the respondent fears, insufficient evidence that his relatives or employees have been targets of kidnapping, and the respondent’s ability to relocate within Nigeria, the Immigration Judge permissibly found that it is…