J-L-L

Cite as

28 I&N Dec. 684

(BIA 2023) Interim Decision #4058 Matter of J- L- L-, Applicant Decided February 10, 2023 U.S. Department of Justice Executive Office for Immigration Review Board of Immigration Appeals Pereira v. Sessions,

138 S. Ct. 2105

(2018), and Niz-Chavez v. Garland,

141 S. Ct. 1474

(2021), are inapplicable to proceedings initiated by a Notice to Applicant for Admission Detained for Hearing Before Immigration Judge (“Form I-122”) and other charging documents issued prior to the effective date of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, Division C of

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