U.S. Department of Justice
Executive Offices of Immigration Review
Board of Immigration Appeal
Cite as 26 I&N Dec. 693 (BIA 2015)
Interim Decision #3854
693
The 10 years of continuous physical presence required by 8 C.F.R. § 1240.66(c)(2)
(2015) for aliens seeking special rule cancellation of removal under section 203 of the
Nicaraguan Adjustment and Central American Relief Act, Pub. L. No. 105-100, tit. II,
111 Stat. 2160, 2193, 2196 (1997), amended by Pub. L. No. 105-139, 111 Stat. 2644
(1997), should be measured from the alien’s most recently incurred ground of removal,
at least where that ground is among those listed in 8 C.F.R. § 1240.66(c)(1).
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