Matter of Buri Mora
29 I&N Dec. 186 (BIA 2025)
2025
Holding
Respondent has not established exceptional and extremely unusual hardship where qualifying relatives will remain in the United States and treatment for their mental health conditions and developmental delays will not be affected by the respondent's removal; economic detriment and emotional hardship of family separation, standing alone, do not suffice.
Practitioner Note
Reaffirms that hardship must be to the qualifying relative, not to the applicant personally. Where children stay in the U.S. and retain access to services, removal of the parent usually falls short.
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