Matter of C-P-Y-
BIA
29 I&N Dec. 610 (BIA 2026)
2026
Holding
The words 'arrival' and 'arrived' in the serious nonpolitical crime bar provisions at INA §§ 208(b)(2)(A)(iii) and 241(b)(3)(B)(iii) refer to the alien's most recent arrival in the United States.
Practitioner Note
Resolves a circuit split on whether the crime's timing is measured from first or most recent entry. The most recent arrival controls.
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