Matter of Kim
BIA
29 I&N Dec. 339 (BIA 2025)
2025
Holding
IJ erred in finding respondent warranted a favorable exercise of discretion for cancellation where he engaged in systemic criminal fraud for decades; recent expressed remorse and rehabilitative efforts while in prison were insufficient to overcome his lengthy and serious criminal history.
Practitioner Note
Short-term rehabilitation during incarceration carries little weight against decades of serious fraud. Discretion is not rehabilitated overnight.
Topics
This summary describes what the tribunal held. Always verify the citation and read the full decision before relying on it. Case law changes — confirm this decision has not been overruled, limited, or superseded. Not legal advice.