Hachem v. Holder, No. 09-3992 (6th Cir. Aug. 29, 2011) (published)
In this published decision, the Court found that the new voluntary departure regulations, which provide for the automatic termination of a voluntary departure grant upon the filing of a petition for review (subject to narrow exceptions), are a valid exercise of rulemaking authority. The Court found that the regulation applies to grants by IJs before the regulation where the BIA reinstated the grant after the regulation took effect on on January 20, 2009.
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