By Alex SheppardIn a decision published Friday, April 17, 2015, the Board of Immigration Appeals (BIA) chose to follow its prior opinion in Matter of Avetisyan, 25 I&N Dec. 688 (BIA 2012), and found that, where warranted, removal proceedings may be delayed. Matter of Montiel, 26 I&N Dec. 555 (BIA 2015). In Matter of Montiel, the BIA granted a motion to administratively close immigration proceedings because a direct appeal of the respondent’s criminal conviction remains pending in the Ninth Circuit.