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).

org/resources/removal-proceedings/end-administrative-closure-sessions-moves-further-strip-immigration; See also Brief of Amicus Curiae Catholic Legal Immigration Network, Inc. at 2, Matter of Castro-Tum, 27 I&N Dec. 271 (A.G. 2018) (“Although administrative closure, a docket-controlling measure used by courts and administrative agencies, previously without much controversy, is not explicitly mentioned in immigration statute, it is a well-authorized tool for the administration of justice.”)Id. Matter of Castro-Tum, 27 I&N Dec. at 271.Id. at 272-73 (citing Matter of Avetusyan, 25 I&N Dec. 688, 692 (BIA 2012)).Id. at 271 (“For cases that truly warrant a brief pause, the regulations expressly provide for continuances. 8 C.F.R. § 1003.29.”).Id. at 293.