In a recent decision the BIA held that an IJ may not terminate removal proceedings simply because the respondent was granted Temporary Protected Status (TPS). Matter of Sosa Ventura, 25 I&N Dec. 391 (BIA 2010) (Grant, Malphrus, and Mullane). Board member Malphrus wrote the BIA’s decision.This case involved a citizen of El Salvador who was put into removal proceedings and charged as removable for being in the United States without being admitted.INA § 212(a)(6)(A)(i).The respondent conceded the factual allegations, but sought and received TPS from DHS. Matter of Sosa Ventura, 25 I&N Dec. at 391-92.