HO

19 I. & N. Dec. 582
CourtBoard of Immigration Appeals
DecidedJuly 1, 1988
DocketID 3051
StatusPublished
Cited by50 cases

This text of 19 I. & N. Dec. 582 (HO) is published on Counsel Stack Legal Research, covering Board of Immigration Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HO, 19 I. & N. Dec. 582 (bia 1988).

Opinion

Interim Decision 4t 8051

MATTER OF HO

In Visa Petition Proceedings

A-24247019

Decided by Board March 17, 1988

(1) The petitioner bears the burden in visa petition revocation proceedings of estab- lishing that the beneficiary qualifies for the benefit sought under the immigration laws. Matter of Cheung 12 I&N Dec. 715 (BIA 1968), reaffirmed- (2) Approval of a visa petition vests no rights in the beneficiary of the petition but is only a preliminary step in the visa or adjustment of status application procebs, and the beneficiary is not, by mere approval of the petition, entitled to an immi- grant visa or to adjustment of status. (3) The realization by the district director that he made an error in judgment in initially approving a visa petition may, in and of itself, be good and sufficient cause for revoking the approval, provided the district director's revised opinion is supported by the record. (4) Doubt cast on any aspect of the petitioner's proof may lead to a reevaluation of the reliability and sufficiency of the remaining evidence offered in support of the visa petition. (5) Evidence serving as the basis of a notice of intention to revoke approval of a visa petition need not have been previously unavailable or undiscoverable. (6) It is incumbent upon the petitioner to resolve any inconsistencies in the record by independent objective evidence, and attempts to explain or reconcile such in- consistencies, absent competent objective evidence pointing to where the truth, in fact, lies, will not suffice.

ON BEHALF OF PNITHONER: ON BEHALF OF SERVICE: Sam Bernsen, Esquire David M. Dixon Fragomen, Del Rey & Bernsen, P.C. Appellate Counsel 1140 Connecticut Avenue, N.W. Suite 1000 Glyndell E. William' Washington, D.C. 20036 General Attorney

BY: Milhollan, Chairman; Dunne, Morris, Vacca, and Heilman, Board Members

In a decision dated May 2, 1985, the district director revoked his prior approval of the visa petition which the petitioner had filed to accord the beneficiary preference status as his unmarried son pur- 582 Interim Decision # 3051

scant to section 203(aX1) of the Immigration and Nationality Act, 8 U.S.C. § 1153(a)(1) (1982). The petitioner appealed from that deci- sion and oral argument in the case was heard by the Board on June 4, 1986. The appeal will be dismissed. The petitioner, a 55-year-old native of the People's Republic of China ("PRC") and citizen of the United States, immigrated to this country with his wife and five biological children on September 19, 1968. The petitioner claims that he and his wife adopted the benefi- ciary in the PRC in 1966 when the beneficiary was 7 years old. In order to qualify as a "son" for the purpose of obtaining prefer- ence status under the immigration laws, the beneficiary must once have qualified as a "child" of the petitioner as that term is defined by section 101(b)(1) of the Act, 8 U.S.C. § 1101(bX1) (1982); Matter of Coker, 14 I&N Dec. 521 (BIA 1974). Section 101(bX1)(E) of the Act includes within the definition of the term "child" an adopted child, provided the child was legally adopted while under the age of 16 years and the child resided with and was in the legal custody of the adopting parent or parents for the requisite 2-year period.' The petitioner filed his visa petition on the beneficiary's behalf on May 9, 1979. On February 4, 1982, the district director issued a notice Of intention to deny the visa petition on the ground that the evidence submitted failed to establish that the beneficiary qualified as the petitioner's adopted child. On August 17, 1982, following the submission of additional evidence by the petitioner, the visa peti- tion was approved and was forwarded to the American consulate general in Guangzhou, PRC. The consulate general returned the visa petition to the district director for possible revocation on De- cember 6, 1983, setting forth reasons for its belief that the claimed adoption may not have taken place and, 'further, that the 2-year residence and legal custody requirements of section 101(bX1XE) had not been satisfied. In a letter dated January 24, 1985, the district director notified the petitioner of his intention to revoke his approval of the visa pe- tition based upon the recommendation of the American consulate general at Guangzhou, and he granted the petitioner 15 days within which to offer evidence in opposition to the grounds for rev- ocation cited in the consulate general's report. The petitioner was

" Under the law in effect at the time the petitioner filed his visa petition, periods of residence both prior and subsequent to the adoption could be considered in deter- mining whether the residenmt requirement of section 101(bX1XE) had been met, but the child had to be in the legal custody of the adopting parent for 2 years following the adoption. The requirement that the legal custody provision could only be satis- fied subsequent to the adoption was eliminated by section 2 of the Immigration and Nationality Act Amendments of 1936, Pub. L. No. 99-653, 100 Stet. 3655. Interim Decision #3051

provided with a copy of the report, both prior and subsequent to the notice of intention to revoke, and he responded through letters of counsel dated October 22, 1984, and March 4, 1985. On May 23, 1985, notwithstanding the petitioner's rebuttal, the district director determined that the petitioner had failed to demonstrate compli- ance with the residence and legal custody requirements of the stat- ute, and he accordingly revoked his approval of the visa petition. The consulate general's report, upon which these revocation pro- ceedings are based, expressed doubt both as to whether an adoptive relationship was in fact created and whether the 2-year residence and legal custody requirements of section 101(b)(1)(E) had been sat- isfied. Since the district director's decision to revoke his approval of the visa petition was grounded solely on the petitioner's failure to establish compliance with the residence and legal custody require- ments of the Act, we shall focus on those aspects of the record that relate to the stated ground for revocation. Offered in support of the visa petition when it was first before the district director were several letters to the petitioner and his wife from the beneficiary, money order receipts, affidavits, and Chi- nese documents. Those documents included an adoption agreement, purportedly signed by the petitioner and his wife and the benefi- ciary's natural mother, which recites that the agreement was made on April 2, 1967. In an affidavit dated July 7, 1981, the petitioner's wife stated that she and the petitioner adopted the beneficiary in June 1966, some 10 months prior to the date the adoption agreement was exe- cuted, following the death of the beneficiary's natural father. The petitioner's wife explained that she had not realized the would need documentation for the adoption until the family began ar- rangements to immigrate to the United States. She stated that her husband, the petitioner, lived in Hong Kong 2 and was fearful of returning to their village in the PRC, having once been detained by the Communist regime as the son of a landlord. She asserted that she accordingly "had the responsibility of living in the village to- gether with my adopted son to look after our farmlands being tilled by our workers." She claimed that her residence was in the village except for periodic visits to Hong Kong to be with her husband.

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