In Depth look at the effects of ICE Raid on TNReady Scores

The New Yorker's Jonathan Blitzer takes an in depth look at the ripple effects of an ICE raid on a small East Tennessee towns children. Blitzer looks at unintended consequences on TN Ready scores. For more click here.

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Bill to Punish Sanctuary Cities Temporarily Fails

Legislation sponsored by Rep. Jay Reedy, R-Erin, that would have financially punished any city in Tennessee that became a sanctuary city, was defeated with a voice vote when it was taken up in the House finance committee, The Tennessean reports. The committee then voted to revisit the bill at a later date. To read more click here.

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House Committee Temporarily Halts Bill Banning Sanctuary Cities

A bill that would punish so-called “sanctuary cities” in Tennessee and mandate that law enforcement cooperate with immigration officials was defeated in a state House committee meeting today, The Tennessean reports, but it may face another vote. The bill, sponsored by Rep. Jay Reedy, R-Erin, was defeated with a voice vote. Rep. Patsy Hazlewood, R-Signal Mountain, expressed concern about the financial impact of the measure. After a recess of the committee, a motion was made to reconsider the initial vote. That motion passed, meaning the committee will look at the bill again, although it is unclear whether it will be reconsidered before the session adjourns for the year.
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7th Circuit Upholds Injunction Barring DOJ from Withholding Grants from Sanctuary Cities

The 7th U.S. Circuit Court of Appeals today upheld a nationwide injunction that bars the Department of Justice from withholding public safety grants from cities that don’t cooperate with immigration enforcement, the ABA Journal reports. “The power of the purse rests with Congress,” Judge Ilana Rovner wrote in her majority opinion. “Which authorized the federal funds at issue and did not impose any immigration enforcement conditions on the receipt of such funds.”
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ABA President Calls for Overhaul of Immigration Court System in Senate Testimony

American Bar Association President Hilarie Bass called for an overhaul of the immigration court system during testimony today before a U.S. Senate subcommittee, the ABA Journal reports. Speaking before the Judiciary Committee’s Subcommittee on Border Security and Immigration, Bass said immigration courts should be restructured as independent Article I courts, and immigrants should be given increased access to counsel and legal information.
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Attorneys Claim Memphis Reporter Arrested Over Negative Coverage

Attorneys for Manuel Duran, a reporter who was arrested and then picked up by federal immigration agents in Memphis, claim that their client was targeted for arrest due to critical reporting, The Commercial Appeal reports. Duran was arrested alongside demonstrators during a protest on April 3 because he refused commands to leave the street. Charges stemming from the protest were dropped two days later, but shortly after he was picked up and detained by U.S. Immigration and Customs Enforcement. He remains in detention at a facility in Louisiana.
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Bill Prohibiting Sanctuary Cities, Requiring ICE Collaboration Passes House Committee

A bill that would explicitly ban sanctuary cities in Tennessee and require local law enforcement to detain certain immigrants passed the House State Government Committee today, The Tennessean reports. Tennessee currently doesn’t have any sanctuary cities and the executive director of the Tennessee Sheriffs’ Association says that the current detainer system is working, but proponents of the measure say it’s necessary to avoid issues seen in other states. The Senate version of the bill is set to be taken up tomorrow.
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East Tennessee ICE Crackdown Called ‘Largest Workplace Raid in a Decade’

The Immigration and Customs Enforcement raid conducted at the Southeastern Provision meatpacking plant in Bean Station on Thursday constituted the “largest single workplace raid in a decade,” The Washington Post reports. Ten people were arrested on federal immigration charges, one was arrested on state charges and 86 immigrants were detained for being in the country illegally. Volunteers interested in helping the affected families should sign up with the Tennessee Immigrant and Refugee Rights Coalition here.
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Sessions Announces Zero-Tolerance Policy for Border Crossings

Attorney General Jeff Sessions announced today a “zero-tolerance” policy for people entering the United States illegally on the Mexican border, the Associated Press reports. The directive tells federal prosecutors in border states to put more emphasis on charging people with illegal entry, which has previously been treated as a misdemeanor offense for first-timers. Smugglers and repeat offenders are usually charged with more serious crimes.
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Immigration Raids Performed in Grainger County

The Department of Homeland Security Investigations division and the IRS conducted immigration raids in Morristown this morning, the Citizen Tribune reports. The Southern Provision slaughterhouse was the site of the enforcement action, and multiple individuals were detained at the National Guard Armory. Immigration attorneys wishing to volunteer in their cases should contact the Tennessee Immigrant and Refugee Rights Coalition at or

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Social Hour for Immigration Lawyers on Friday

The TBA Immigration Law section will hold a cocktail reception immediately following its forum on April 6. Immigration practitioners and CLE attendees are welcome to attend. The reception start at 3 p.m. at the Tennessee Bar Center. For questions, contact TBA staffer Wil Hammond.
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States File Suit Against Trump Administration Over Census Citizenship Question

Seventeen states, the District of Columbia and six cities sued the U.S. government Tuesday, saying the addition of a citizenship question to the census form is unconstitutional, the Associated Press reports. The Trump administration's plan to ask a citizenship question on the 2020 census marks the first time in 70 years the federal government has asked such a question. Tennessee is not currently on the list of states pursuing legal action. California filed a separate lawsuit last week.
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ABA Files SCOTUS Brief Urging Rejection of Latest Trump Travel Ban

The American Bar Association filed an amicus brief Friday with the U.S. Supreme Court supporting Hawaii’s challenge to President Donald Trump’s revised executive order banning all immigration from six majority-Muslim nations, including five covered under previous versions of the executive order. Like the amicus briefs filed in previous cases, the ABA brief takes issue with the Trump administration’s contention that the executive order is unreviewable by the courts, including the Supreme Court. “The government contends that this sweeping exercise of authority by the president is simply unreviewable,” the brief said. “That position cannot be reconciled with this court’s precedent and with the rule of law.”
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Legislature Considers Banning Acceptance of Consular ID Cards

The Tennessee legislature is now considering legislation that would prohibit state and local officials from accepting student IDs, library cards and matricula consular IDs, The Tennessean reports. Consular IDs are commonly used by Mexican immigrants to verify their identity and help the Mexican government track its citizens. The bill will be taken up by the House State Government Committee at its final meeting tomorrow.
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California, New York Sue Over Addition of Citizenship Question to Census

The state of California filed a lawsuit against the Trump administration last night over the decision to add a question about citizenship to the 2020 Census, The Washington Post reports. Today, New York Attorney General Eric Schneiderman announced that he would lead a multi-state lawsuit to fight the measure. California’s lawsuit alleges that the change violates the constitutional requirement of “actual enumeration” of every person in every state, every 10 years.
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10 Essential Documents for Your Practice

Instructions and rules for client file retention, list of current curse and copy of bank’s form for IOLTA access are three of the top 10 documents attorneys need for succession planning and practice management. Learn more in this 3-hour dual credit workshop with attorney Timothy Takacs.

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Letter from Editor

I would like to thank Chay Sengkhounmany and Terry Olsen for writing excellent articles for this issue. I’m always looking for writers and articles on a variety of topics, including family-based immigration issues, employer-based immigration issues, crimimigration, and immigration court/custody issues. Please feel free to contact me at or 615-345-0266 concerning writing an article.

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The “Almost One Year” Anniversary of the “Buy American and Hire American” Executive Order

On April 18, 2017, President Trump signed the Executive Order (EO) “Buy American and Hire American," which has two distinct components – buying American-made goods and enforcing immigration laws in order to create higher wages for workers inside the United States. The EO calls for a shift away from manufacturing goods outside of the United States to conducting production inside the United States.  
The two sides of Buy American and Hire American - products almost entirely created in the United States, and stricter immigration enforcement - work together to create the desired result of the Executive Order, which is protecting “American Workers." First, by mandating production to be conducted mostly inside the United States, Americans will in theory purchase exclusively American made products. Second, by rigorously enforcing tougher immigration policies towards foreign nationals, American owners of businesses will in theory hire more “Americans."
Hire American
The substantive portions of the EO related to Hire American are as follows: Secretaries of State, Labor, Department of Homeland Security (DHS) and the Attorney General, “shall, as soon as practicable, and consistent with applicable law, propose new rules and issue new guidance, to supersede or revise previous rules and guidance if appropriate, to protect interests of U.S. workers in administration of our immigration system, including through prevention of fraud or abuse.” Furthermore, it states: “In order to promote the proper functioning of the H-1B visa program, the Secretary of State, the Attorney General, the Secretary of Labor and the Secretary of Homeland Security shall, as soon as practicable, suggest reforms to help ensure that H-1B visas are awarded to the most-skilled or highest-paid petition beneficiaries.”
When Buy American and Hire American was first announced, many immigration lawyers, and international business/trade lawyers were shocked about the intent and language of the EO but wondered how much of an effect the EO would have on immigration laws due to its vagueness. However, time has shown it has had a major effect. The following are some of the ways: 1) USCIS’s “Policy Memorandum: Rescission of Guidance Regarding Deference to Prior Determinations of Eligibility in the Adjudication of Petitions for Extension of Nonimmigrant Status” – meaning the USCIS can re-adjudicate H-1B extension petitions; 2) additions to the Foreign Affairs Manual (FAM), used by the Department of State consular officers, to keep the “spirit” of the EO in mind – remembering to protect American workers regarding wages and “prevention of fraud or abuse” when adjudicating H-1B, L, O-1, E-1, E-2 and P visas; 3) postponement and probable withdrawal of the International Entrepreneur Rule, which was expected to go into effect on July 17, 2017; 4) the new requirement for in-person interviews for all employment-based immigration cases, effective October 1, 2017; and 5) the proliferation of RFEs on H-1B applications.
Buy American
On the commerce/manufacturing side, within the first 150 days of the EO, federal agencies were required to develop federal programs, and rules to ensure that federal financial assistance awards, and federal procurements create a business environment in the United States for materials to be produced in the United States, and for products to be made entirely in the United States. Additionally, within the first 150 days of EO, all free trade agreements, and the World Trade Organization Agreement on Government Procurement were reviewed and analyzed with the intent of fulfilling the objectives of Buy American and Hire American. Within 220 days of EO’s issuance, the Secretary of Commerce along with the Secretary of State, the Director of the of Management and Budget, and the United States Trade Representative were required to submit a Report to President Trump regarding how to strengthen the implementation, and effect of Buy American and Hire American—specifically including domestic procurement preference policies and programs. Also, the required agencies must submit subsequent implementation reports on November 15, 2018, November 15, 2019, and November 15, 2020.
As time marches on, you will see the EO leaving the infancy period and transitioning to the toddler stage in a year or so.  And by 2020 and beyond, Buy American and Hire American will be a growing child with the ability to speak and argue for itself. And as a child often does, Buy American and Hire American will not only be learning only from others and its environment, but it will then be teaching others in turn and will be the focus of its world.
Even though Buy American and Hire American is less than a year old, it is very apparent that it is not going away anytime soon, and most likely will be here for a very long time. For example, as the Deferred Action for Childhood Arrivals Executive Order has shown to the American public that even if an Executive Order may later be viewed as unconstitutional and is fought in the court system, its effect(s), and its very life does not go away from the American culture, and people right away—if at all. Subsequently, even though the existence of this EO may not make sense right now, or if at all—with the passing of time, the changing of language, and with memory being less pungent— Buy American and Hire American is a fact, and item of essential detail which must be seen in its entirety of effect, and result.
The author is Terry Olsen, the founder of his own immigration law practice, Olsen Law Firm, in Chattanooga, Tennessee.  His practice areas include both employment and family immigration law.  Mr. Olsen is the Chair of the TBA’s International Law Section. He may be contacted at or (423) 648-9390.  
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Worksite Enforcement is on the Rise

As I have been discussing in my blog, Immigration and Customs Enforcement (ICE) is taking a much more aggressive approach to worksite enforcement, also called employer immigration compliance. I will detail several actions by ICE in 2018 that demonstrate this aggressive approach.
Memphis Enforcement Action
The first example hits close to home as 20 undocumented workers were indicted for using fake identification to obtain their jobs with Provide Staffing Services, a staffing agency, at Memphis International Airport. According to Michael Dunavant, the U.S. Attorney for the Western District of Tennessee, no one with the company that hired the workers has been indicted but the investigation is ongoing.  
Robert Hammer, assistant special agent in charge with Homeland Security Investigations (HSI), stated the federal government is aggressively pursuing this case because the undocumented workers had access to a sensitive air cargo area at Memphis International Airport that required special clearance. “It is imperative for the safety and security of our airports, seaports and railyards that all individuals requiring this type of special vetting present valid and genuine identification documents in the hiring process,” he said. Hammer also stated worksite immigration investigations will likely focus on "critical infrastructure," such as airports, defense contractors, food distribution and other businesses that have an impact on the general safety and welfare of the community. 
The U.S. Attorney also stated ICE plans to increase its focus on this type of criminal investigation in Tennessee throughout 2018: "Our enforcement strategy is going to be dual-pronged, focusing on both employers and the employees.” 
7-Eleven “Silent Raids”
In a true show of force, ICE delivered Notice of Inspections (NOIs) (sometimes referred to as “silent raids”) at almost 100 7-Eleven stores nationwide in January 2018 demanding to see the I-9 forms of all employees. Furthermore, ICE detained 21 employees. Thomas Homan, acting director of ICE, issued a statement – “Today’s actions send a strong message to U.S. businesses that hire and employ an illegal workforce: ICE will enforce the law, and if you are found to be breaking the law, you will be held accountable.”
ICE referred to its 7-Eleven actions as a “follow-up” of a 2013 investigation that resulted in the arrests and convictions of five 7-Eleven franchise owners in New York and Virginia for harboring undocumented workers and wire fraud. Because of these convictions, it spawned the largest forfeiture in ICE history – forfeiture of franchise rights to 14 stores, forfeiture of five houses, valued at $1.3 million, and restitution of over $2.6 million for back wages stolen from employees. After the convictions of the store owners in New York and Virginia in 2013 and 2014, 7-Eleven’s corporate office stated it would “take aggressive actions to audit the employment status of all of its franchisees’ employees.” However, after the most recent actions, 7-Eleven management issued a statement appearing to try and wash their hands of any responsibility or liability for the franchisees’ actions.
ICE’s New Three-Prong Approach to Worksite Enforcement
Immediately after the 7-Eleven enforcement actions, ICE announced a three-prong approach to conduct worksite enforcement. This strategy involves: immigration compliance, through Form I-9 inspections, civil fines and referrals for debarment; enforcement, through the arrest of employers, knowingly employing undocumented workers, and the arrest of unauthorized workers for violation of laws associated with working without authorization; and outreach, through the IMAGE program, to instill a culture of compliance and accountability.
“Homeland Security Investigations (HSI) prioritizes violators who abuse and exploit their workers, aid in the smuggling or trafficking of their alien workforce into the United States, create false identity documents or facilitate document fraud, or create an entire business model using an unauthorized workforce,” said HSI Acting Executive Associate Director Derek Benner. “Further priority is given to looking closely at those companies or industries that are deemed national security or critical infrastructure interests.” ICE also stated an effective worksite enforcement strategy must address both employers who knowingly hire illegal workers, as well as the workers themselves.
California “Silent Raids”
In February, ICE announced it conducted I-9 inspections of 77 employers in the San Francisco and Sacramento areas over a three-day period. A few days later, ICE issued NOIs for almost 10 employers in the Fresno, California. ICE refused to identify any of the businesses visited by its agents. However, just the fact that ICE served subpoenas on so many employers demanding their I-9 forms and then announced it to the media, demonstrates ICE is trying to put the fear of government action in the minds of every employer.
Cost of Non-Compliance of Immigration Laws
So, what do these enforcement actions potentially cost employers? After the businesses comply with the subpoena/NOI, ICE auditors will carefully review the I-9 forms to determine whether undocumented workers are employed at the business and whether the I-9 forms have substantive errors, which could cost $224 to $2,236 per I-9 form. As an example, if an employer employs 100 employees, of which 50 have one or more I-9 substantive errors, then that employer’s liability is at least $92,750. For larger business, the penalties would be greater if the 50 percent error rate continued. 
If undocumented workers are employed, ICE may return to the employer and detain the undocumented workers. Alternatively, ICE may issue a Notice of Suspect Documents to the employer stating which employees do not have valid work authorization. If after the employer gives its employees an opportunity to provide valid documentation (“newer and better documentation”), the employees fail to provide such, the employer must discharge those employees or face fines of up to $4473 per employee.

— Bruce E. Buchanan is the founding partner of Sebelist Buchanan Law PLLC located in Nashville and Atlanta. He is also “Of Counsel” to Siskind Susser PC on employer immigration compliance matters. Buchanan is a graduate of Vanderbilt University School of Law. He has co-authored a book, I-9 and E-Verify Handbook, 2d ed. (2017). Reach him at or (615) 345-0266.
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Termination of TPS – Are There any Other Options Available

The Trump Administration has revoked the Temporary Protected Status (TPS) designations for four countries and is set to review the designations for several more countries in 2018. The TPS revocations will affect over 300,000 people who will lose TPS by the end of 2019. Many of these TPS holders have lived in the United States for decades and have developed significant family and economic ties to this country. In the ensuing months prior to the termination of their TPS status, TPS recipients must explore other immigration options. Termination of TPS means they will be undocumented and not be authorized to work or stay in the United States. This article will cover two specific options as they relate to TPS. Keep in mind that options other than the two discussed may be available and should also be explored.

A.   Adjustment of Status

To be eligible to adjust status under INA § 245(a) to legal permanent residence, an individual must have been “inspected and admitted or paroled” into the United States. He or she must be admissible, and an immigrant visa must be immediately available. Generally, those who entered without inspection cannot adjust status under INA § 245(a) because they have not been inspected and admitted or paroled. However, the Sixth Circuit[1] and Ninth Circuit[2] Courts of Appeal have held an individual holding TPS status who initially entered without inspection will be considered to have been inspected and admitted for the purposes of adjusting status under INA § 245(a).

In making their decisions, the circuit courts analyzed INA § 244(f)(4), which states:

(f) Benefits and Status During Period of Temporary Protected Status. — During a period in which an alien is granted temporary protected status under this section—

(4) for purposes of adjustment of status under section 245 and change of status under section 248, the alien shall be considered as being in, and maintaining, lawful status as a nonimmigrant.

The courts held the plain meaning of the phrase “for purposes of adjustment of status under section 245” applies to all of section 245, and so a person granted TPS “shall be considered as being in, and maintaining, lawful status as a nonimmigrant” for purposes of adjustment of status under section 245(a).[3]  Therefore, the courts concluded a grant of TPS must constitute an “admission” for adjusting status.Individuals who meet the following requirements are eligible to adjust their statuses because of the rulings in Ramirez and Flores:  1) those living in a state within the jurisdiction of the Sixth and Ninth Circuits; 2) those currently in TPS status; 3) those who are immediate relatives of U.S. citizens, i.e. children and spouses of U.S. citizens and the parents of U.S. citizens who are 21 or older; and 4) those who initially entered without inspection and would otherwise be eligible for adjustment of status to lawful permanent resident status.

The issue of whether a person whose TPS was terminated or expired continues to satisfy the “inspected and admitted” requirement remains unresolved. The Ramirez and Flores cases involved plaintiffs who were currently in TPS status. The language of INA § 244(f)(4), which the courts based their decisions on, refer specifically to the period in which a person is granted TPS status. An American Immigration Council (AIC) Practice Advisory, “Court Decisions Ensure TPS Holders in Sixth and Ninth Circuits May Become Permanent Residents”, dated September 16, 2017, states USCIS will likely deny an adjustment of status application by relying upon the statutory language -  “During the period in which an alien is granted temporary protected status under this section - … (4) for purposes of adjustment of status under section 245 … the alien shall be considered as being in, and maintaining, lawful status as a nonimmigrant.” INA § 244(f)(4).  Additionally, the AIC Practice Advisory states USCIS may cite Medina v. Beers, 65 F.Supp. 3d 419, 431 (E.D. Pa. 2014), which held TPS recipient’s “failure to maintain [TPS] status—by failing to re-register for TPS or by otherwise making him or herself ineligible for TPS—would be grounds for denying an adjustment to lawful permanent resident status.” Additionally, the argument that a TPS holder would “revert” to an unadmitted status is bolstered by the Ninth Circuit’s decision in United States v. Hernandez-Arias, 757 F.3d 874 (9th Cir. 2014), which held that if temporary resident status under IRCA was terminated, an applicant for adjustment of status was no longer considered admitted.

In the jurisdictions outside of the Sixth and Ninth Circuits, USCIS does not consider a grant of TPS to be an admission for adjustment purposes. Also, the Eleven Circuit Court of Appeal has held that TPS is not an admission.  For those TPS holders who entered without inspection living in jurisdictions outside of the Sixth and Ninth Circuits, adjustment of status based on being inspected and admitted is not an option. 

B.    Advance Parole

An alternative option for those outside of the Sixth and Ninth Circuit is travelling on advance parole. Advance parole allows the person to have a lawful means of returning to the United States after a brief trip abroad. TPS holders are specifically allowed by statute to travel while in TPS status.[4]  The regulations do not require any specific reasons for travel[5], and advance parole for TPS holders have been granted for personal and business reasons. A person who travels and returns on an advance parole will not trigger the three-or-ten-year unlawful presence bars because he or she has not made a legal departure.[6]  Upon return to the United States with advance parole, a TPS holder will be paroled in and thus, eligible for adjustment of status (as long as they meet the other requirements) without the need for an unlawful presence waiver. Bear in mind that travelling on advance parole may be risky and being granted advance parole does not guarantee admission back into the United States.


Countries currently designated for TPS




Re-registration period

TPS designation Date

Number of people affected

El Salvador



01/18/2018 – 03/19/2018






01/18/2018 – 03/19/2018



























South Sudan

























Author Chay Sengkhounmany formed her own law firm, Sengkhounmany Law, about four years ago after working for Legal Aid Society of Middle Tennessee and the Cumberlands for 10 years, seeking humanitarian immigration relief, such as VAWA, T visas and U visas. Sengkhounmany holds a law degree from Georgia State University College of Law. She may be reached at or 615-667-0270.

[1] See Flores v. USCIS, 718 F.3d 548 (6th Cir. 2013)

[2] See Ramirez v. Brown, 852 F.3d 954 (9th Cir. 2017),

[3] Ramirez, 852 F.3d at 962; Flores, 718 F.2d at 553.

[4] INA § 244(f)(3).

[5] 8 CFR § 244.15.

[6] Matter of Arrabelly and Yerrabelly, 25 I&N Dec. 771 (BIA 2012).

[7] 83 Fed. Reg. 2654 (Jan. 18, 2018).

[8] 66 Fed. Reg. 14214 (Mar. 9, 2001).

[9] 83 Fed. Reg.  2648 (Jan. 18, 2018).

[10] 75 Fed. Reg. 3476 (Jan. 21, 2010).

[11] 82 Fed. Reg. 59630 (Dec. 15, 2017).

[12] 64 Fed. Reg. 524 (Jan. 5, 1999).

[13] 81 Fed. Reg.  74470 (Oct. 26, 2016).

[14] 80 Fed. Reg. 36346 (Jun. 24, 2015).

[15] 82 Fed. Reg. 59636 (Dec. 15, 2017).

[16] 64 Fed. Reg. 526 (Jan. 5, 1999).

[17] 82 Fed. Reg. 4905 (Jan. 17, 2017).

[18] 56 Fed. Reg. 46804 (Sept. 16, 1991).

[19] 82 Fed. Reg. 44205 (Sept. 21, 2017).

[20] 76 Fed. Reg. 63629 (Oct. 13, 2011).

[21]  82 Fed. Reg. 47228 (Oct. 11, 2017).

[22] 62 Fed. Reg. 59737 (Nov. 4, 1997).

[24] 77 Fed. Reg. 19026 (March 29, 2012), and correction at 77 FED. REG. 20046 (April 3, 2012).

[25] 82 Fed. Reg. 859 (Jan. 4, 2017).

[26] 80 Fed. Reg. 53319 (Sept. 3, 2015).

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Immigration Law Forum Reception

The TBA Immigration Law section will hold a cocktail reception immediately following its forum on April 6. Join friends and colleagues to relax and unwind after the program.
This event provides a great opportunity to meet leadership of the organization while networking with attorneys and professionals with a similar focus. Forum attendance is not required to attend the reception. Here’s the key info:
  • When: April 6, 3 p.m., CDT
  • Where: Tennessee Bar Center, 5th Floor Terrace Room, 221 4th Ave N., Nashville, TN 37219
  • To learn more: Contact Wil Hammond with any questions.
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Immigration Law Forum 2018

Join your colleagues for the 2018 Immigration Law Forum on April 6 at the Tennessee Bar Center. This seminar will offer practical tips to both experienced immigration attorneys as well as those practitioners who are just getting started, or attorneys whose representation of foreign national clients in juvenile or criminal matters could touch on immigration-related issues. Learn more or register today!

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House Committee Approves In-State Tuition for Immigrants

The Tennessee House Education Administration and Planning Subcommittee today approved a bill that would grant in-state tuition to undocumented and immigrant students, The Tennessean reports. Last year, the bill failed in the same committee by a 7-6 vote. Gov. Bill Haslam has expressed support for the measure, and even took photos with students who came to the Capitol to rally for the bill’s passage.
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SCOTUS Denies Request to Review Judge’s Ruling on DACA

The U.S. Supreme Court today refused to review an injunction that prevents the Trump administration from phasing out DACA, the ABA Journal reports. The Supreme Court denied the U.S. Justice Department’s request for "certiorari before judgment," a process for direct, immediate review of cases, usually involving issues of national crisis. The preliminary injunction in question was issued by U.S. District Judge William Alsup of San Francisco. According to a brief filed in the case, it has been nearly 30 years since certiorari before judgment was used to decide a case before a federal appeals court issued its decision. The Supreme Court can still decide to hear the case after a decision by the 9th Circuit Court of Appeals. 
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