January 26th, 2011 
Max Nuyen Matter of Sosa Ventura (B.I.A. 2010)
This case delineates the limitations of Temporary Protected Status (“TPS”). Congress created TPS in order to allow persons whose home country is in a state of drought, famine, civil strife, or warfare who otherwise would not qualify for asylum or refugee status the chance to remain lawfully in the United States. It only applies to persons who are physically present in the country, not to those who are outside U.S. borders. TPS applies regardless of the person’s status or lack thereof. That is, a person who entered the country without inspection (and thus, without status) may nonetheless qualify for TPS even though under typical immigration scenarios, such a person would be disqualified from receiving any type of immigration benefit. TPS provides a person who entered without inspection a waiver and allows such a person to remain in the country and even authorizes employment. A person in TPS status may not be placed in removal proceedings while the status is current. However, such benefits are only temporary. TPS is not an immigration status. It is merely a waiver against removal for humanitarian reasons.
This case involved a national from El Salvador, who had entered the country without inspection. She was placed in removal proceedings. She applied for TPS status, and the government granted it (El Salvador has been a TPS country for over a decade now). Afterwards, she requested that her removal proceedings be administratively closed. The government agreed with her request. In the removal context, to “administratively close” a case is simply to take the case off the immigration judge’s docket for a temporary time period. The case is still considered pending, but nothing occurs because all activities are placed on hold. The case may be quickly reactivated at a later date if circumstances change. This is what all the parties asked the immigration judge to do.
Instead, the judge terminated the proceedings. By terminating the proceedings, the judge dismissed the case with prejudice. The case at that point would be permanently taken off the docket. In such a scenario, the person in removal proceedings would be free and clear of the jurisdiction of the immigration court. The judge believed that since the petitioner had been granted TPS status, and TPS waives her inadmissibility, and TPS protects the petitioner from being removed, removal proceedings would no longer be appropriate and terminated the proceedings.
The government appealed the judge’s decision and the BIA affirmed the appeal. The BIA reminded the judge that TPS is, by its definition, only a temporary remedy. While it is true that a person with TPS may not be removed while in such status, the protection is not permanent or definite. In fact, TPS must be renewed periodically (usually every 12-18 months). A change in TPS designation would take away any type of protection which a person in TPS might enjoy. TPS does not make a person admissible. A person such as the petitioner who was inadmissible because she entered the country without inspection will remain inadmissible even after receiving TPS. The grounds for inadmissibility are waived for a finite duration and she cannot be removed for being inadmissible while TPS is in effect. She does not become an immigrant while in TPS.
For these reasons, the immigration judge’s termination of the removal proceedings with prejudice was improper, because such termination was permanent. The proper action was to administratively close the case until such time as TPS no longer is in effect for the petitioner. At that time, she may be removed as any other person who is inadmissible.
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