In Sanchez v. Att’y Gen., Petitioner sought review of the Board of Immigration Appeals’ (“Board”) denial of his request for remand to the Immigration Judge for administrative closure, which would have given time for renewal of his Deferred Action for Childhood Arrivals (“DACA”) status. The Board determined that it did not have authority to administratively close proceedings unless a regulation or a previous judicially approved settlement expressly authorizes such an action. The Third Circuit reversed and remanded. After considering the text, structure, history, and purpose of 8 C.F.R. §§ 1003.10(b) and 1003.1(d)(1)(ii), the Third Circuit held that the plain language of those statutes unambiguously authorized administrative closure.
