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USCIS designates decision in Matter of Z-R-Z-C- as adopted policy

  1. Original Date Announced

    August 20, 2020

    USCIS issues a policy memorandum which designates the Administrative Appeals Office's (AAO) decision in Matter of Z-R-Z-C- as an adopted decision, holding that a TPS recipient who is granted authorization to temporarily travel abroad under Immigration and Nationality Act (INA) §244(f)(3) will generally resume the same immigration status upon their return as at time of departure. TPS authorized travel will not satisfy the ‘inspected and admitted or paroled’ provision at INA §245(a). USCIS will only apply Matter of Z-R-Z-C- prospectively, starting August 20, 2020. [ID #1032]

    Matter of Z-R-Z-C-, Adopted Decision 2020-02 (AAO Aug. 20, 2020)
  2. Effective Date

    August 20, 2020
  4. Biden Administration Action: Revoked/Replaced

    July 1, 2022

    2022.07.01 Rescission of Matter of Z-R-Z-C- as an Adopted Decision

    This Biden administration policy rescinds in its entirety the Trump-era policy identified in this entry.

    On July 1, 2022, USCIS issued a policy memorandum rescinding Matter of Z-R-Z-C- as an adopted decision and updating agency interpretation of the effects of authorized travel by TPS beneficiaries. The policy memorandum announced that USCIS will no longer use the advance parole mechanism to authorize travel for TPS beneficiaries, but will instead provide a new TPS travel authorization document, and those TPS beneficiaries inspected and admitted by DHS will be considered "inspected and admitted," including for the purposes of adjustment of status under INA § 245.

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Current Status

Not in effect

Most Recent Action

July 1, 2022 Action: Revoked/Replaced 2022.07.01 Rescission of Matter of Z-R-Z-C- as an Adopted Decision
July 1, 2022
Acted on by Biden Administration

Original Trump Policy Status

Trump Administration Action: Agency Directive
Subject Matter: TPS
Agencies Affected: USCIS

Pre Trump-Era Policies

  • January 1, 1991

    In a 1991 General Counsel Opinion, INS made clear that a TPS holder who initially entered without inspection nevertheless would be found to satisfy INA § 245(a) if, after being granted TPS, he or she departed the United States and was permitted to return with an Advance Parole Travel Document issued pursuant to INA § 244(f)(3). The new policy memorandum does not change the General Counsel Opinion, but clarifies the jurisdiction of USCIS and the immigration courts over TPS adjustment cases.

    INS 1991 opinions re TPS travel

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