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

  1. Date Announced

    Aug. 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 that they had 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]

    View Policy Document
  2. Effective Date of Change

    Aug. 20, 2020
Status: Final/Actual
Type of Action: Agency Directive
Subject Matter: TPS
Agencies Affected: USCIS

Prior Policies

  • 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 guidance does not change the general counsel opinions, but clarifies the jurisdiction of USCIS and the immigration courts over TPS adjustment cases.

    INS 1991 opinions re TPS travel

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