08/14/2026
Dear Clients,
Important Update - if your advance parole was approved, PLEASE do NOT travel. Please see below. This new decision will be applied prospectively. If you have an advance parole and travel outside of the US, you may trigger the 3- or 10-year bar of inadmissibility.
Matter of Delcarmen-Lara, 29 I&N Dec. 830 (BIA 2026) — decided August 13, 2026 (Interim Decision #4233)
Holding: A departure from the United States pursuant to a grant of advance parole is a "departure" within the meaning of INA § 212(a)(9)(B)(i)(II), 8 U.S.C. § 1182(a)(9)(B)(i)(II), expressly overruling Matter of Arrabally and Yerrabelly, 25 I&N Dec. 771 (BIA 2012).