Practice Advisory: The Return of Administrative Closure
In May 2018, then-Attorney General Sessions issued a decision in Matter of Castro-Tum that eliminated administrative closure in immigration proceedings. In June 2020, the U.S. Court of Appeals for the Seventh Circuit joined the Fourth Circuit in rejecting that decision, allowing administrative closure to be available once more in immigration proceedings within these circuits. This practice advisory aims to be a resource for attorneys practicing within jurisdictions that permit administrative closure, and also to provide some general guidance for practitioners in other jurisdictions.