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Motion to Reopen & Reconsider
8 C.F.R. § 1003.23 • EOIR Court

Motion to Reopen & Reconsider

Strategies for rescinding deportation orders, overturning in absentia removals, changed country conditions, ineffective assistance of counsel (Matter of Lozada), and sua sponte reopening.

Motion to Reopen (MTR) & Motion to Reconsider

8 C.F.R. § 1003.23 (Court) • 8 C.F.R. § 1003.2 (BIA) • 8 C.F.R. § 103.5 (USCIS)

Rescinding Removal Orders & Overturning Denials

When an Immigration Judge issues a final order of removal, the Board of Immigration Appeals (BIA) dismisses an appeal, or USCIS denies an immigration benefit, the case is not necessarily over. A Motion to Reopen asks the adjudicator to vacate the prior decision based on new, previously unavailable material facts or changed country conditions.

In contrast, a Motion to Reconsider asserts that the prior decision was based on an incorrect application of law or USCIS/EOIR precedent based on the existing record.

Strict Filing Deadlines & Number Bars

Under INA § 240(c)(7), respondents are generally limited to one motion to reopen filed within 90 days of the final order (30 days for motions to reconsider). However, critical statutory exceptions exist for lack of notice, changed country conditions, joint motions, and asylum.

Exceptions to 90-Day Limit

Overcoming Deadlines

  • In Absentia (Lack of Notice): No time limit if respondent did not receive proper statutory notice.
  • Changed Country Conditions: No time limit for asylum/CAT based on new country evidence.
  • Joint Motion with OPLA: Can be filed at any time with DHS consent under 8 C.F.R. § 1003.23(b)(4)(iv).
Consult MTR Counsel

Ineffective Assistance of Counsel & Equitable Tolling

Matter of Lozada, 19 I&N Dec. 637 (BIA 1988) • Reopening Cases Botched by Prior Attorneys

1

Affidavit of Representation

Detailed sworn affidavit explaining the exact retainer agreement, promises made, and specific failings of the prior attorney.

2

Notice to Prior Counsel

Former counsel must be notified of the allegations and provided an opportunity to respond in writing.

3

Bar Grievance / Explanation

Proof of filing a disciplinary complaint with the state bar licensing authority, or a detailed legal explanation for not doing so.

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