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What an answer looks like

A question asked in Claude on September 13, 2026, and the answer that came back. Every link opens that decision’s PDF in the EOIR reading room.

Scroll inside the answer for all 32, or replay it.

Claude, with the Passim connector
Searching 256,315 unpublished BIA decisions
Reading 32 decisions in full

I found 32 on-point cases. In 25 the Board found the hardship itself or upheld a judge who did, five were sent back for a proper hardship analysis, and two are procedural rulings worth knowing. Newest first.

The Board found the hardship

BIA, May 22, 2024, on appeal from Pearsall Single father with sole custody of four U.S. citizen children, among them twins with ADHD, learning disabilities, and speech disorders. The Board held the judge had applied the wrong test by asking whether the children would lose all schooling, found the hardship itself, and sent the case back only for the discretion question. Decision PDF
BIA, Mar. 11, 2024, on appeal from Hartford Ecuadoran parents of a U.S. citizen son who had been accepted into a professional soccer club’s academy, held a merit scholarship, spoke no Spanish, and carries an EpiPen for severe food allergies. The Board reversed the judge, found that the cumulative hardship met the standard, and remanded for background checks, over a dissent without opinion. Decision PDF
BIA, Apr. 5, 2023, on appeal from Tucson A house cleaner earning $250 a week, sole provider for four U.S. citizen children and her permanent-resident mother; her teenage daughter has chronic liver disease and will likely need a transplant. The Board compared the family to Recinas, found the hardship in the aggregate, reversed the good-moral-character finding too, and remanded for the discretion question. Decision PDF
BIA, Mar. 8, 2022, on appeal from Salt Lake City Father of two U.S. citizen children; his daughter had depression, anxiety, and a documented history of self-harm and suicidal ideation after his arrest. On de novo review the Board found the hardship, held him eligible and deserving of cancellation, and remanded only for background checks. Decision PDF
BIA, Mar. 30, 2020, on appeal from New York Ecuadoran parents of an 11-year-old son with autism who is mostly nonverbal and struggles with transitions, and an infant daughter deaf in one ear and partly deaf in the other. The Board held that even an interruption in the children’s therapy would be hardship substantially beyond the ordinary, found the parents eligible and deserving, and remanded for background checks. Decision PDF
BIA, Mar. 26, 2020, on appeal from Harlingen A mother in end-stage renal failure, on dialysis three times a week and waiting for a kidney transplant, whose two U.S. citizen children would go with her to Mexico. The Board found that the burden on the children of securing her care there without interruption, while supporting the family, was exceptional and extremely unusual hardship, and granted cancellation in discretion. Decision PDF
BIA, Mar. 23, 2020, on appeal from Seattle Four U.S. citizen children under five: one with a heart murmur, one who had cranial surgery, one with an uncorrected cleft palate, plus a diabetic permanent-resident father he helped care for. The Board reversed the judge’s hardship finding and sent the case back for findings on physical presence and good moral character. Decision PDF
BIA, Apr. 26, 2018, on appeal from Detroit Sole provider for two U.S. citizen sons, one who had cranial surgery as a toddler and needs continuing follow-up, the other with severe asthma and repeated hospital stays. The Board found the hardship on de novo review, over a dissent, and remanded for background checks. Decision PDF
BIA, Apr. 13, 2018, on appeal from Miami A widowed Guatemalan father, sole support of two U.S. citizen children since their mother died in 2007, who speaks Quiché, has no formal education, and cannot read or write. The Board found the hardship in the totality, held that he merits relief in discretion, and remanded for background checks. Decision PDF
BIA, Apr. 11, 2018, on appeal from Memphis Three U.S. citizen children whose mother had struggled with drug addiction, left the family for a year, and served ten months in prison; the eldest has serious mental-health problems and the youngest a heart condition. Calling it a close case, the Board found the hardship in the aggregate and held the father eligible. Decision PDF
BIA, Feb. 26, 2018, on appeal from Los Angeles An illiterate farm laborer with cognitive difficulties from a head injury, sole provider for four U.S. citizen children, whose eldest daughter was in therapy for depression and anxiety. The Board rejected the judge’s comparison to Monreal, found the hardship, and said a discretionary grant was warranted. Decision PDF
BIA, Jan. 24, 2018, on appeal from New York Indian father whose eldest U.S. citizen daughter has profound developmental delays requiring constant supervision, special education, and extensive rehabilitative services. The Board found both the continuous physical presence and the hardship and held that he merits relief, over a dissent on the presence question. Decision PDF
BIA, Dec. 21, 2017, on appeal from New York Malian father of three U.S. citizen daughters, whose eldest daughter in Mali had already been subjected to female genital mutilation against his wishes. The Board found clear error in the judge’s prediction that he could protect the girls, held that the risk was exceptional and extremely unusual hardship, and reversed the denial. Decision PDF
BIA, Dec. 13, 2017, on appeal from Florence A detained father whose 8-year-old U.S. citizen son has significant intellectual and emotional developmental delays, special education, and several therapies. The Board found that separation from a father who had been an active participant in the boy’s care was hardship substantially beyond the ordinary, and remanded for background checks. Decision PDF
BIA, Nov. 7, 2017, on appeal from Philadelphia A restaurant owner with nearly 20 years in the country, employing about 30 people, whose U.S. citizen daughter was the qualifying relative. The Board called it a close case but found the hardship on de novo review, exercised discretion in his favor despite back taxes, and remanded for background checks. Decision PDF
BIA, Aug. 3, 2017, on appeal from Los Angeles The youngest U.S. citizen daughter has a learning disability and receives special education services. The Board found the requisite hardship in a short decision, over a dissent that considered the learning issues not severe. Decision PDF
BIA, Aug. 2, 2017, on appeal from Batavia A detained father whose U.S. citizen child’s mother has significant medical problems; since his detention the family had faced an eviction notice with no relatives able to help and no government assistance. The Board called it a very close case but found the hardship under Recinas and Monreal. Decision PDF

The Board upheld a judge who found it

BIA, Apr. 5, 2024, DHS appeal from New York The judge granted cancellation to a Peruvian father on hardship to his U.S. citizen children, and DHS appealed. The Board found no clear error in the detailed written decision and upheld the hardship finding. Decision PDF
BIA, Mar. 29, 2023, DHS appeal from Los Angeles The judge relied on expert testimony about the mental health of the respondent’s U.S. citizen son. Calling the case close in some respects, the Board held the findings were a permissible view of the record and affirmed the grant. Decision PDF
BIA, Feb. 14, 2022, DHS appeal from Charlotte The judge found hardship to a permanent-resident husband and an 11-year-old U.S. citizen daughter. The Board adopted and affirmed the decision under Burbano and dismissed the DHS appeal. Decision PDF
BIA, May 24, 2018, DHS appeal from Lumpkin Primary provider for six U.S. citizen children; during his detention his diabetic wife and the children had to move under threat of eviction. The Board agreed that at least one child would suffer hardship substantially beyond the ordinary and affirmed the grant. Decision PDF
BIA, May 7, 2018, DHS appeal from Lumpkin DHS challenged only the hardship finding for a respondent facing removal to El Salvador. The Board found no clear error in the facts and affirmed in a one-page decision. Decision PDF
BIA, Feb. 26, 2018, DHS appeal from Atlanta A pro se respondent’s grant, challenged by DHS on hardship to her qualifying relatives if she were removed to El Salvador. The Board affirmed the judge’s conclusion in a one-page decision. Decision PDF
BIA, Feb. 16, 2018, DHS appeal from San Francisco Two U.S. citizen sons with speech and language delays tied to hearing loss, whose therapy would not be available in Mexico, and a permanent-resident wife who would have to leave a professional job. The Board affirmed the hardship finding and, despite several DUI convictions, the favorable exercise of discretion. Decision PDF
BIA, Nov. 2, 2017, DHS appeal from Lumpkin The judge granted cancellation on the aggregate hardship factors, including the health problems of two U.S. citizen children. The Board found no basis to reverse and dismissed the DHS appeal, with one member dissenting on the hardship issue. Decision PDF

Sent back for a proper hardship analysis

BIA, Mar. 27, 2023, on appeal from El Paso The judge weighed hardship to only one of three U.S. citizen children, two of whom have learning disorders. The Board reversed the discretionary denial and sent the case back. Decision PDF
BIA, Dec. 28, 2022, on appeal from Seattle The judge found the spouse’s autoimmune disease, back injuries, abuse history, and a prior suicide attempt, but never analyzed how removal would affect her ability to care for the two U.S. citizen children. Remanded under Recinas for hardship in the aggregate. Decision PDF
BIA, Sept. 27, 2022, on appeal from Newark The judge found hardship to an autistic U.S. citizen son but denied relief in discretion. The Board sent the case back for a proper weighing of the equities. Decision PDF
BIA, Apr. 11, 2022, on appeal from Orlando Seven qualifying relatives, including a stepson with ADHD and a wife with three herniated discs. The Board sustained the appeal because the judge had not applied Monreal and Recinas or weighed all seven relatives in the aggregate. Decision PDF
BIA, July 11, 2017, on appeal from Los Angeles The judge never treated the U.S. citizen spouse as a qualifying relative. The Board remanded for a hardship analysis that includes her. Decision PDF

Procedural rulings worth knowing

BIA, Oct. 18, 2021, on appeal from Seattle After the hearing the respondent’s wife was diagnosed with colon cancer requiring surgeries and chemotherapy. The Board granted his motion to remand so the new hardship evidence could be considered. Decision PDF
BIA, Nov. 9, 2021, motion to reopen from San Diego Reopened after Pereira v. Sessions so the respondent could apply for cancellation on hardship to his U.S. citizen child, who has an individualized education plan. Granted and sent back to the immigration judge. Decision PDF

All of these are non-precedential: cite them as examples, not authority, and read each decision before you rely on it. The published anchors are Monreal, Andazola, Recinas, and J-J-G-.

What you can ask

The questions of a working immigration practice, answered with the sources behind them.

  • Is Matter of A-B- still good law in the Fifth Circuit?

    The treatment history of the case, quoted from the later decisions, and the circuit precedent that applies it.

  • Check every citation in this brief and flag anything overruled, vacated, or amended.

    Your assistant pulls the citations from the brief, and only those reach Passim. Back come each decision’s current treatment, quoted from the citing decision, and the current text of every statute and regulation cited, so a vacated case or a stale subsection is caught before filing.

  • What are the immigration consequences of a Texas assault conviction under § 22.01?

    The text of the provision and the Board and circuit decisions that have construed it.

  • Find unpublished BIA decisions where the Board found exceptional and extremely unusual hardship.

    A search across more than 258,000 unpublished Board decisions and 168,000 AAO decisions, with a PDF link for each result.

  • Draft the hardship argument for this cancellation case, citing the standard and recent decisions.

    The drafting is your assistant’s; the authority is Passim’s: Monreal, Andazola, Recinas, and J-J-G- with their current treatment, and recent unpublished decisions where the Board found the hardship, each linked to its PDF.

  • Is EB-3 India current for October?

    The Visa Bulletin, this month and past months, and which chart USCIS is using.

What’s in the library

Primary legal sources, organized for immigration research.

Showing saved counts. Counts as of September 19, 2026. Updated is the recorded source or collection update date. Refresh schedules vary by source. Every source, with what it covers and when it was last refreshed.

The full-text total includes the national case-law library: 9,863,729 available opinion texts from the June 2026 CourtListener archive, counted September 20, 2026. The saved combined total is from September 22, 2026. Some decisions appear in both libraries.

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