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Template BIA Notice of Appeal for CARR and HAAV Pretermissions

Practice Advisory
Issue area
Removal Defense
Audience
Attorney
Published: Mar. 13, 2026

Immigration judges continue to pretermit asylum applications and deny asylum seekers a day in court, based on alleged deficiencies in the I-589 and/or based on the alleged failure to state a prima facie case for relief. This template is designed to give practitioners a strong starting point for drafting their own Notices of Appeal to the Board of Immigration Appeals.