E-R-M-F- & A-S-M

Citations

• 25 I. & N. Dec. 580

Syllabus

E-R-M-F- & A-S-M-, 25 I&N Dec. 580 (BIA 2011) ID 3725 (PDF) Until an alien who is arrested without a warrant is placed in formal proceedings by the filing of a Notice to Appear (Form I-862), the regulation at 8 C.F.R. § 287.3(c) (2011) does not require immigration officers to advise the alien that he or she has a right to counsel and that any statements made during interrogation can subsequently be used against the alien.