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· 1/21/2026

S-M-H

Citations

  • 29 I. & N. Dec. 412

Syllabus

The written warnings on the respondent's initial asylum application provided the respondent with statutorily compliant notice of the consequences of filing a frivolous application, irrespective of the absence of oral warnings by an Immigration Judge. Matter of X-M-C-, 25 I&N Dec. 322 (BIA 2010), clarified.

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