Cite as 26 I&N Dec. 105 (BIA 2013) Interim Decision #3778
“Partial” accreditation is authorization to represent aliens before the Department of
Homeland Security. “Full” accreditation is authorization to represent aliens before both the
Department of Homeland Security and the Executive Office for Immigration Review, which
includes the immigration courts and this Board. See 8 C.F.R. § 1292.2(a), (d).
Matter of CENTRAL CALIFORNIA LEGAL SERVICES, INC.,
Request for Accreditation
Decided March 28, 2013
U.S. Department of Justice
Executive Office for Immigration Review
Board of Immigration Appeals
A recognized organization’s application for initial accreditation of a proposed
representative must show that the individual has recently completed at least one formal
training course that was designed to give new practitioners a solid overview of the
fundamentals of immigration law and procedure.
BEFORE: Board Panel: NEAL, Chairman; HOLMES and MANN, Board Members.
Central California Legal Services, Inc., Visalia office, has reapplied for
partial accreditation for Janie Munoz-Tafoya as its representative under
8 C.F.R. § 1292.2(d) (2012).1 The Department of Homeland Security has
recommended that we approve the application. The application will be
On October 1, 2012, the Board approved the organization’s application
for recognition but disapproved its request for accreditation for this
proposed representative. While we were satisfied that she is a person of good
moral character and we acknowledged that she is a strong candidate for
accreditation, we were unable to determine from her resume and the
supporting documentation that she possesses the requisite broad knowledge of
immigration law and procedure.
A recognized organization seeking accreditation of an individual must
show that the proposed representative has good moral character and the
requisite broad knowledge of immigration law and procedure. See 8 C.F.R.
§ 1292.2(d); see also Matter of EAC, Inc., 24 I&N Dec. 563 (BIA 2008). TheCite as 26 I&N Dec. 105 (BIA 2013) Interim Decision #3778
2 We note that the organization also submitted documents showing that the proposed
representative has completed formal training in specific areas of immigration law.
Documentation of specialized training consistent with the organization’s mission is also
valuable to the Board’s review of an application for accreditation.
3 Training information is valuable not only to initial applications, but to renewal
applications as well. When a recognized organization seeks to renew a representative’s
accreditation, it should provide documentation that its accredited representative has received
“broad knowledge” requirement, applicable to both full and partial
accreditation, ensures that a duly accredited representative is able to identify
immigration issues of all types and know when to seek additional legal
guidance. Matter of EAC, Inc., 24 I&N Dec. at 564. Thus, effective
representation requires more than specialized knowledge of specific topics
within the spectrum of the immigration laws; it also requires an understanding
and command of the fundamentals.
While broad knowledge can be acquired through a series of in-depth courses
and seminars, training focused specifically on immigration fundamentals, in
complement to other trainings, provides a meaningful survey of immigration
law and procedure. Such training also provides critical insights into the
interconnectedness of the immigration laws and the possible interaction of
other areas of law with the immigration laws. An overview course on the
fundamentals also alerts the proposed representative to the dangers of
over-specialization, the value of referral to more expert representation, and the
potential for unintended harm when legal advice is not supported by a broad
knowledge of the law. We therefore find that a successful application for
initial accreditation must show that a proposed representative has recently
completed at least one formal training course designed for new practitioners
and that the training provided a solid overview of the fundamentals of
immigration law and procedure. Thus, in the request for accreditation, the
organization should submit information about a proposed representative’s
training, including the date(s) of the overview course (and all other trainings),
the provider or providers, the hours completed, the topics addressed at each
training, and certificates of completion, where available.2
In this instance, the organization has provided the agenda and Certificate of
Completion for a 2-day training entitled “Introduction to Immigration Law
Practice: A Course for New Practitioners.” The training was conducted by an
established provider of immigration training, and it covered a spectrum of
foundational concepts in immigration law. In complement, the organization
also provided information on numerous other trainings attended by the
proposed representative, along with various letters of recommendation on her
behalf.3Cite as 26 I&N Dec. 105 (BIA 2013) Interim Decision #3778
additional formal training in immigration law since the most recent accreditation.
Candidates for renewal of accreditation should have updated training that reflects that they
have kept current in immigration law.
Based upon our review of the application and the materials submitted, we
are satisfied that the proposed representative appears to be a person of good
moral character and possesses the broad knowledge of immigration law and
procedure required to practice before the Department of Homeland Security.
Accordingly, the application for partial accreditation will be approved.
ORDER: The application for partial accreditation of Janie Munoz-Tafoya
to represent individuals on behalf of Central California Legal Services, Inc.,
Visalia office, is approved.
Cite as 26 I&N Dec. 105 (BIA 2013) Interim Decision #3778