BIA's CSPA Decision Not Entitled to Deference

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At least six federal lawsuits are pending which challenge the USCIS' interpretation of the "automatic conversion" clause of the Child Status Protection Act (CSPA) of 2002. In one of these lawsuits, Costelo v. Chertoff, a Federal Judge has certified a nationwide class of family-based derivative beneficiaries.

We link to each of the cases referred to in this article from our "CSPA" page at

http://shusterman.com/cspa.html
The question addressed by this article is how much, if any, deference, should the Federal Courts give the BIA's recent decision interpreting CSPA's automatic conversion clause. Matter of Wang, 25 I&N 28 (BIA 2009).

The automatic conversion clause of CSPA is section 203(h)(3) of the Immigration and Nationality Act as amended. In order to understand the meaning of this clause, it is important to read and understand the meaning of section 203(h) of the Act:

203(h) RULES FOR DETERMINING WHETHER CERTAIN ALIENS ARE CHILDREN -

(1) IN GENERAL.-- For purposes of subsections (a)(2)(A) and (d), a determination of whether an alien satisfies the age requirement in the matter preceding subparagraph (A) of section 101(b)(1) shall be made using--

(A) the age of the alien on the date on which an immigrant visa number becomes available for such alien (or, in the case of subsection (d), the date on which an immigrant visa number became available for the alien's parent), but only if the alien has sought to acquire the status of an alien lawfully admitted for permanent residence within one year of such availability; reduced by

(B) the number of days in the period during which the applicable petition described in paragraph (2) was pending.

(2) PETITIONS DESCRIBED- The petition described in this paragraph is—

(A) with respect to a relationship described in subsection (a)(2)(A), a petition filed under section 204 for classification of an alien child under subsection (a)(2)(A); or

(B) with respect to an alien child who is a derivative beneficiary under subsection (d), a petition filed under section 204 for classification of the alien's parent under subsection (a), (b), or (c).

(3) RETENTION OF PRIORITY DATE- If the age of an alien is determined under paragraph (1) to be 21 years of age or older for the purposes of subsections (a)(2)(A) and (d), the alien's petition shall automatically be converted to the appropriate category and the alien shall retain the original priority date issued upon receipt of the original petition.

(4) APPLICATION TO SELF-PETITIONS- Paragraphs (1) through (3) shall apply to self-petitioners and derivatives of self-petitioners.

Since section 203(h)(3) refers to "subsections (a)(2)(A) and (d)" of section 203, it is also necesssary to read and understand both of these sections of law.

Section 203(a)(2)(A) provides as follows:

(a) Preference Allocation for Family-Sponsored Immigrants. - Aliens subject to the worldwide level specified in section 201(c) for family-sponsored immigrants shall be allotted visas as follows:

(2) Spouses and unmarried sons and unmarried daughters of permanent resident aliens. - Qualified immigrants -

(A) who are the spouses or children of an alien lawfully admitted for permanent residence.

In simple English, this section of law refers to spouses and children of permanent residents who are petitioned under the family-based 2A category.

Section 203(d) provides as follows:

Treatment of family members

A spouse or child as defined in subparagraph (A), (B), (C), (D), or (E) of section 101(b)(1) shall, if not otherwise entitled to an immigrant status and the immediate issuance of a visa under subsection (a), (b), or (c) of this section, be entitled to the same status, and the same order of consideration provided in the respective subsection, if accompanying or following to join, the spouse or parent.

In simple English, section 203(d) states that spouses and children of principal beneficiaries of visa petitions are entitled to permanent residence in the same category as the principal. In other words, if a U.S. citizen brother petitions his sister for a green card, not only does the sister obtain permanent residence in the family-based fourth preference category, but her husband and children also qualify under the same category. Or if a person qualifies for a green card through employment or through the visa lottery, his spouse and children also qualify under the same category as the principal.

Section 101(b)(1) defines "child" for purposes of immigrating to the U.S. In general, a child is defined as a person who is under 21 years of age and who is unmarried.

Spouses and children under section 203(d) who are accompanying or following to join the principal beneficiary of a visa petition or the winner of the visa lottery are commonly referred to as "derivative beneficiaries".

In Matter of Garcia (2006), an unpublished decision of the Board of Immigration Appeals (BIA), the Board considered the case of Maria Garcia, a "derivative beneficiary" who was born in Mexico. On January 13, 1983, Maria's mother was petitioned as the sister of a U.S. citizen. At that time, Maria was only nine years old.

Under section 203(d), Maria was a derivative beneficiary who would have been eligible to become a permanent resident along with her mother as long as she remained a "child", that is, unmarried and under 21 years of age. However, by the time that visa numbers became available to Maria and her mother in 1996, Maria was 22years of age. In common parlance, she had "aged-out". By 1996, the only relief that was available to Maria was for her permanent resident mother to submit a visa petition on Maria's behalf under the 2B category for unmarried adult sons and daughters of lawful permanent residents. Maria's mother did just that in 1997.

However, Maria was placed in deportation proceedings, and by the time her case was decided by the BIA on June 16, 2006, visa numbers were available in the Mexican 2B category only to persons whose lawful permanent resident parent(s) had petitioned for them before October 22, 1991, a 15-year wait.

Under the law as it existed prior to CSPA, Maria would have had to wait in line for a green card twice. First, she waited from 1983 to 1996, a period of 13 years for a family-based 4th preference visa number to be current. However, she was no longer a child under section 101(b)(1) because she had reached the age of 21 before her visa number became current in 1996. Therefore, she lost her place in line for a green card. When her mother petitioned for her in the 2B category in 1997, she would have had to go to the back of a 15-year line and be separated from her mother until 2012. Furthermore, if Maria married prior to immigrating in 2012, the visa petition would automatically terminate. By then, she would be 38-years-old.

The unanimous BIA panel which decided her case in 2006 held that CSPA's automatic conversion clause applied to Maria Garcia. The Board held that Maria was no longer a "child" for purposes of section 203(h)(1) since she was 22 years of age when her visa number under the family-based fourth preference category became current, and since the visa petition was approved the same day that it was submitted, no time could be subtracted from Maria's age under CSPA.

Because she was still a "derivative beneficiary" under section 203(d) except that her age was more than 21 years old, the Board held that she qualified for automatic conversion of her visa petition under section 203(h)(3). They then addressed the question of what was the "appropriate category" that the visa petition should be "converted" to. The Board held as follows:

"The respondent was (and remains) her mother's unmarried daughter, and therefore, the 'appropriate category' to which her petition was converted is the second preference category of family-based immigrants, i.e., the unmarried sons and daughters of lawful permanent residents. Furthermore, the respondent is entitled to retain the January 13, 1983, priority date that applied to the original fourth-preference petition, and therefore a visa number under the second-preference category is immediately available to the respondent.

The Board, in Matter of Garcia, did not find the statutory language of section 203(h)(3) ambiguous. Since this section of law specifically applies to derivative beneficiaries as defined by section 203(d), the Board found that Maria Garcia was entitled to benefit from the automatic conversion clause. They remanded the case to the Immigration Judge to consider her application for adjustment of status.

Three years later, in Matter of Wang, the Board refused to follow the reasoning of Matter of Garcia, held that the language of section 203(h)(3) was ambiguous and ruled that CSPA's automatic conversion clause did not apply to derivative beneficiaries.

This ruling is puzzling to say the least. How can section 203(h)(3) not apply to derivative beneficiaries when it specifically references section 203(d), the section of law which concerns derivative beneficiaries? Matter of Wang essentially deletes this reference to section 203(d) from the statute.

Further, the Board fails to discuss what it finds "ambiguous" in the language of section 203(h)(3). It simply goes on to discuss the legislative history of this section of law when no such legislative history exists.

The starting point of all statutory interpretation is the intent of Congress, and “‘[d]eference to the (agency's) interpretation...is only appropriate if Congress' intent is unclear.’" Padash v. INS, 358 F.3d 1161, 1168 (9th Cir. 2004). Where traditional tools of statutory construction reveal Congress’ intent, “deference is not required at all.”

USCIS' Redesigned Website: Our Suggestions

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The USCIS announced that, on September 22, the agency "will launch a vastly improved public Web site to help customers navigate the immigration system and remain up-to-date regarding their case status." See the USCIS Fact Sheet dated August 11 at

http://www.shusterman.com/pdf/redesign.pdf

Almost 10 years ago, the INS redesigned its website. We were very critical. See our review entitled "INS's New Website Emphasizes Content Over Form(s)" at

http://shusterman.com/sep99.html#6

We pointed out that after spending millions of dollars and employing a great many experts, the INS website did not even allow readers to access as many INS forms as our website. The INS Webmaster responded to our review on September 20, 1999. See

http://www.shusterman.com/beyer.html

Subsequently, the INS established the best U.S. immigration website on the Internet.

However, several years later, the INS again redesigned its website, and in the process, eliminated many of the most helpful features of the site.

Since the USCIS is once again redesigning it's website, we wish to make a few suggestions:

1. Please do something to improve the search engine.

Our website has more links to the USCIS website (several hundred) than any other site on the web. So we empathize with readers who tell us that it is extremely difficult to find information on the USCIS website. For example, take a look at the first link above, the USCIS Fact Sheet dated August 11. We could not find this on the USCIS website, so we scanned in the Fact Sheet and posted it on our website.

Example: What if someone is interested in L status? Whether they type in "L", "L status", "L visa petition" into the USCIS search engine, they get the following answer: "404 - Requested Page Not Found on Site".

The USCIS search engine, even when it is working, leaves a lot to be desired.

2. Make the website easier to navigate.

Your fact sheet lists the following customer comments about the present USCIS website. It is "hard to navigate", "overwhelming" and "frustrating". That's because the layout of the website is illogical. For example, let's say someone is searching for information about L status. How do they find this information at www.uscis.gov?

The website has the following buttons near the top of the page:

* Services & Benefits
* Immigration Forms
* Laws & Regulations
* About USCIS
* Education & Resources
* Press Room

Where would one find information about L status? Probably under "Services & Benefits". Clicking this button leads one to a four-paragraph general introduction which ends with the following guidance: "For information about a particular immigration benefit or service, please select the appropriate button on the menu to your left."

The menu on the left contains a total of 17 different items, none of them clearly relating to L status or temporary visa categories. So we decided to click the "How do I Customer Guides". This page lists six different categories of guides, one of them being "Nonimmigrants". Fine for an attorney, but does the average immigrant realize that the word "Nonimmigrants" relates to temporary visa categories like the L category? Probably not.

However, let's assume that the reader clicks on "Nonimmigrants". This leads to a page which contains three links, the most appropriate being "How do I Change to Another Nonimmigrant Status?" Click on this link, and you are transported to a three-page PDF file. The file lists some of the 40 types of nonimmigrant categories, but provides precious little information about any of these categories. For instance, with reference to the L category, the document states "L-1A or L-1B Intracompany Transfer". Not very helpful, is it?

By this time, the person has probably given up on the USCIS website and found all the information that they need to know about L status on our website at

http://shusterman.com/toc-temp.html#3m

And where did we get all this great information about L status? Confession: We copied and pasted it from the old INS website! (which leads us to our next suggestion...)

3. Bring Back the Old INS Website

Or at least make the new USCIS website as useful as the old INS website was. For example, the USCIS used to include four charts which relate to derivative citizenship. And we linked to all four nationality charts. For example, we linked to the chart for "Acquisition of U.S. Citizenship for Children Born Abroad in Wedlock" at

http://www.uscis.gov/propub/ProPubVAP.jsp dockey=6f3ca27ff6c196d35e87dae2221deee9

Every few weeks, the URL would change and we would have to repair the link. We wrote to the USCIS webmaster about this problem, but we never received a reply. Now, it seems that the USCIS has removed all four nationality charts from their website. Why? We have no idea.

We could write to the USCIS webmaster, but what's the use?

4. What's With the Long URLs?

Check out the following web page:


http://www.uscis.gov/portal/site/uscis/menuitem.eb1d4c2a3e5b9ac89243c6a7543f6d1a/?vgnextoid=4f719c7755cb9010VgnVCM10000045f3d6a1RCRD&vgnextchannel=4f719c7755cb9010VgnVCM10000045f3d6a1RCRD

What's this, you may ask? It's USCIS' page regarding "Lawful Permanent Residence (Green Card)". Why is the web address (aka, the URL) so long? Maybe there is a reason for the long URLs on the USCIS website, but we don't know what it is.

5. Help Immigrants and Their Employers Find Good Legal Advice

The USCIS website wisely advises persons not to use the services of notarios or "immigration consultants".

However, it does little to advise immigrants where to find knowledgeable and experienced immigration attorneys. USCIS' "Finding Legal Advice" page contains eight links: To the websites of the American Bar Association and the National Organization of Bar Counsel and even to EOIR's list of "Free Legal Service Providers". However, when one clicks on this last link, the list indicates that the services of these attorneys are not necessarily free, and what's more, this list is for persons in removal proceedings who cannot afford an attorney. Not exactly the list that an employer who wants to submit a PERM application or a permanent resident who wants to apply for naturalization needs.

A long time ago, we suggested to the USCIS that since four states (California, Florida, Texas and North Carolina) certify certain attorneys as Specialists in Immigration Law, why not link to the lists of these specialists. On November 6, 2006, Alfonso Aguilar, the Chief of USCIS' Office of Citizenship told us that he would do so. See

http://shusterman.com/pdf/certsp1106.pdf

We have been waiting for this to occur for nearly three years. Please surprise us, and add this to the new USCIS website!

US Senators Urge Crack Down On “Sham” Universities

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A number of prominent US senators recently sent a letter to President Barack Obama's administration, urging it deal with supposed "sham" universities that exist solely to give US student visas to illegal immigrants.

"These so-called schools not only defraud students and violate immigration laws, but they pose a real threat to our country," the senators wrote in a letter to officials at the US Citizenship and Immigration Services and Immigration and Customs Enforcement. "When the student visa program can easily be manipulated by bad actors, it threatens the viability of the entire program for the large majority of bona fide participants.

According to Fox News, the letter was signed by senators Dianne Feinstein, Chuck Schumer, Claire McCaskill and Jon Tester, all of whom are Democrats.

The letter cited the example of California's Tri-Valley University, which was investigated after officials noticed that its enrollment soared to 1,500, and many of the students came from the same area in India. A sting operation found that the school may not have ever provided classwork or courses.

NY1 reports that some of the people involved in the 9/11 terrorist attacks entered the country via student visas.

Source: US senators urge crack down on “sham” universities

Hispanic Group Critiques Obama on Immigration Reform

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Despite improving some services and moving to block strict state laws, the administration of President Barack Obama has not delivered on immigration reform promises, according to a recent National Hispanic Leadership Agenda progress report.

“In no other area of public policy have the Obama Administration and Congress over-promised and under-delivered more than immigration,” the report states.

In its report, NHLA praises the U.S. Department of Justice for securing an injunction against Arizona’s strict omnibus immigration law, SB 1070, which NHLA says would have led to racial profiling in the state. The organization also recognizes the administration for cracking down on vigilante anti-immigrant crime and commends U.S. Citizenship and Immigration Services for streamlining naturalization processes.

These positive steps have been overshadowed, NHLA says, by legislative inaction or stalemates at the federal level. No action has been taken on Congressional bills to reunite immigrant families, and after passage in the House of Representatives, the Senate blocked passage of the Dream Act. In addition to these legislative disappointments, NHLA says the Obama Administration has increased deportations of Hispanic immigrants.

The U.S. Supreme Court might soon provide direction regarding immigration reform, as the state of Arizona recently petitioned the top court to overturn the injunction blocking SB 1070.

Source:Hispanic Group Critiques Obama on Immigration Reform


OTHER RELATED ARTICLES:

• Newsletter May 2011 – Immigration Reform in President Obama’s Own Words

• Immigration Reform in 2010?

• Newsletter April 2011 – The View From Down There: Immigration Reform at the Federal Level

• Immigration reform stalls in Florida Senate Bloomberg Advocates Immigration Reform in Washington, D.C.

• California Latino Leaders Hope Immigration Reform Bills Receive Political Support

• Comprehensive Immigration Reform on the Agenda for Early 2010

Immigrant Family's Kafkaesque Ordeal

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In Franz Kafka's chilling story "The Metamorphosis", a man wakes up one morning to find that he has been transformed into a "gigantic insect".

Recently, a California family, all permanent residents for over 30 years, was suddenly informed by the government that they were all illegal aliens and must return to Thailand.

Mr. Promsiri entered the United States on a student visa. His wife and two young sons, aged 10 and 3 joined him in 1971.

In 1975, the parents obtained a divorce from a Thai Consulate in the U.S. The wife married an American citizen, and the couple honeymooned in Thailand. The U.S. Embassy in Bangkok examined their marriage certicate and the divorce degree before granting the wife permanent residence.

The couple then returned to the U.S. where the citizen stepfather sponsored his two stepsons. Another agency, the Immigration and Naturalization Service (INS) examined the paperwork and granted green cards to the boys.

Fast forward to 2009. The U.S. Citizenship and Immigration Services (USCIS), successor to the INS, recently ordered the mother and the boys to appear before an Immigration Judge and charged them with being illegally present in the U.S. Nearly
34 years after examining their paperwork and granting them green cards, the agency suddenly decided that they should never have been granted permanent residence in the first place!

Why?

Because the government maintains that a divorce granted by the Thai government in the U.S. rather than by a state court is invalid.

Why then did two U.S. government agencies approve the paperwork for the Promsiri family back in 1975? If they had found the divorce to be invalid then, the parents could have obtained a divorce in the Superior Court, and the mother could have remarried, and obtained a valid green card.

Did the agency ever get a chance to review the paperwork since 1975? Many times. In 1983, the older brother Andy applied for U.S. citizenship. The INS examiner approved his application, and he was scheduled for a swearing-in ceremony. However, the day before the ceremony, someone from the INS called Andy's mother, told her that there was a problem with her divorce and that Andy should not appear at the naturalization ceremony. The agency would let them know what they needed to do.

Despite the passage of 25 years, dozens of inquiries and many new naturalization applications, the family was kept in the dark until 2009 when they were suddenly placed in deportation proceedings.

During those years, time did not stand still. Andy and Kevin graduated from college. Both have prestigious jobs, one at a major university; the other at a bank. Both are homeowners and taxpayers and have no connection to the country of their birth. Their mother, now 71 years of age, has retired. Andy and Kevin support and care for her.

As soon as they received the notice from the Immigration Service, they came to see me. They were in a state of shock. After living almost their entire lives in the United States, they are American as American can be. All their lives, they had played by the rules. Why did the government want to send them back to Thailand?

We requested that the local director of the Immigration Service exercise prosecutorial discretion. To our great relief, he did so. He agreed to cancel the removal proceedings against the Promsiris.

The Promsiri family were all smiles when we told them the good news. See

http://shusterman.com/photo17.html
We hope that now the family can finally become U.S. citizens.

We also hope that other families will not be subjected to the Kafkaesque ordeal that the Promsiris have suffered.

DHS Suspends "Widow's Penalty"

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On June 9, DHS Secretary Janet Napolitano announced that the government would cease the prosecution and deportation of widows and orphans of U.S. citizens who died before the permanent residence process could be completed.

“Smart immigration policy balances strong enforcement practices with common-sense, practical solutions to complicated issues,” said Secretary Napolitano. “Granting deferred action to the widows and widowers of U.S. citizens who otherwise would have been denied the right to remain in the United States allows these individuals and their children an opportunity to stay in the country that has become their home while their legal status is resolved.”

ICE will no longer place qualifying widow(er)s and orphans in removal proceedings. If a person has already been ordered removed, ICE will not enforce the removal order. In addition, USCIS will favorably consider requests for “humanitarian reinstatement” of revoked immigrant visa petitions.

The new policy will apply regardless of whether the U.S. citizen submitted a visa petition on behalf of his or her spouse and children before their death.

We link to the DHS Press Release from our “Green Cards Through Family Members” page at

http://shusterman.com/family.html#2
Secretary Napolitano’s new policy is a stopgap measure which does not change the law, but allows time for Congress to step in and change the law before any deportations can take place.

And step in they did.

Just two days after Secretary Napolitano announced her new policy, Senators Menendez (D-NJ), Gillibrand (D-NY) and Leahy (D-VT) introduced the Orphans, Widows and Widowers Protection Act (S. 1427) which addresses the immigration-related hardships caused by the death of a sponsoring relative.

We link to this bill from our “Immigration Legislation” page at

http://shusterman.com/toc-leg.html#3
Currently, the issue is being litigated in courts all across the U.S. There are nearly 20 cases being fought in Federal Court. Three federal appeals courts have ruled that an immigrant does not cease being a spouse when the American partner dies during the processing of a residency application.

The television program “60 Minutes” will feature an update on the "Widow's Penalty" on Sunday, June 14th.

BIA's CSPA Decision Not Entitled to Deference

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At least six federal lawsuits are pending which challenge the USCIS' interpretation of the "automatic conversion" clause of the Child Status Protection Act (CSPA) of 2002. In one of these lawsuits, Costelo v. Chertoff, a Federal Judge has certified a nationwide class of family-based derivative beneficiaries.

We link to each of the cases referred to in this article from our "CSPA" page at

http://shusterman.com/cspa.html
The question addressed by this article is how much, if any, deference, should the Federal Courts give the BIA's recent decision interpreting CSPA's automatic conversion clause. Matter of Wang, 25 I&N 28 (BIA 2009).

The automatic conversion clause of CSPA is section 203(h)(3) of the Immigration and Nationality Act as amended. In order to understand the meaning of this clause, it is important to read and understand the meaning of section 203(h) of the Act:

203(h) RULES FOR DETERMINING WHETHER CERTAIN ALIENS ARE CHILDREN -

(1) IN GENERAL.-- For purposes of subsections (a)(2)(A) and (d), a determination of whether an alien satisfies the age requirement in the matter preceding subparagraph (A) of section 101(b)(1) shall be made using--

(A) the age of the alien on the date on which an immigrant visa number becomes available for such alien (or, in the case of subsection (d), the date on which an immigrant visa number became available for the alien's parent), but only if the alien has sought to acquire the status of an alien lawfully admitted for permanent residence within one year of such availability; reduced by

(B) the number of days in the period during which the applicable petition described in paragraph (2) was pending.

(2) PETITIONS DESCRIBED- The petition described in this paragraph is—

(A) with respect to a relationship described in subsection (a)(2)(A), a petition filed under section 204 for classification of an alien child under subsection (a)(2)(A); or

(B) with respect to an alien child who is a derivative beneficiary under subsection (d), a petition filed under section 204 for classification of the alien's parent under subsection (a), (b), or (c).

(3) RETENTION OF PRIORITY DATE- If the age of an alien is determined under paragraph (1) to be 21 years of age or older for the purposes of subsections (a)(2)(A) and (d), the alien's petition shall automatically be converted to the appropriate category and the alien shall retain the original priority date issued upon receipt of the original petition.

(4) APPLICATION TO SELF-PETITIONS- Paragraphs (1) through (3) shall apply to self-petitioners and derivatives of self-petitioners.

Since section 203(h)(3) refers to "subsections (a)(2)(A) and (d)" of section 203, it is also necesssary to read and understand both of these sections of law.

Section 203(a)(2)(A) provides as follows:

(a) Preference Allocation for Family-Sponsored Immigrants. - Aliens subject to the worldwide level specified in section 201(c) for family-sponsored immigrants shall be allotted visas as follows:

(2) Spouses and unmarried sons and unmarried daughters of permanent resident aliens. - Qualified immigrants -

(A) who are the spouses or children of an alien lawfully admitted for permanent residence.

In simple English, this section of law refers to spouses and children of permanent residents who are petitioned under the family-based 2A category.

Section 203(d) provides as follows:

Treatment of family members

A spouse or child as defined in subparagraph (A), (B), (C), (D), or (E) of section 101(b)(1) shall, if not otherwise entitled to an immigrant status and the immediate issuance of a visa under subsection (a), (b), or (c) of this section, be entitled to the same status, and the same order of consideration provided in the respective subsection, if accompanying or following to join, the spouse or parent.

In simple English, section 203(d) states that spouses and children of principal beneficiaries of visa petitions are entitled to permanent residence in the same category as the principal. In other words, if a U.S. citizen brother petitions his sister for a green card, not only does the sister obtain permanent residence in the family-based fourth preference category, but her husband and children also qualify under the same category. Or if a person qualifies for a green card through employment or through the visa lottery, his spouse and children also qualify under the same category as the principal.

Section 101(b)(1) defines "child" for purposes of immigrating to the U.S. In general, a child is defined as a person who is under 21 years of age and who is unmarried.

Spouses and children under section 203(d) who are accompanying or following to join the principal beneficiary of a visa petition or the winner of the visa lottery are commonly referred to as "derivative beneficiaries".

In Matter of Garcia (2006), an unpublished decision of the Board of Immigration Appeals (BIA), the Board considered the case of Maria Garcia, a "derivative beneficiary" who was born in Mexico. On January 13, 1983, Maria's mother was petitioned as the sister of a U.S. citizen. At that time, Maria was only nine years old.

Under section 203(d), Maria was a derivative beneficiary who would have been eligible to become a permanent resident along with her mother as long as she remained a "child", that is, unmarried and under 21 years of age. However, by the time that visa numbers became available to Maria and her mother in 1996, Maria was 22years of age. In common parlance, she had "aged-out". By 1996, the only relief that was available to Maria was for her permanent resident mother to submit a visa petition on Maria's behalf under the 2B category for unmarried adult sons and daughters of lawful permanent residents. Maria's mother did just that in 1997.

However, Maria was placed in deportation proceedings, and by the time her case was decided by the BIA on June 16, 2006, visa numbers were available in the Mexican 2B category only to persons whose lawful permanent resident parent(s) had petitioned for them before October 22, 1991, a 15-year wait.

Under the law as it existed prior to CSPA, Maria would have had to wait in line for a green card twice. First, she waited from 1983 to 1996, a period of 13 years for a family-based 4th preference visa number to be current. However, she was no longer a child under section 101(b)(1) because she had reached the age of 21 before her visa number became current in 1996. Therefore, she lost her place in line for a green card. When her mother petitioned for her in the 2B category in 1997, she would have had to go to the back of a 15-year line and be separated from her mother until 2012. Furthermore, if Maria married prior to immigrating in 2012, the visa petition would automatically terminate. By then, she would be 38-years-old.

The unanimous BIA panel which decided her case in 2006 held that CSPA's automatic conversion clause applied to Maria Garcia. The Board held that Maria was no longer a "child" for purposes of section 203(h)(1) since she was 22 years of age when her visa number under the family-based fourth preference category became current, and since the visa petition was approved the same day that it was submitted, no time could be subtracted from Maria's age under CSPA.

Because she was still a "derivative beneficiary" under section 203(d) except that her age was more than 21 years old, the Board held that she qualified for automatic conversion of her visa petition under section 203(h)(3). They then addressed the question of what was the "appropriate category" that the visa petition should be "converted" to. The Board held as follows:

"The respondent was (and remains) her mother's unmarried daughter, and therefore, the 'appropriate category' to which her petition was converted is the second preference category of family-based immigrants, i.e., the unmarried sons and daughters of lawful permanent residents. Furthermore, the respondent is entitled to retain the January 13, 1983, priority date that applied to the original fourth-preference petition, and therefore a visa number under the second-preference category is immediately available to the respondent.

The Board, in Matter of Garcia, did not find the statutory language of section 203(h)(3) ambiguous. Since this section of law specifically applies to derivative beneficiaries as defined by section 203(d), the Board found that Maria Garcia was entitled to benefit from the automatic conversion clause. They remanded the case to the Immigration Judge to consider her application for adjustment of status.

Three years later, in Matter of Wang, the Board refused to follow the reasoning of Matter of Garcia, held that the language of section 203(h)(3) was ambiguous and ruled that CSPA's automatic conversion clause did not apply to derivative beneficiaries.

This ruling is puzzling to say the least. How can section 203(h)(3) not apply to derivative beneficiaries when it specifically references section 203(d), the section of law which concerns derivative beneficiaries? Matter of Wang essentially deletes this reference to section 203(d) from the statute.

Further, the Board fails to discuss what it finds "ambiguous" in the language of section 203(h)(3). It simply goes on to discuss the legislative history of this section of law when no such legislative history exists.

The starting point of all statutory interpretation is the intent of Congress, and “‘[d]eference to the (agency's) interpretation...is only appropriate if Congress' intent is unclear.’" Padash v. INS, 358 F.3d 1161, 1168 (9th Cir. 2004). Where traditional tools of statutory construction reveal Congress’ intent, “deference is not required at all.”

USCIS' Redesigned Website: Our Suggestions

To contact us Click HERE
The USCIS announced that, on September 22, the agency "will launch a vastly improved public Web site to help customers navigate the immigration system and remain up-to-date regarding their case status." See the USCIS Fact Sheet dated August 11 at

http://www.shusterman.com/pdf/redesign.pdf

Almost 10 years ago, the INS redesigned its website. We were very critical. See our review entitled "INS's New Website Emphasizes Content Over Form(s)" at

http://shusterman.com/sep99.html#6

We pointed out that after spending millions of dollars and employing a great many experts, the INS website did not even allow readers to access as many INS forms as our website. The INS Webmaster responded to our review on September 20, 1999. See

http://www.shusterman.com/beyer.html

Subsequently, the INS established the best U.S. immigration website on the Internet.

However, several years later, the INS again redesigned its website, and in the process, eliminated many of the most helpful features of the site.

Since the USCIS is once again redesigning it's website, we wish to make a few suggestions:

1. Please do something to improve the search engine.

Our website has more links to the USCIS website (several hundred) than any other site on the web. So we empathize with readers who tell us that it is extremely difficult to find information on the USCIS website. For example, take a look at the first link above, the USCIS Fact Sheet dated August 11. We could not find this on the USCIS website, so we scanned in the Fact Sheet and posted it on our website.

Example: What if someone is interested in L status? Whether they type in "L", "L status", "L visa petition" into the USCIS search engine, they get the following answer: "404 - Requested Page Not Found on Site".

The USCIS search engine, even when it is working, leaves a lot to be desired.

2. Make the website easier to navigate.

Your fact sheet lists the following customer comments about the present USCIS website. It is "hard to navigate", "overwhelming" and "frustrating". That's because the layout of the website is illogical. For example, let's say someone is searching for information about L status. How do they find this information at www.uscis.gov?

The website has the following buttons near the top of the page:

* Services & Benefits
* Immigration Forms
* Laws & Regulations
* About USCIS
* Education & Resources
* Press Room

Where would one find information about L status? Probably under "Services & Benefits". Clicking this button leads one to a four-paragraph general introduction which ends with the following guidance: "For information about a particular immigration benefit or service, please select the appropriate button on the menu to your left."

The menu on the left contains a total of 17 different items, none of them clearly relating to L status or temporary visa categories. So we decided to click the "How do I Customer Guides". This page lists six different categories of guides, one of them being "Nonimmigrants". Fine for an attorney, but does the average immigrant realize that the word "Nonimmigrants" relates to temporary visa categories like the L category? Probably not.

However, let's assume that the reader clicks on "Nonimmigrants". This leads to a page which contains three links, the most appropriate being "How do I Change to Another Nonimmigrant Status?" Click on this link, and you are transported to a three-page PDF file. The file lists some of the 40 types of nonimmigrant categories, but provides precious little information about any of these categories. For instance, with reference to the L category, the document states "L-1A or L-1B Intracompany Transfer". Not very helpful, is it?

By this time, the person has probably given up on the USCIS website and found all the information that they need to know about L status on our website at

http://shusterman.com/toc-temp.html#3m

And where did we get all this great information about L status? Confession: We copied and pasted it from the old INS website! (which leads us to our next suggestion...)

3. Bring Back the Old INS Website

Or at least make the new USCIS website as useful as the old INS website was. For example, the USCIS used to include four charts which relate to derivative citizenship. And we linked to all four nationality charts. For example, we linked to the chart for "Acquisition of U.S. Citizenship for Children Born Abroad in Wedlock" at

http://www.uscis.gov/propub/ProPubVAP.jsp dockey=6f3ca27ff6c196d35e87dae2221deee9

Every few weeks, the URL would change and we would have to repair the link. We wrote to the USCIS webmaster about this problem, but we never received a reply. Now, it seems that the USCIS has removed all four nationality charts from their website. Why? We have no idea.

We could write to the USCIS webmaster, but what's the use?

4. What's With the Long URLs?

Check out the following web page:


http://www.uscis.gov/portal/site/uscis/menuitem.eb1d4c2a3e5b9ac89243c6a7543f6d1a/?vgnextoid=4f719c7755cb9010VgnVCM10000045f3d6a1RCRD&vgnextchannel=4f719c7755cb9010VgnVCM10000045f3d6a1RCRD

What's this, you may ask? It's USCIS' page regarding "Lawful Permanent Residence (Green Card)". Why is the web address (aka, the URL) so long? Maybe there is a reason for the long URLs on the USCIS website, but we don't know what it is.

5. Help Immigrants and Their Employers Find Good Legal Advice

The USCIS website wisely advises persons not to use the services of notarios or "immigration consultants".

However, it does little to advise immigrants where to find knowledgeable and experienced immigration attorneys. USCIS' "Finding Legal Advice" page contains eight links: To the websites of the American Bar Association and the National Organization of Bar Counsel and even to EOIR's list of "Free Legal Service Providers". However, when one clicks on this last link, the list indicates that the services of these attorneys are not necessarily free, and what's more, this list is for persons in removal proceedings who cannot afford an attorney. Not exactly the list that an employer who wants to submit a PERM application or a permanent resident who wants to apply for naturalization needs.

A long time ago, we suggested to the USCIS that since four states (California, Florida, Texas and North Carolina) certify certain attorneys as Specialists in Immigration Law, why not link to the lists of these specialists. On November 6, 2006, Alfonso Aguilar, the Chief of USCIS' Office of Citizenship told us that he would do so. See

http://shusterman.com/pdf/certsp1106.pdf

We have been waiting for this to occur for nearly three years. Please surprise us, and add this to the new USCIS website!

DHS Suspends "Widow's Penalty"

To contact us Click HERE
On June 9, DHS Secretary Janet Napolitano announced that the government would cease the prosecution and deportation of widows and orphans of U.S. citizens who died before the permanent residence process could be completed.

“Smart immigration policy balances strong enforcement practices with common-sense, practical solutions to complicated issues,” said Secretary Napolitano. “Granting deferred action to the widows and widowers of U.S. citizens who otherwise would have been denied the right to remain in the United States allows these individuals and their children an opportunity to stay in the country that has become their home while their legal status is resolved.”

ICE will no longer place qualifying widow(er)s and orphans in removal proceedings. If a person has already been ordered removed, ICE will not enforce the removal order. In addition, USCIS will favorably consider requests for “humanitarian reinstatement” of revoked immigrant visa petitions.

The new policy will apply regardless of whether the U.S. citizen submitted a visa petition on behalf of his or her spouse and children before their death.

We link to the DHS Press Release from our “Green Cards Through Family Members” page at

http://shusterman.com/family.html#2
Secretary Napolitano’s new policy is a stopgap measure which does not change the law, but allows time for Congress to step in and change the law before any deportations can take place.

And step in they did.

Just two days after Secretary Napolitano announced her new policy, Senators Menendez (D-NJ), Gillibrand (D-NY) and Leahy (D-VT) introduced the Orphans, Widows and Widowers Protection Act (S. 1427) which addresses the immigration-related hardships caused by the death of a sponsoring relative.

We link to this bill from our “Immigration Legislation” page at

http://shusterman.com/toc-leg.html#3
Currently, the issue is being litigated in courts all across the U.S. There are nearly 20 cases being fought in Federal Court. Three federal appeals courts have ruled that an immigrant does not cease being a spouse when the American partner dies during the processing of a residency application.

The television program “60 Minutes” will feature an update on the "Widow's Penalty" on Sunday, June 14th.

BIA's CSPA Decision Not Entitled to Deference

To contact us Click HERE
At least six federal lawsuits are pending which challenge the USCIS' interpretation of the "automatic conversion" clause of the Child Status Protection Act (CSPA) of 2002. In one of these lawsuits, Costelo v. Chertoff, a Federal Judge has certified a nationwide class of family-based derivative beneficiaries.

We link to each of the cases referred to in this article from our "CSPA" page at

http://shusterman.com/cspa.html
The question addressed by this article is how much, if any, deference, should the Federal Courts give the BIA's recent decision interpreting CSPA's automatic conversion clause. Matter of Wang, 25 I&N 28 (BIA 2009).

The automatic conversion clause of CSPA is section 203(h)(3) of the Immigration and Nationality Act as amended. In order to understand the meaning of this clause, it is important to read and understand the meaning of section 203(h) of the Act:

203(h) RULES FOR DETERMINING WHETHER CERTAIN ALIENS ARE CHILDREN -

(1) IN GENERAL.-- For purposes of subsections (a)(2)(A) and (d), a determination of whether an alien satisfies the age requirement in the matter preceding subparagraph (A) of section 101(b)(1) shall be made using--

(A) the age of the alien on the date on which an immigrant visa number becomes available for such alien (or, in the case of subsection (d), the date on which an immigrant visa number became available for the alien's parent), but only if the alien has sought to acquire the status of an alien lawfully admitted for permanent residence within one year of such availability; reduced by

(B) the number of days in the period during which the applicable petition described in paragraph (2) was pending.

(2) PETITIONS DESCRIBED- The petition described in this paragraph is—

(A) with respect to a relationship described in subsection (a)(2)(A), a petition filed under section 204 for classification of an alien child under subsection (a)(2)(A); or

(B) with respect to an alien child who is a derivative beneficiary under subsection (d), a petition filed under section 204 for classification of the alien's parent under subsection (a), (b), or (c).

(3) RETENTION OF PRIORITY DATE- If the age of an alien is determined under paragraph (1) to be 21 years of age or older for the purposes of subsections (a)(2)(A) and (d), the alien's petition shall automatically be converted to the appropriate category and the alien shall retain the original priority date issued upon receipt of the original petition.

(4) APPLICATION TO SELF-PETITIONS- Paragraphs (1) through (3) shall apply to self-petitioners and derivatives of self-petitioners.

Since section 203(h)(3) refers to "subsections (a)(2)(A) and (d)" of section 203, it is also necesssary to read and understand both of these sections of law.

Section 203(a)(2)(A) provides as follows:

(a) Preference Allocation for Family-Sponsored Immigrants. - Aliens subject to the worldwide level specified in section 201(c) for family-sponsored immigrants shall be allotted visas as follows:

(2) Spouses and unmarried sons and unmarried daughters of permanent resident aliens. - Qualified immigrants -

(A) who are the spouses or children of an alien lawfully admitted for permanent residence.

In simple English, this section of law refers to spouses and children of permanent residents who are petitioned under the family-based 2A category.

Section 203(d) provides as follows:

Treatment of family members

A spouse or child as defined in subparagraph (A), (B), (C), (D), or (E) of section 101(b)(1) shall, if not otherwise entitled to an immigrant status and the immediate issuance of a visa under subsection (a), (b), or (c) of this section, be entitled to the same status, and the same order of consideration provided in the respective subsection, if accompanying or following to join, the spouse or parent.

In simple English, section 203(d) states that spouses and children of principal beneficiaries of visa petitions are entitled to permanent residence in the same category as the principal. In other words, if a U.S. citizen brother petitions his sister for a green card, not only does the sister obtain permanent residence in the family-based fourth preference category, but her husband and children also qualify under the same category. Or if a person qualifies for a green card through employment or through the visa lottery, his spouse and children also qualify under the same category as the principal.

Section 101(b)(1) defines "child" for purposes of immigrating to the U.S. In general, a child is defined as a person who is under 21 years of age and who is unmarried.

Spouses and children under section 203(d) who are accompanying or following to join the principal beneficiary of a visa petition or the winner of the visa lottery are commonly referred to as "derivative beneficiaries".

In Matter of Garcia (2006), an unpublished decision of the Board of Immigration Appeals (BIA), the Board considered the case of Maria Garcia, a "derivative beneficiary" who was born in Mexico. On January 13, 1983, Maria's mother was petitioned as the sister of a U.S. citizen. At that time, Maria was only nine years old.

Under section 203(d), Maria was a derivative beneficiary who would have been eligible to become a permanent resident along with her mother as long as she remained a "child", that is, unmarried and under 21 years of age. However, by the time that visa numbers became available to Maria and her mother in 1996, Maria was 22years of age. In common parlance, she had "aged-out". By 1996, the only relief that was available to Maria was for her permanent resident mother to submit a visa petition on Maria's behalf under the 2B category for unmarried adult sons and daughters of lawful permanent residents. Maria's mother did just that in 1997.

However, Maria was placed in deportation proceedings, and by the time her case was decided by the BIA on June 16, 2006, visa numbers were available in the Mexican 2B category only to persons whose lawful permanent resident parent(s) had petitioned for them before October 22, 1991, a 15-year wait.

Under the law as it existed prior to CSPA, Maria would have had to wait in line for a green card twice. First, she waited from 1983 to 1996, a period of 13 years for a family-based 4th preference visa number to be current. However, she was no longer a child under section 101(b)(1) because she had reached the age of 21 before her visa number became current in 1996. Therefore, she lost her place in line for a green card. When her mother petitioned for her in the 2B category in 1997, she would have had to go to the back of a 15-year line and be separated from her mother until 2012. Furthermore, if Maria married prior to immigrating in 2012, the visa petition would automatically terminate. By then, she would be 38-years-old.

The unanimous BIA panel which decided her case in 2006 held that CSPA's automatic conversion clause applied to Maria Garcia. The Board held that Maria was no longer a "child" for purposes of section 203(h)(1) since she was 22 years of age when her visa number under the family-based fourth preference category became current, and since the visa petition was approved the same day that it was submitted, no time could be subtracted from Maria's age under CSPA.

Because she was still a "derivative beneficiary" under section 203(d) except that her age was more than 21 years old, the Board held that she qualified for automatic conversion of her visa petition under section 203(h)(3). They then addressed the question of what was the "appropriate category" that the visa petition should be "converted" to. The Board held as follows:

"The respondent was (and remains) her mother's unmarried daughter, and therefore, the 'appropriate category' to which her petition was converted is the second preference category of family-based immigrants, i.e., the unmarried sons and daughters of lawful permanent residents. Furthermore, the respondent is entitled to retain the January 13, 1983, priority date that applied to the original fourth-preference petition, and therefore a visa number under the second-preference category is immediately available to the respondent.

The Board, in Matter of Garcia, did not find the statutory language of section 203(h)(3) ambiguous. Since this section of law specifically applies to derivative beneficiaries as defined by section 203(d), the Board found that Maria Garcia was entitled to benefit from the automatic conversion clause. They remanded the case to the Immigration Judge to consider her application for adjustment of status.

Three years later, in Matter of Wang, the Board refused to follow the reasoning of Matter of Garcia, held that the language of section 203(h)(3) was ambiguous and ruled that CSPA's automatic conversion clause did not apply to derivative beneficiaries.

This ruling is puzzling to say the least. How can section 203(h)(3) not apply to derivative beneficiaries when it specifically references section 203(d), the section of law which concerns derivative beneficiaries? Matter of Wang essentially deletes this reference to section 203(d) from the statute.

Further, the Board fails to discuss what it finds "ambiguous" in the language of section 203(h)(3). It simply goes on to discuss the legislative history of this section of law when no such legislative history exists.

The starting point of all statutory interpretation is the intent of Congress, and “‘[d]eference to the (agency's) interpretation...is only appropriate if Congress' intent is unclear.’" Padash v. INS, 358 F.3d 1161, 1168 (9th Cir. 2004). Where traditional tools of statutory construction reveal Congress’ intent, “deference is not required at all.”

USCIS' Redesigned Website: Our Suggestions

To contact us Click HERE
The USCIS announced that, on September 22, the agency "will launch a vastly improved public Web site to help customers navigate the immigration system and remain up-to-date regarding their case status." See the USCIS Fact Sheet dated August 11 at

http://www.shusterman.com/pdf/redesign.pdf

Almost 10 years ago, the INS redesigned its website. We were very critical. See our review entitled "INS's New Website Emphasizes Content Over Form(s)" at

http://shusterman.com/sep99.html#6

We pointed out that after spending millions of dollars and employing a great many experts, the INS website did not even allow readers to access as many INS forms as our website. The INS Webmaster responded to our review on September 20, 1999. See

http://www.shusterman.com/beyer.html

Subsequently, the INS established the best U.S. immigration website on the Internet.

However, several years later, the INS again redesigned its website, and in the process, eliminated many of the most helpful features of the site.

Since the USCIS is once again redesigning it's website, we wish to make a few suggestions:

1. Please do something to improve the search engine.

Our website has more links to the USCIS website (several hundred) than any other site on the web. So we empathize with readers who tell us that it is extremely difficult to find information on the USCIS website. For example, take a look at the first link above, the USCIS Fact Sheet dated August 11. We could not find this on the USCIS website, so we scanned in the Fact Sheet and posted it on our website.

Example: What if someone is interested in L status? Whether they type in "L", "L status", "L visa petition" into the USCIS search engine, they get the following answer: "404 - Requested Page Not Found on Site".

The USCIS search engine, even when it is working, leaves a lot to be desired.

2. Make the website easier to navigate.

Your fact sheet lists the following customer comments about the present USCIS website. It is "hard to navigate", "overwhelming" and "frustrating". That's because the layout of the website is illogical. For example, let's say someone is searching for information about L status. How do they find this information at www.uscis.gov?

The website has the following buttons near the top of the page:

* Services & Benefits
* Immigration Forms
* Laws & Regulations
* About USCIS
* Education & Resources
* Press Room

Where would one find information about L status? Probably under "Services & Benefits". Clicking this button leads one to a four-paragraph general introduction which ends with the following guidance: "For information about a particular immigration benefit or service, please select the appropriate button on the menu to your left."

The menu on the left contains a total of 17 different items, none of them clearly relating to L status or temporary visa categories. So we decided to click the "How do I Customer Guides". This page lists six different categories of guides, one of them being "Nonimmigrants". Fine for an attorney, but does the average immigrant realize that the word "Nonimmigrants" relates to temporary visa categories like the L category? Probably not.

However, let's assume that the reader clicks on "Nonimmigrants". This leads to a page which contains three links, the most appropriate being "How do I Change to Another Nonimmigrant Status?" Click on this link, and you are transported to a three-page PDF file. The file lists some of the 40 types of nonimmigrant categories, but provides precious little information about any of these categories. For instance, with reference to the L category, the document states "L-1A or L-1B Intracompany Transfer". Not very helpful, is it?

By this time, the person has probably given up on the USCIS website and found all the information that they need to know about L status on our website at

http://shusterman.com/toc-temp.html#3m

And where did we get all this great information about L status? Confession: We copied and pasted it from the old INS website! (which leads us to our next suggestion...)

3. Bring Back the Old INS Website

Or at least make the new USCIS website as useful as the old INS website was. For example, the USCIS used to include four charts which relate to derivative citizenship. And we linked to all four nationality charts. For example, we linked to the chart for "Acquisition of U.S. Citizenship for Children Born Abroad in Wedlock" at

http://www.uscis.gov/propub/ProPubVAP.jsp dockey=6f3ca27ff6c196d35e87dae2221deee9

Every few weeks, the URL would change and we would have to repair the link. We wrote to the USCIS webmaster about this problem, but we never received a reply. Now, it seems that the USCIS has removed all four nationality charts from their website. Why? We have no idea.

We could write to the USCIS webmaster, but what's the use?

4. What's With the Long URLs?

Check out the following web page:


http://www.uscis.gov/portal/site/uscis/menuitem.eb1d4c2a3e5b9ac89243c6a7543f6d1a/?vgnextoid=4f719c7755cb9010VgnVCM10000045f3d6a1RCRD&vgnextchannel=4f719c7755cb9010VgnVCM10000045f3d6a1RCRD

What's this, you may ask? It's USCIS' page regarding "Lawful Permanent Residence (Green Card)". Why is the web address (aka, the URL) so long? Maybe there is a reason for the long URLs on the USCIS website, but we don't know what it is.

5. Help Immigrants and Their Employers Find Good Legal Advice

The USCIS website wisely advises persons not to use the services of notarios or "immigration consultants".

However, it does little to advise immigrants where to find knowledgeable and experienced immigration attorneys. USCIS' "Finding Legal Advice" page contains eight links: To the websites of the American Bar Association and the National Organization of Bar Counsel and even to EOIR's list of "Free Legal Service Providers". However, when one clicks on this last link, the list indicates that the services of these attorneys are not necessarily free, and what's more, this list is for persons in removal proceedings who cannot afford an attorney. Not exactly the list that an employer who wants to submit a PERM application or a permanent resident who wants to apply for naturalization needs.

A long time ago, we suggested to the USCIS that since four states (California, Florida, Texas and North Carolina) certify certain attorneys as Specialists in Immigration Law, why not link to the lists of these specialists. On November 6, 2006, Alfonso Aguilar, the Chief of USCIS' Office of Citizenship told us that he would do so. See

http://shusterman.com/pdf/certsp1106.pdf

We have been waiting for this to occur for nearly three years. Please surprise us, and add this to the new USCIS website!

a car at milan

To contact us Click HERE
a car at milan
remove your in-dash car radio is generally quick and easy. Disassembly and assembly are best, leaving the passenger seat, when you right hand. Some, but only a small number of cars, indent the environment to remove the radio because the radio can be with screws.

Your first step to your original radio. Pay special attention to the individual steps, such as the conversion is simply a reversal of removal.

There are several radio-assembly methods between the various car manufacturers. However, the majority of factory-equipped radios are either in a metal shell (also known as cage) of two or four screws securing clips that you push inwards to the radio, or using the same method, without sleeves.

For radios that have one or two small round holes on both sides of the radio, you can use standard (DIN) radio removal keys in all car accessories shops or websites.

DIN radio tools let the majority of the radios in pre-2004 Fiat, Ford, Land Rover, MG, Peugeot, Rover, and many makes radio. Simply insert the key into the holes until they lock into place (for radios with only two holes, you can simply use the buttons curve). Some radios need to make four small Allen screws (with a 2 mm or 5 / 64 Allen key) before you can remove the key. I believe that this simply a safety measure.

Now push the key a little outwards, away from the radio, the fuse will push the spring clips inwards. Now, drag the key to eliminating disposal of radio. Some radios are a bit stubborn, but a little perseverance should pay off.

Some factory-installed radios are held in place by the screws on the sides of the radio. This type of assembly concept is mainly on Japanese cars and radios that are behind the dash that surrounds the radio. Most radios have some sort of backwards, but this is more often than not, just a push fit.

Once you have the radio out of his sleeve, disconnect the antenna and factory wiring harness connectors.

If you have problems with the removal of radios that are behind the dashboard to try ringing your local dealer. Ask for the service department and ask to speak, a technician, as they are usually glad to help. On the other hand, you can always have a Haynes manual.

These people are specialized in car audio installation. I give them the thumbs - I work with them daily (so I know their business philosophy - customer satisfaction). Read more car audio installation articles here

Chimezirim Odimba writes for CarAudioPlus.

a car cambridge

To contact us Click HERE
a car cambridge
Stansted and Luton airports are two of the five international airports in London. They are all owned and operated by the BAA, and access to all areas of London. To round the towns nearby you should UK Airport Car Rental and both airports are popular car hire locations

Stansted To start, you have the opportunity to work with the surrounding hotels as a form of base, or with the airport as a hub to connect to another airport. This third busiest airport in the United Kingdom is a terminal with an air-bridge and connected transit system. In the airport there is Internet access, currency conversions, and several shops and restaurants. Landing at Stansted Airport is southwest of London and Cambridge. If you wish, London Stansted Airport car rental is available. This airport is planned to take in the coming years due to capacity being met, to 25 million passengers per year. If the proposal is to expand by 2015 Stansted will have the capability to even more passengers than Heathrow.

There are some, though, that fighting this expansion, although they have a negative effect on the environment, with ad-land that is not pleasing to nearby residents. The original purpose of the airport, it was simply relieve Heathrow and Gatwick airports. It has since come into its own with an increasing number of passengers and flights.

The nearby London Luton Airport is located approximately 30 miles north of London city proper. It is the fifth busiest airport in the United Kingdom. In general, serves as a hub for the operation of the other four airports in and around London. You can also use London Luton Airport Car Hire here.

Luton When opened, the focus was on commercial operation as a passenger with. He added that in 1985 an international terminal, and in 1990 was renamed London Luton Airport to maintain its connection to the City of London recognized. Nevertheless, this is just an airport runway, and it is equipped with the technology to support the aircraft during landing in bad weather.

It also has the popular Silverjet terminal, which hosts around 100 passengers, and process them for less than 30 minutes. It is located in the terminal. The Luton even an 8% rate for charter flights from the runway, and has the ability to accept and cargo flights.

This airport is located, this growth in recent years is that the site of an enterprise of exploring the surface movement surveillance and control tools. This increases the security of the airport, as well as the capacity and efficiency, since the number of passengers continues to climb.

The extension is that the environmentally conscience organizations, because the flight paths from Luton are currently creating disturbances in the Chilterns Area of Outstanding Natural Beauty.

The plans for this extension are required for today, since the expansion of the year 2007 have been stopped. They Airport plans to revise some flight paths to avoid as many major cities as possible, and to improve the airport in its current form.

If you live in the United Kingdom, it is much better, even the cars available for the UK. You can even rent a car London Stansted Airport or a Car Hire London Luton Airport. They are readily available and now is the best time to book.

a car cornwall

To contact us Click HERE
a car cornwall
She is everything you need, you try it everything it asks, the clothes, the dog, and the summer holidays, but now that her Sweet Sixteen is fast approaching you need the perfect car and not just any car will do.

Sure she wants a Porsche, they even mentioned an Audi, but you still want to keep it in style, but not her everything she wants. That is why the BMW 1 Series is a great choice and a wonderful first car for teen girls in your life.

The BMW 1-Series at a Glance is sporty and cute. No frills and no real bling, but it is still 100% of all BMW. This sporty little number is up to 25 miles to the gallon, so it is ideal for all your little angel days trips to the mall or on the beach. The sporty style of the BMW is it the envy of other children their age, no matter where she goes.

BMW has the price adequately reflected in this line. One of the less expensive versions of the sports car, the BMW 1 Series, which the car as a gift to your teen still affordable. Competitive prices within a medium price range, you can even have your teen help make the payments on this car.

Just because this BMW comes cheap does not mean it lacks in style and content. While there are two options available to style, the coupe and convertible, the coupe is a safe choice, while still sporty and elegant at the same time. The coupe with four passengers and are still living up to high standards of quality and safety. The convertible bond is a bit flashier and offers a playful substance that many other cars in its price range definitely missing.

There is no need to worry if your teen will be disappointed or not with either the BMW 1 Series coupe or convertible, they are the perfect choice. Affordable, modern and secure, the BMW 1 Series is not just your teen happy, it will look as good. Remember, if your teen is not happy, nobody is happy.

Richard McCombs writes interesting articles about used cars for a popular automotive website. If you want to see good used BMW car deals go to Autoweb.

a car dorset

To contact us Click HERE
a car dorset
When selling a cheap car, there are a few tips that can help not only sell a vehicle quickly, but for the price the seller is looking for. Choose where your car for sale, is one of the first steps. With leverage and placing ads in several places, such as free classified ads may also help your vehicle is available. Note that some of these measures can be used to some more than others, but ideally, this should help is that someone has for a quick sale and / or maximum price.

First impressions are key to an interested buyer. The appearance of a car can do a lot to make them attractive and valuable. Now of course, not every vehicle price $ 1000 or less, the competition winners, but there are some things that can be done for a vehicle, no matter what kind of condition its in. First of all, when is the last time, when the vehicle washed? One detail perhaps not worth the time it takes to do that, and there will be some flaws, though, dents and damage, which we simply can not avoid. However a little time to wash the car and make a good vacuum, and perhaps even some wax-service products, we can on the long road to a serious sales accelerate. There are tons of vehicles, which have probably sold much higher / faster when the seller for a little time so clean. Personally, one thing I cringe as a buyer to do is to remove the garbage under the seats of vehicles Ive purchased. (You would not believe some of the things I have found!)

Nevertheless, focusing on general appearance, sometimes a little repair may also be in order. Of course we are mainly talking back $ 1000 or so fewer cars in some cases, sellers may not want or need, to repairs, alterations, etc., so take these tips as needed. Body work can be very expensive to have, by a professional and very time consuming to do, but some of the small things you can do. Article wipers often lose their color or very weak, and everything you need to do in most cases, give them a quick coat of some black spray paint. (usually gloss). Now we can discuss this information for days on end, but keep in mind that some repairs or cleaning can be used with very little effort and almost without cost to make your car more attractive to potential buyers. In fact, the more $ $ 1000 cars I've heard, where people thought I had such big hands, the vehicles were better. (my $ 300'89 Buick ran like a Champ, and looked like a chump therefore has little love)

In short, this was broken down into two sub-series. Check Part 2 for tips on the photos and a good display, the full inbox and the phone rings.

About the author:

Ostrowiak Brian is the co-creator of http://www.1000DollarAutos.com and an avid car enthusiast who often buys and sells cars and trucks for less than one thousand dollars.

1000DollarAutos is the best place to buy and sell vehicles of all kinds for $ 1000 or less. If you look to buy or sell a car or truck for a thousand dollars or less as soon as possible to visit http://www.1000DollarAutos.com right now to post your ad or check the current ads.

1000DollarAutos - the place with thousands of cars for hundreds of dollars.

a car essex

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a car essex
It was 1981 or 82 and we had decided to visit some friends in Southern California. We were not much for traveling these days. Not that we do not enjoy, and we just do not really money and lives in Phoenix during the summer travel 500-600 miles in 115 degree weather was not very appealing. But Janice and Andy was that we visit, because they are so good friends of us before they left our neighborhood because of his firm transfer. Jane and Janice, in fact, were at the hip to 7 years, she lived two houses and the children played together almost every time.

Jane convinced me that was launched in July this year to visit our good friends. I have read the rules for exemption from work, and we were west-bound, that last week in August in our trusty camper. We have our time and drove the southern route to San Diego to stop several times to stretch our legs and walk a little arrival in San Diego that evening at 5 clock, where we have a couple of nights in a very nice RV Park near the water and enjoyed two days of Sea World and the San Diego Zoo, before the motorway at the Mariner's home in Costa Mesa. The days are warm, but with a cool breeze and the nights were absolutely delightful. Jane slept like a baby to walk to both parks for a solid 8-10 hours, but I was up and down both nights are not used to the shores of the air.

Driving north on the fourth day between San Diego and Los Angeles, we found one of the drive-in zoos and Jane that we made it. It was quite interesting, with the animals to walk everywhere. They would benefit from one section to another waiting for each gate to open to take you to another animal group. Many were walking through the park with other only in the sun or shade and you could stop and the images and take your good old time working your way through the park It was fascinating to observe the animals in this environment in contrast to the previous day at the zoo.

At each gate, there were clear instructions to keep your hands in the windows, they rolled over like animals came close to the car and by all means do not honk your horn. Unfortunately, there was a car of young adults something to do, after some time trying to stir up the pot with the big cats. You could see them taunting the lions, in the distance, hoping they would come closer. They would call it, hold it arms and head out the door and into her arms wildly around the animals attention. Fortunately, for the most part, the animals paid little attention with only a slight lifting of the head, a brief look of disgust and then head back to the no pay no-mind.

But that does not apply to Mr. Elephant. Although the people were not trying to his attention, he was the one who had enough of this nonsense. He gradually made his way to our car, but to our surprise, the young couples either saw him or have enough of them even ignored and flew just in time. But there we were between the elephant and the cars behind us. Not sure what to happen, we rolled our windows and watched as Mr. Elephant strolled to the front of the motorhome, slightly increased his tribe, gave a slide nod, and then sit on the front or our hood. "" Oh my God, what are we doing now? "" I could hear Jane talk. I must admit, I was at a complete loss. The big Fella not do it. He made his statement very clear, then stood up again and went with absolutely no fan fare. A few tonnes to cover my whole left an impression, if you know what I mean.

At the beginning I was very worried about my radiator but once outside the park, where we might not indicate anything leaking. I went to the office, people were very apologetic and the park and we have a few calls to the insurance and within an hour or so, and we were on the way to Andy and Janice's.

Withdrawn, as we at the San Diego Freeway to the north, we had not gone more than 3 miles and a car about 4 cars ahead of us are impatient and tried to trace not notice the car next to them before they knew it was there three cars pile up that we just - two cars and a motorhome. After seeing that everyone seemed to be good, we have found that cars in order to shoulder, around the crash site. We have decided to follow them because we were tired and with a little bit late, after it has been in the park What have we not noticed was that for some reason, the campers also left the scene of the accident, before Highway Patrol arrived .

Jeff Gustafson is a media professional with improvement, LLC. A successful singer / songwriter and founder of http://www.myhatt.com an international cultural awareness Concept and Strategy Golf Central.

a car from milan

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a car from milan
Sometimes I am asked, what are the differences between Formula 1 and Champ Car chassis. But how many people really know what a Champ Car is? (I'm often asked to explain what they are)

Unfortunately, the majority of today's non-racing public can only know what "RASSCAR" (Nextel Cup) is ... So my simple answer is: Do you know the cars at the Indianapolis 500? These are "Indycar," which loosely resembles Champ Car.

Although technically speaking, the Indy 500 is the only area of the Indy Racing League, Champ Cars are not. This is due to the current state of open-wheel race was between two opposing sanctioning bodies in the Cart-IRL split in 1996, came back ...

The most notable visual difference between a Champ Car and IRL chassis, the rear bonnet. Turbo Champ Cars will not use an overhead airbox. IRL cars with a "Formula-1-esque" Airbox to RAM air into the engines buried in the induction of carbon-fiber casing ...

And yet this year, the brand new Panoz DP-01 Champ Car will be for a hybrid of the series former Lola B2K chassis and a current Formula-1-spec candidate with his new wing before the treatment. The new Panoz also use similar F1 steering wheel mounted paddle shift and a variety of new electronic engine management functions including the elimination of the ubiquitous "pop-off valve ...

One interesting twist on the topic of open wheel racing cars terminal velocity has been the announcement that the F1 BAR-Honda would attack the Bonneville Salt Flats in October 2006 in an effort to break 400kph ...

Further details were shone during last July, the Formula 1 qualifying at Silverstone. (Sat, 7/09/06), when the speed channel Bob Varsha some interesting comments in the 5-shipment.

Varsha noted that the BAR-Honda "jalopy" was expected to "Max out" in 250 + mph, a change in the Formula-1-chassis with front and rear wings away and use a parachute ...

This leads back to another question I am often asked: What is faster: "The chicken or the egg. The Coyote and the Roadrunner?" ERR, Formula 1, or "carZs hip?"

This leads naturally to a comparison of the competing machines. The 2005 BAR-Honda 007 chassis is a 3.0-liter normally aspirated V-10,
According to rumors, the production 955bhp@19.200 RPM's ... But in July 2005, BAR-Honda was the last place in the Constructors' Standings F1.

Meanwhile die'05 Champ Car, the Lola / Cosworth 2.65-liter turbo V-8 production was 750bhp @ 37 "reinforcement. Cosworth use of the" push-to-pass "technology allows riders 60 seconds of "Turbo Boost" an additional 50bhp, for a maximum power of 800bhp.

During the waning years factory backed Champ Car (CART) racing, engines were fast approaching 900bhp. And in 2000, Gil de Ferran captured Honda fifth consecutive CART drivers' championship, while a new world closed course speed record of 241.428 mph at California Speedway. (Fontana, CA: 2.5 miles Tri-oval)

Meanwhile, the F1 circus hit "Terminal Velocity" speeds of 221 + mph on the front right of Indianapolis, during the long blast directly using full throttle for 21 seconds ... (before the 2005 Michelin tire debacle! Fortunately at Portland GI Joe's Champ Car race ...)

This was before the Formula-1-reducing engine 3.0-liter normally aspirated V-10 is up to 2.4 liter V-8 is made by lopping two cylinders in an effort to reduce benefits, which threatens to over 1000 HP!

This was in the middle of the 1980s in the F1 turbo era, which had seen 1,100 + horsepower during qualifying from the small 1.5 liter inline 4's and V-6 twin-turbo engines. The spiraling increases horsepower to the FIA (Formula 1 of the sanctioning body) to the normally aspirated, with the introduction of 3.5 liters of displacement maximum in 1989 with a decline to 3.0 liters in 1990 ... (This engine formula in 1990 remained until 2005)

The monsters of all time were known as Am, the races from 1966-1974. This saw the development of the all-conquering German Panzer, also known as the Porsche 917/30, the housing 12 turbo engine was rumored to more than 1300 hp ...

But in the mid-90s direct descendant of the Porsche 917's: The 956 is followed by the dominant's 962 vs. Jaguar XJR's (Lemans prototypes) were both beams to 3.0 miles Mulsane just shy of 250mph. (246 + mph) This led to the addition of two chicanes added whittle that directly ...

Naturally top speed is simple when compared to the vehicle application ...

On Oct. 15, 1997 the British Thrust SSC was the first jet-powered "car" to the Speed of Sound! (Mach 1) The dual-engine land jet blasted a two-way average speed of 766.609 mph ...

And only if the ultimate speed limits of the end?

For example, the Lockheed SR-71 flies faster than a speeding bullet (3,000 km / h), while the XB-70 Valkerie broke all records with a maximum speed of Mach 5! (3,700 + mph)

That is ultimately faster: Formula-1-or Champ Cars? Unfortunately, this will never really be answered, as the two different forms of open-wheel cruise missiles at different engine formulas, rules packages, different tires, weights, fuel, gear ratios, etc. And the biggest limiting factor is the different aerodynamic rules enforced Formula 1-vs Champ Cars.

Also, the race is slightly different. During the two races on the traditional track circuits and the same "Point 'N Squirt" theory of racing. F1 drivers are better suited for final acceleration from corner to corner, while Champ Cars have been able to achieve higher speeds, while the banks continually circling approaches Oval Super Speedway in the late 1990s or today's exhibition runs the Indy 500 ...

But during 2006, the Champ Car World Series race at Montreal's Circuit Gilles Villenuve, site of the Canadian Formula-1-race, the lap times were nearly 7 seconds slower then the F1 cars ... (Lap Time Comparison: 1:14.942 = F1 vs Champ Car = 1:21.856)

Tomas Rotelli is an aspiring writer Motorsport, together with an avid racing fan in the past two decades plus. Living in Seattle, WA I have a variety of different racing venues, especially the permanent road courses and temporary street circuits.

I have my trip in written form in the mid-1990s during a monthly Penning Ford Racing News Colum for WASAAC (Washington Shelby Automobile Club) for 6 years ...

I have the good fortune to attend a variety of vintage car races at the various venues, including: Monterey, Sonoma, Seattle and Portland. I also have fun at several Formula 1, Champ Cars (CART) and IMSA GTP & ALMS races in the last few years ...