Matter of Patel, 16 I. & N. 600 (BIA 1978) (once there is a remand that is not limited or qualified, the immigration judge may consider other and further relief).



A respondent may therefore apply for additional discretionary relief before the Immigration Judge when the BIA remands a case, unless the BIA has specifically limited the purposes for which the case is remanded. A BIA order remanding a case to allow an application for a specific form of relief would not be considered such a specific limitation, as it does not expressly preclude applications for additional forms of relief. Thanks to Lory Rosenberg.