Barrios v. Holder, 567 F.3d 451 (9th Cir. May 27, 2009) (a minor who seeks NACARA special rule cancellation of removal, under Nicaraguan Adjustment and Central American Relief Act 203, as a derivative, must personally satisfy the Act's requirement of seven years of continuous physical presence; the father's physical presence in the United States cannot be imputed to him to satisfy this requirement).



NOTE: The court distinguished Cuevas-Gaspar and Escobar v. Holder (decided the same day as Barrios) on the basis that while the court imputes a parents "status, intent or state of mind" to an unemancipated minor child, it does not impute actual physical presence required under NACARA.