Matter of DK, 25 I&N Dec. 761 (BIA Apr. 2012) (noncitizen refugee under INA 207, 8 U.S.C. 1157, who has not adjusted status to LPR status may be placed in removal proceedings without a prior determination by the DHS that the noncitizen is inadmissible; distinguishing Matter of Garcia-Alzugaray, 19 I&N Dec. 407 (BIA 1986); when removal proceedings are initiated against a noncitizen who has been "admitted" to the United States as a refugee, the charges of removability under INA 237, 8 U.S.C. 1227 apply).

 

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