Hernandez v. Holder, 738 F.3d 1099 (9th Cir. Dec. 24, 2013) (place-of-filing rule for motions to reopen, which provides that a motion to reopen must be filed with the immigration judge when the BIA dismisses an appeal on jurisdictional grounds, is only a procedural claims-processing rule and not a jurisdictional bar to the BIA's authority to consider a motion to reopen).

 

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