Matter of Montiel, 26 I&N Dec. 555 (BIA Apr. 17, 2015) (immigration judge has discretion to delay removal proceedings, where warranted, pending the adjudication of a direct appeal of a criminal conviction); following Matter of Avetisyan, 25 I&N Dec. 688 (BIA 2012).
Cal Crim Def 21.24, 20.28

Note: There is no logical reason why the immigration court does not also have discretion to postpone removal proceedings when other requests for post-conviction relief are pending.

 

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