Matter of Garcia Arreola
June 23, 2010
**Mandatory detention**
Section 236(c) of the Immigration and Nationality Act requires mandatory detention of a criminal alien only if he or she is released from non-DHS custody after the expiration of the Transition Period Custody Rules (“TPCR”) and only where there has been a post- TPCR release that is directly tied to the basis for detention under sections 236(c)(1)(A)–(D) of the Act. Matter of Saysana, 24 I&N Dec. 602 (BIA 2008), overruled.
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