Zerezghi v. United States Citizenship and Immigration Services

A citizen petitioner has a constitutionally protected interest in the granting of his I-130 petition; the government’s use of undisclosed records in making a marriage-fraud finding violates procedural due process; the substantial and probative evidence standard in 8 C.F.R. § 204.2(a)(1)(ii) must be at least as high as a preponderance of the evidence.

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