PRACTICE ALERT: SANCHEZ V. MAYORKAS
Eighth Circuit Courts of Appeal had held that it did,2 whereas the Eleventh, Fifth, and Third Circuits had held that it did not.3 Thus, until the Supreme Court weighed in, TPS holders living in the Ninth, Eighth, or Sixth Circuits could apply to adjust even if they had last entered the United 1 No. 20-315, 2021 WL 2301964 (2021). 2 See Flores v.
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