Recently Filed Complaint Could Have Significant Impact Upon K-1 Visa Processing Procedures

This post will briefly analyze a recently filed complaintfor a visa under section 212(a)(6)(C)(i) of the Act." INA
against the US Federal Government and those212(a)(6)(C)(i), 8 U.S.C. 1182(a)(6)(C)(i), is a permanent
agencies responsible for making K1 visa applicationbar to admissibility for misrepresentation. Pursuant to
adjudications.the Foreign Affairs Manual, 9 FAM 40.63 N10.1, State
This writer often discusses issues which might haveDepartment placed a marker, called a "P6C1" marker,
an impact upon the overall processing procedures ofor "quasi-refusal" in Ms. Pham's records, and will deem
American Family Visas. In the case of Tran v.USCIS revocation of the petition as automatically
Napolitano*, a lawsuit that was recently filed in theestablishing the permanent misrepresentation bar to
Oregon Federal District Court, an American Citizen hasany future immigration possibility.*
challenged the current administrative protocolsAlthough this article will not attempt to go into all of the
associated with K-1 visa adjudication and denial.details of the complaint, it should be noted that the
At the time of this publication, there seems to be someplaintiff seems to allege that the Consular Officer
institutional confusion within the American Immigrationadjudicating the application, on more than one occasion,
apparatus regarding the exact nature of visa refusalsmade determinations that were "conclusive,
issued by US Consular Posts abroad. For instance,speculative, equivocal or irrelevant"*. The result of this,
when a visa applicant from a country participating inin the plaintiff's view, incorrect adjudication was the
the Visa Waiver Program is issued a 221(g) refusal inplacement of a "quasi-denial" marker in the plaintiff's
connection with an immigrant family visa, a K-1 fiancefiancee's case file. This "qusai-denial," when coupled
visa, or any US visa for that matter; then that refusalwith a later revocation by USCIS, which happens
could detrimentally affect that individual's ability toautomatically if the petitioner doesn't proactively dispute
subsequently enter the United States on the visathe revocation, results in the automatic establishment
waiver program. In accordance with recentlyof a permanent bar to admission to the United States
promulgated protocols under the Electronic System forirrespective of the fact that USCIS initially approved
Travel Authorization (ESTA) the United Statesthe underlying petition.
Customs and Border Protection Service (USCBP)Some may argue that this process of finding an
would seem to view visa application "refusals" by theapplicant permanently inadmissible is "boot strapping" in
Department of State as "denials" which should bethe sense that the two agencies involved use
disclosed by those seeking admission to the US underadministrative protocols such as automatic
the Visa Waiver Program. Existence of said "denial"establishment of permanent misrepresentation based
could potentially result in USCBP refusing to grant theupon "conclusive, speculative, equivocal or irrelevant"*
alien admission to the USA under the visa waiverfindings, rather than legal and factual findings on the
program.part of the Consular Officer, to bar admission to
In the previously cited Tran* case, an issue similar tofiances of United States Citizens.
the "refusal" vs. "denial" dichotomy was brought to light.It remains to be seen how this case will unfold, but
In a direct quote from the initial complaint, the plaintiffthere is no doubt that the ultimate decision in the case
alleged that the:could have a significant impact upon the way in which
State Department, in its denial, stated that, "[i]f USCISK-1 visa applications are processed in the future.
revokes the petition, beneficiary will become ineligible