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Abstract: 

Our regular review of appellate court rulings examines six important decisions. The Ninth Circuit holds that a survivor’s severe, repeated abuse—while “tragic”—did not, without more, qualify as “extraordinary circumstances” to excuse VAWA’s one-year deadline for reopening removal proceedings. New Mexico’s high court protects immigrant victims by treating U/T-visa applications as privileged and confidential, barring compelled disclosure to criminal defendants while permitting limited cross-examination about potential benefits. In Montana, a grandmother secures post-adoption visitation after the child’s father murdered the mother, over adoptive paternal grandparents’ objection. West Virginia vacates denial of grandparent guardianship where a mother intentionally exposed children to a convicted child-pornography offender, requiring renewed best-interest analysis. Two custody/dependency decisions round out the review: New York affirms sole custody to a grandmother based on “extraordinary circumstances” rooted in DV exposure and minimization, while Vermont affirms termination of parental rights where DV, substance use, and housing instability prevented timely reunification—even absent a permanent placement.

Keywords: VAWA Immigration Relief; U And T Visa Confidentiality; Grandparent Visitation; Guardianship Standards; Extraordinary Circumstances; Termination Of Parental Rights

Affiliations:  1: Contributing Editor; 2: Associate Editor.