Davila-Bardales v. Immigration and Naturalization Service

Davila-Bardales (plaintiff), an unrepresented, unaccompanied minor under 16, admitted illegal entry and confirmed an I-213 form's accuracy at his deportation hearing, even though INS regulations barred using an unrepresented minor's admission of deportability in such circumstances; the immigration judge relied on these admissions to order deportation, and the Board of Immigration Appeals (BIA) affirmed, distinguishing the I-213 form itself from the barred admissions. On the very same day, in an unrelated case, the BIA had expressed skepticism requiring close scrutiny of I-213 forms used against juveniles under similar circumstances.