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INA §245 Overview

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INA §245 • 8 U.S.C. §1255

INA §245 Adjustment of Status

INA §245 is the central federal statute governing many applications for lawful permanent residence filed from inside the United States. Its subsections establish the basic adjustment rule, statutory bars, exceptions, grandfathering provisions, employment-based relief, special adjustment categories, and other requirements.

What does INA §245 do?

INA §245 creates several statutory pathways through which qualifying noncitizens in the United States may obtain lawful permanent resident status. Section 245(a) supplies the principal adjustment framework, while later subsections impose restrictions, create exceptions, and establish specialized rules for particular categories.

The Basic Framework

Four legal layers usually control the analysis

01

Basic eligibility

Determine whether the applicant satisfies the applicable adjustment provision, including the ordinary requirements of §245(a) where relevant.

02

Adjustment bars

Determine whether §245(c), §245(d), §245(e), or another statutory limitation prevents adjustment.

03

Exceptions

Analyze §245(i), §245(k), VAWA protections, special immigrant rules, or another statutory exception.

04

Admissibility & procedure

Separately determine admissibility, visa availability, evidence, jurisdiction, and USCIS procedural requirements.

Section-by-Section

Map of INA §245

Each subsection performs a different function within the adjustment statute.

§245(a)

Basic adjustment authority

Establishes the ordinary eligibility framework, including inspection and admission or parole, immigrant visa eligibility, admissibility, and immediate visa availability.

§245(b)

Record of permanent residence

Addresses recording lawful permanent residence upon approval and reduction of the applicable preference visa number.

§245(c)

Adjustment bars

Identifies classes barred from ordinary §245(a) adjustment, subject to statutory exemptions and exceptions.

§245(d)

Conditional residents and K visas

Restricts adjustment of conditional residents and limits adjustment of K nonimmigrants to the qualifying petitioner-based relationship.

§245(e)

Marriage during proceedings

Restricts marriage-based adjustment where the marriage occurred during specified proceedings, with a bona fide marriage exception.

§245(f)

Conditional EB-5 residents

Limits adjustment under §245(a) for persons already admitted as conditional permanent residents under the investor provisions.

§245(g)

Certain special immigrants

Deems qualifying special immigrants under INA §101(a)(27)(K) paroled for §245(a) purposes.

§245(h)

Special immigrant juveniles

Deems qualifying SIJs paroled and modifies the inadmissibility rules that apply to their adjustment applications.

§245(i)

Grandfathered adjustment

Allows certain qualifying beneficiaries of older petitions or labor certifications to adjust notwithstanding specified §245(a) and §245(c) problems.

§245(j)

S nonimmigrant adjustment

Creates a specialized permanent residence mechanism for qualifying S nonimmigrants who have provided required law-enforcement assistance.

§245(k)

Employment-based exemption

Makes specified §245(c) bars inapplicable to qualifying employment-based immigrants whose aggregate covered violations do not exceed 180 days.

§245(l)

T nonimmigrant adjustment

Establishes adjustment rules for qualifying victims of severe forms of trafficking and eligible derivative family members.

§245(m)

U nonimmigrant adjustment

Provides a permanent residence mechanism for qualifying U nonimmigrants and certain family members.

§245(n)

EB-5 concurrent filing

Provides for concurrent or subsequent filing of an adjustment application where approval of the qualifying EB-5 petition would make a visa immediately available.

Ordinary adjustment under INA §245(a)

Section 245(a) is the principal statutory provision for adjustment of status. It generally applies where an applicant was inspected and admitted or paroled into the United States, or qualifies under the statute's VAWA self-petitioner language.

The applicant must also apply for adjustment, be eligible to receive an immigrant visa, be admissible for permanent residence, and have an immigrant visa immediately available when the application is filed.

Important distinction

Satisfying §245(a) is the beginning of the eligibility analysis, not necessarily the end.

A separate subsection may bar adjustment even where §245(a) is otherwise satisfied. Conversely, another subsection may create an exception that permits adjustment despite an apparent problem.

See the complete INA §245(a) Guide.

Statutory bars and restrictions

INA §245 contains several limitations on adjustment eligibility. Section 245(c) contains eight principal bars to ordinary §245(a) adjustment. Other subsections impose additional category-specific restrictions.

ProvisionGeneral Subject
§245(c)Crewmen, status violations, unauthorized employment, Visa Waiver entrants, employment-based status issues, and other specified classes
§245(d)Conditional residents and K nonimmigrant adjustment restrictions
§245(e)Marriages entered during specified immigration proceedings
§245(f)Conditional permanent residents under the EB-5 framework

The applicability of a bar depends on the applicant's immigrant category and immigration history. Congress expressly exempted certain applicants from particular bars.

See the Adjustment Bars Guide.

INA §245(i) and INA §245(k)

INA §245(i)

Section 245(i) is a grandfathering provision. Certain applicants connected to qualifying immigrant petitions or labor certification applications filed on or before April 30, 2001 may be able to adjust notwithstanding entry without inspection or specified §245(c) bars.

Additional requirements can apply, including the December 21, 2000 physical-presence requirement for certain filings made after January 14, 1998.

See INA §245(i).

INA §245(k)

Section 245(k) provides a narrower employment-based exemption. Qualifying employment-based immigrants may adjust notwithstanding §245(c)(2), §245(c)(7), and §245(c)(8) where the covered violations after the relevant lawful admission do not exceed 180 days in the aggregate.

See INA §245(k).

Special adjustment categories within §245

INA §245 is not limited to ordinary family- and employment-based adjustment cases. Congress incorporated several specialized pathways into the statute.

  • Special immigrants under §245(g);
  • Special immigrant juveniles under §245(h);
  • S nonimmigrants under §245(j);
  • T nonimmigrants under §245(l);
  • U nonimmigrants under §245(m); and
  • EB-5 concurrent filing under §245(n).
Not every green-card application filed from within the United States arises under INA §245(a). Specialized adjustment statutes can establish materially different eligibility and waiver rules.

See Special Adjustment Categories.

INA §245 and inadmissibility are separate bodies of law

Adjustment eligibility under §245 should not be confused with admissibility under INA §212. A person can satisfy the §245 adjustment requirements but remain unable to obtain permanent residence because an inadmissibility ground applies.

Likewise, a person may have no inadmissibility problem but still be barred from adjustment by §245(c) or another adjustment-specific limitation.

Analytical order

First identify the adjustment pathway and any §245 bar. Then analyze admissibility and any available exception or waiver.

Visa availability remains essential

For ordinary §245(a) adjustment, an immigrant visa must be immediately available when the application is filed. Visa-number rules can also affect when USCIS is able to approve the application.

Numerically limited family- and employment-based categories therefore require careful analysis of the applicant's priority date, preference category, chargeability, the Department of State Visa Bulletin, and USCIS's monthly filing-chart determination.

See Visa Availability.

Form I-485 and the regulatory framework

The statute establishes substantive eligibility, while federal regulations and USCIS policy supply many of the procedural rules governing adjustment applications.

These rules address subjects such as:

  • How and where an application is filed;
  • Visa availability;
  • Initial and supplemental evidence;
  • Medical examination requirements;
  • Interviews;
  • Employment-based portability;
  • Jurisdiction;
  • Derivative applicants; and
  • Adjudication and discretionary review.

See the Form I-485 Process Guide.

USCIS and immigration-court jurisdiction

USCIS adjudicates most affirmative adjustment applications, but jurisdiction can change where removal proceedings are pending or where a particular regulatory rule assigns authority to an immigration judge.

Arriving-alien cases, reopened proceedings, terminated proceedings, and cases involving prior removal orders can require a separate jurisdictional analysis before determining where Form I-485 should be adjudicated.

See Adjustment Problems & Denials.

Need an INA §245 eligibility analysis?

The Messersmith Law Firm, P.A. represents clients in complex adjustment matters involving admission, statutory bars, §245(i), §245(k), inadmissibility, removal proceedings, RFEs, NOIDs, and denials.

Schedule a Consultation