Pablo Mejia-Castanon v. Attorney General United States, 931 F.3d 224

Mejia-Castanon, a Guatemalan national, entered the U.S. without inspection in 2002 and was placed in removal proceedings; DHS served a Notice to Appear (NTA) process beginning October–November 2013.
He applied for cancellation of removal under 8 U.S.C. § 1229b(b), which requires (inter alia) 10 years continuous physical presence and being of good moral character "during such period."
Mejia admitted at a 2017 merits hearing that he paid to help relatives illegally enter the U.S. in 2015–2016—conduct that constitutes alien smuggling and statutorily disqualifies one from being of good moral character.
The legal question: whether the IIRIRA "stop-time rule" (8 U.S.C. § 1229b(d)(1)), which deems physical presence to end upon service of an NTA, also truncates the 10-year period for evaluating good moral character.
The BIA (In re Ortega-Cabrera) held the stop-time rule does not apply to the good-moral-character period; the Board evaluates moral character over the 10 years preceding the final administrative decision.
The Third Circuit granted review and, applying Chevron deference, affirmed the BIA: the stop-time rule does not cut off the good-moral-character window, so Mejia is ineligible for cancellation because his 2015–2016 conduct falls within the applicable moral-character period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop-time rule terminates the 10-year good-moral-character period upon service of a notice to appear	Mejia: "during such period" ties moral-character window to the physical-presence window, so service of an NTA stops accrual and excludes post‑NTA misconduct	Government/BIA: stop-time rule applies only to physical presence; §1229b(d)(1) mentions only residence/physical presence and does not mention moral character	Held: The statute is ambiguous; under Chevron the BIA's reasonable interpretation controls—stop-time does not apply to good moral character; moral-character period runs through final administrative decision

Pereira v. Sessions, 138 S. Ct. 2105 (U.S. 2018) (defines minimum content of an NTA required to trigger the stop-time rule)
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (U.S. 1984) (framework for judicial deference to reasonable agency statutory interpretations)
I.N.S. v. Aguirre-Aguirre, 526 U.S. 415 (U.S. 1999) (applies Chevron deference in immigration context)
Rios-Pineda v. United States, 471 U.S. 444 (U.S. 1985) (recognized incentive to prolong proceedings to accrue statutory presence time)
Rodriguez-Avalos v. Holder, 788 F.3d 444 (5th Cir. 2015) (deferred to BIA holding that stop-time does not truncate moral-character period)
Duron-Ortiz v. Holder, 698 F.3d 523 (7th Cir. 2012) (same)
Mondragon-Gonzalez v. Attorney General, 884 F.3d 155 (3d Cir. 2018) (describes Chevron framework in this circuit)