Collegial Conversation: When to Refer a Student or Scholar to an Attorney

When is it in the best interest of you and the student or scholar you are advising to refer him or her to an attorney? What are some common questions that international student and scholar advisers face that are normally referred to an attorney?

Linda Melville, international advisement specialist at the University of New Mexico and the ISTA network leader, asked four experienced NAFSAns a series of questions on this topic in order to provide advisers with tips on how to handle some common—and not so common—situations that may require legal advice and therefore the service of an immigration attorney. Our contributors are:

• Linda Gentile, Interim Director of the Office of International Education, Carnegie Mellon University
• Suzanne B. Seltzer, Partner of Klasko, Rulon, Stock & Seltzer LLP
• Steve Springer, Immigration attorney with David Ware and Associates
• Tina Tan, Director of International Students and Scholar Services, University of Colorado Boulder

General Questions	Specific Cases
You Want to Talk About What? I Know, But I Can't Tell You... Can't Touch This And You're Telling Me This Now? Lines in the Sand Attorney, How Do You Spell That? You Get What You Pay For	Green Card Issue Tenure-Track Position Criminal Issue Failure to Enroll

You Want to Talk About What?

What are some situations where it's not within the job description of an adviser, but you find yourself advising students/scholars in particular situations? Does your office have a policy about what and for whom advisers should provide advice? If not, how do you decide where your boundaries are and how do you protect yourself/your office from liability?

Linda Gentile:
"I've been asked a lot of interesting questions over the years—where can I get health insurance now that I'm pregnant? I stabbed my girlfriend accidently, what should I do? I've been arrested for writing graffiti, can you help me? Sometimes those interesting questions are not directly related to a student or scholar's immigration status. Our office does not have a formal policy about topics for which we will not provide advice but, in general, we limit our advice to topics we are responsible for (F and J student and scholar immigration issues primarily) and we refer people to others when a topic is beyond our expertise or falls under someone else's area of responsibility. For example, when students have health insurance questions, I might be able to answer them and I can help someone strategize about options, which might include returning home for health care when someone has a preexisting condition, but I direct students to our Health Services office because the expert on health insurance on our campus is located in that office."

Tina Tan:
"Because our office is generally the 'go to' office for any immigration-related questions for our campus, there is a tendency for folks to think we can help with any immigration question. Of course, this isn't true since our role is only within a fairly narrow context of working on university issues; specifically, advising F-1, J-1 students/scholars, filing H-1B and LPR petitions related to hiring foreign nationals for university-related business/functions. Some of the common questions that we get include questions about how to get a green card; what to do to apply for a green card now that they have married a U.S. citizen or permanent resident; how to fill out their tax forms, etc. What we do with these situations is to explain that these issues are beyond the scope of expertise/advice that we can provide. We may have very generalized answers to some of these questions, but we will then tell the student/scholar that it isn't legal advice, and if they wanted more detailed information, they should speak to an immigration attorney.

Our general policy is that when it's not related to the work we do for the University of Colorado at Boulder (i.e., advising in an F-1, J-1, H-1B, etc. context), we tell the person we aren't able to help out. We explain that the issue is beyond the scope and area of our expertise, and suggest they speak to an immigration attorney for accurate advice. We are pretty clear about the boundaries within which we can offer advice and that we can't help out in the areas for which we aren't trained."

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I Know, But I Can't Tell You...

What are topics or situations in which even if you knew the answer, it would more appropriate for the student/scholar to hear it from an attorney rather than from an adviser?

Linda Gentile:
"I always recommend that a student consult with an attorney if they have been arrested or charged with a crime. In those cases, I actually recommend they consult with two attorneys—a criminal attorney and an immigration attorney.

When someone tells me that they are getting married to a U.S. citizen and asks for advice, I direct them to the USCIS Web site and the local USCIS office for information and tell them that I will not be able to help them. They can use USCIS' resources and see if they feel comfortable completing the forms. If not, or if there is something complex about their situation, I recommend they consult with an immigration attorney. Our office doesn't handle permanent resident applications so, in general, I steer people towards attorneys whenever someone needs guidance about permanent residency options or applications. I also steer people to attorneys when they appear to have been out of status for a very long time—especially if they were never in F-1 status. Recently, we've begun to receive more questions from our students who have filed H-1B petitions asking questions about travel with a pending H-1B petition or whether or not they can change employers before the H-1B petition takes effect. Some of those questions I have an opinion about, but I've heard various opinions so I recommend that our student ask the attorney who has filed the H-1B petition for his/her guidance. If they have an issue or question they don't want their hiring company to know about, I suggest they consult with their own attorney."

Tina Tan:
"I actually file H and LPR cases for the university, so I am aware of these processes and issues. However, I'm not comfortable advising students/scholars about these issues if they are not employed by our university, so I will certainly tell them that they need to talk to their employer/attorney about these issues since it would be more appropriate.

It's the transitional situations from one status to another that makes this a little trickier where there is still some interface with our office. Examples include:

• Students on OPT whose employers are filing an H1b petition on their behalf—there is some juggling with this to answer the relevant F1 OPT kinds of issues when their H1b is pending.
• Students who are getting married to a U.S. citizen and want to file their paperwork for a green card—some interface with our office is needed with regard to their SEVIS records (more below).
• Scholars for whom we are filing a permanent residency case and have questions/issues come up during the I-485 stage, which is clearly not part of the work that we do for our employer.

Because so much of what we do involves immigration work, I think we all have a tendency to want to find out the answers to questions that we can't answer, particularly if it involves a student/scholar  we know and have had many interactions with, because we want to help. But I think we have to also remind ourselves that it's easy to know enough to be dangerous and be aware of our boundaries! So ultimately, the question I ask myself is:

• Is the situation relevant to our work at the university?
• If not, the answer is best obtained from another source like an attorney."

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Can't Touch This

What are some situations in which advisers should always refer students/scholars to an attorney?

Suzanne Seltzer:
"There are two main areas of concern that I think should always be referred to an immigration attorney:

The first is anytime a student/scholar has an encounter with the police. Even minor criminal offenses can have far-reaching consequences on their nonimmigrant status, ability to apply for permanent residency, ability to travel, and is a key disqualifying factor under the character requirement for naturalization. Unfortunately, criminal attorneys are not always aware of the immigration consequences of plea agreement, so students/scholars would be wise to speak to an immigration attorney regarding the matter.

The other situation that should be referred to an immigration attorney is if a student has no immigration status, or is unlawfully present. Unfortunately, given the limited forms of relief presently available for those who are unlawfully present, the immigration lawyer's role may be limited to advising them of just that. However, it is possible that by exploring the student/scholar's history, that a viable option will be discovered; perhaps they are 245(i) grandfathered—meaning something was filed on their behalf long ago which allows them to continue to pursue options; or they may have an asylum claim or a claim for another form of humanitarian relief, etc. What is most important is ensuring that the student/scholar has a realistic picture of their current situation, and to learn what, if any, options may be available."

Steve Springer:
"International offices should consider establishing policies or guidelines about this. A variety of approaches might be reasonable, depending on skill-levels among advisers, staffing levels, broader institutional policies, and other factors. Most advisers are willing to provide detailed information to potential students who need to file a change of status application, but most also limit their role in the process. Some advisers assist faculty and staff with adjustment of status applications, but most advise applicants that they may use legal counsel for the process. How does the adviser avoid providing advice that might be considered legal advice? What kinds of problems (prior criminal issues, immigration violations, issues with dependents in the adjustment setting, for instance) should trigger referral to an attorney? An office policy concerning the role of the adviser in these kinds of processes and when to refer to legal counsel can be invaluable. Printed materials can inform the office's clientele both about key aspects of the process and about the office's role in the process."

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And You're Telling Me This Now?

What are some red flags to get an attorney involved? (e.g., students who are undocumented, students/scholars with a criminal history, PR applications based on family, refugee/asylee issues/applications, those with previous immigration violations, etc.)

Linda Gentile:
"All of the examples listed are red flags that would prompt me to encourage a student to consult with an immigration attorney because they are all issues that I don't have expertise in and I haven't been hired by the university to deal with those issues. It's not that I don't want to be helpful to the student. In fact, it's more helpful to refer them to an immigration attorney because they would get better advice from someone that expertise in those areas."

Tina Tan:
"Some red flags for me would be if the student/scholar has had some run in with the law, periods of unlawful presence, or undocumented students who are trying to get legalized; these are definite cases where I'd steer the student/scholar to talk to an attorney. Students/scholars who are trying to get a green card on their own (via marriage, self-filing), we tell them their cases would be beyond the scope of our areas of expertise and they are best off speaking with an immigration attorney with their questions since it isn't really related to our work at the university. We have had occasions where students were out of status and had fairly complicated circumstances around being out of status; we'd suggest they talk to an attorney as well, particularly if they wanted to pursue reinstatement."

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Lines in the Sand

What can an attorney do for a student/scholar that an adviser can't do? What can an adviser do that an attorney can't do?

Suzanne Seltzer:
"I think it's not a matter of who can or can't do what, but more about the quite different, but complementary, roles of an attorney and an adviser. As an attorney, I've always thought that my role kicks in when the adviser's role ends. So for students, that would be post-OPT issues. I leave OPT, the new STEM extension, travel on OPT, changes/transfers of F-1, etc to the experts. I do not know how SEVIS works, and terms like "batch processing" make me nervous!

For scholars I think it's a little murkier. Like the issues surrounding F status, issues specific to the J program, what can be done with which funding, and what documents are needed for travel, again, I leave that to the experts. However, many scholars are not in J status, and some may even be ready to apply for permanent residency. In these situations, I think the division between what is the attorney's role and what is the adviser's role may come down to what the institutions handles in-house, whether the immigration issues in question are related to the scholar's work/responsibilities at the institution, and whether there is a potential conflict between the institution's interest and the scholar's interest."

Steve Springer:
"There are a host of things that an adviser can do for a student or scholar that an attorney can't. Most of these are obvious to advisers and experienced attorneys, but they're not always as obvious to students and scholars and even to attorneys who don't regularly work with students and scholars. I receive calls and e-mail messages from students and scholars who should, instead, be consulting their advisers, and I explain why I cannot help and strongly encourage them to contact their advisers. But there are at least a couple of broad categories of situations in which an attorney might be able to help when an advisor might not.

The first category involves processes that the office does not handle and those situations in which, at some point, the adviser must explain that the matter is beyond the scope of his/her duties or not within her/his area of expertise. For instance, some offices do not handle permanent residence processes and would refer an employee to an attorney. As noted above, these might also include situations in which students and scholars have been accused of crimes or need more than basic information about a change of status or adjustment of status application. While some advisers provide only very limited information about adjustment of status, for instance, it seems likely that most would refer an employee to an attorney with questions about whether children would be protected by the Child Status Protection Act.

The second category involves situations in which the student or scholar might not want to disclose certain information to the adviser. For instance, students and especially scholars might not want to reveal personal information, such as certain medical conditions, that could affect admissibility to the United States. Faculty and staff members might not want to discuss a "porting" to a new employer with the adviser, who is a representative of the current employer. It is essential for both attorneys and advisers to know when to refer a student or scholar to the other."

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Attorney, How Do You Spell That?

What guidance do you provide to students on how to look for an attorney? Do you provide a specific list of attorneys?

Linda Gentile:
"We have a handout for students and scholars that explains when someone might want to hire an immigration attorney, how to find an attorney, questions to ask before hiring an attorney and a list of attorneys who are preapproved to handle employment-based applications for our institution. We encourage students and scholars to be good consumers by asking questions so they understand how an attorney can help them, how much it will cost (including for telephone conversations), and whether or not the attorney has experience with the student/scholar's issue."

Tina Tan:
"We have a handout titled "How to Choose an Immigration Attorney" that we give out to those who would like it. This handout actually is comprised of two articles written by attorneys about things to consider in choosing an attorney. We don't provide a list of specific attorneys, but we do give out the Web site for the Colorado AILA, where they can get a list of practicing immigration attorneys in the state.

I like to explain to students/scholars with questions that we can't answer/situations that are beyond us, that they can always pay for an hour's consultation with an attorney to get the answers to the questions they have. And if they feel that they need the attorney to help them with the case, that's when they can retain the attorney's services."

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You Get What You Pay For

How would you respond to a student who doesn't have the money or does not want to spend the money to hire an attorney?

Suzanne Seltzer:
"Students should check with the international office to find out if the university has a relationship with attorneys that may offer free consultations to the students, or if the university hosts outside counsel presentations on "Post-OPT options" or similar topics that could introduce students to the world beyond student visas. So before even thinking about hiring counsel, the student needs to do his/her homework on what they may want counsel to do, and if they actually need counsel for their particular situation. If it turns out they do need counsel, they will get much more out of the consultation if they have already done some research on their own.

If a student does not have the option of a 'free consultation' and does not want to pay for a consultation, I honestly do not know what to tell them. Immigration is getting more challenging every day, and even seemingly simple petitions may have hidden complexities. For example, I recently consulted with a student who filed an I-539 to change her status from F to B. The adjudication took so long, as we know it does, that by the time it was approved, the student found herself unlawfully present. What is particularly disconcerting, is that the student called USCIS (presumably the 800#) and was told it was no problem for her to remain while the petition was pending.

I would caution students not to choose counsel based on price. I understand that hiring a lawyer can be expensive, but a poorly prepared and filed petition can be even more costly."

Steve Springer:
"I would only add that there are resources on the NAFSA Web site addressing this and that students and scholars often need basic information about how to approach the issue. For instance, I frequently encounter students and scholars who hired the attorney with an office closest to the campus. Most advisers probably agree that, unless the student or scholar is involved in removal proceedings, she/he should not select counsel based on location and would be better served by a qualified immigration attorney even if the attorney is not located nearby.

Advisers should become familiar with any nonprofit organizations, for instance The Catholic Legal Immigration Network, Inc. (CLINIC), who might serve their communities.

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Specific Case Questions

Green Card Issue

A student comes in to tell you that they have married a U.S. citizen and would like to apply for the green card. What do you advise them about this process? Under what circumstances would you advise the student to contact an attorney?

Tina Tan:
This is quite a common scenario for our office. We actually inform the student that our office cannot help them with the green card process, but we do give them a handout (Marriage to a U.S. Citizen) that is in the form of an FAQ and a list of documents that they will need to complete to apply for a green card. The handout includes links to the State Department's Web site about marriage to a foreign national.
[Note: The FAQ was adapted from materials shared by Indiana University and the checklist of documents required was shared with us by the University of Colorado Health Sciences Center (prepared by a former immigration attorney)].

We tell the student to look over the Marriage to a U.S. Citizen handout, and that they could either try to file on their own or get professional help with the filing from an immigration attorney. We also supply them with the handout about choosing attorneys and the Colorado AILA Web site if they were interested. Students with complicated immigration histories, or who are subject to the J1 two-year home residency rule, are ones we'd strongly advise to work with an attorney.

However, since the student is on a student visa, things can get a bit complicated with SEVIS and reporting requirements on their SEVIS records. There are some grey areas here and an institutional policy regarding how to handle the student's SEVIS record is useful. Scenarios for an institution to consider include what to do if they work on their EAD that they obtained based on the pending green card; if you should keep their SEVIS record active if you know they have filed the I-485, or if they have travelled and reentered the United States on their Advanced Parole document.

Read more on these issues

Because of this SEVIS piece, we end up doing some general advising—we ask the student to let us know if they want to maintain their F1 status, in which case we continue SEVIS reporting and they have to abide by the F1 regulations. We suggest the students talk to an attorney if they have questions about this. We do advise students that if they have filed their I-485 application that they should not use their F1 visas to reenter the United States if they are travelling because they now have immigrant intent. These are some very general things we talk to students in this scenario about and if they wanted more specifics, we suggest they consult an attorney.

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Tenure-Track Position

A scholar on a J-1 visa with a home residency requirement comes in to tell you that he has a good chance of being offered a tenure-track position in his department. How would you advise the scholar and what questions would you ask? What if the home residency requirement was based on U.S. government funding? When would you refer him to an attorney?

Linda Gentile:
I would ask the scholar questions about his/her sources of funding, country of citizenship and residence immediately prior to coming to the United States, and field of research. Sometimes the consular officer's determination on the DS-2019 is in error so I would want to form my own opinion of whether or not my scholar appears to be subject to the home residency requirement. If it's not clear or there is doubt, I encourage my scholars to seek an advisory opinion from the Department of State and I will provide the Web site where they can obtain more information. If the scholar really is subject, I provide general information about how one might obtain a waiver (no objection letter, interested government agency) and where on the State Department's Web site the waiver information can be found. I also caution scholars about the implications of obtaining a waiver if there is a possibility they might extend their J stay. If they need assistance in actually obtaining a waiver or understanding the process, I would direct them to an immigration attorney. And, if our university is hiring them in a tenure-track position, the chances are that the hiring department already has retained the services of one of our preapproved attorneys who can assist with this.

Suzanne Seltzer:
If the scholar is subject to the two-year home residency requirement and is not eligible for a no objection waiver, because of U.S. government funding, I would first discuss an O-1 with them. Depending on the type, source, and amount of funding, it may be difficult to obtain a waiver, but even if possible, it is certainly time consuming. The O-1 will allow the scholar to transition to the tenure track position. Unfortunately, if the scholar's spouse has been enjoying the EAD benefit of a J-2, the scholar may not be as excited about this option as one may hope.

The ultimate goal for this scholar would be to either get a waiver or to fulfill the two years, so that he or she may eventually obtain permanent residency. It would be important to explore the various waiver options with the scholar—Interested Government Agency (IGA), Hardship, or Persecution. However, if there was no immediate or likely waiver option, we could also discuss the feasibility of fulfilling the two years. Since the two years can be fulfilled incrementally—i.e., summers in the home country, a sabbatical at some point—it may not be as disruptive as one might think, particularly as the scholar may remain on the O-1 indefinitely. These are just some thoughts on how this situation can be managed to allow the scholar to accept this post.

Steve Springer:
We see a variety of approaches among international offices when it comes to waivers of the home residence requirement. Some provide only the basic information about how to obtain a waiver. Others, if the institution is planning to hire the individual, will provide assistance with the waiver, ranging from very limited to extensive assistance. Often the first step is to make sure that the individual is properly subject to the requirement, and not simply that he/she seems to be subject due to a mistake. If the person is subject to the home residence requirement, but no longer in J status (for instance, is now an F-1), then a change of status might be possible but would involve important ramifications to be carefully discussed. While many international offices have the expertise to handle various kinds of waivers, most simply do not have the staffing to do so, and in most cases referring to immigration counsel makes sense.

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Criminal Issue

A student has been arrested for serving alcohol to minors at a party that he hosted (serving alcohol to minors is a 4th degree felony in your state). The student has a criminal attorney, but that attorney has no experience with immigration law and does not seem to think it is important to the student/case. What are the immigration issues for the student? When and how would you advise the student to speak with an immigration attorney in addition to the criminal attorney? How would you talk to the student if the student claims to not have the funds to hire an attorney?

Linda Gentile:
I would advise the student to speak with an immigration attorney as soon as possible because I know there are immigration implications. I don't know all of the implications so I know I can't provide the kind of advice that this student needs, but I know the student needs this advice quickly. If the student does not have funds to hire an attorney, I would try to find an attorney who might be willing to work pro bono or direct the student to community resources that might be able to provide assistance.

Steve Springer:
Any student accused of a crime should be encouraged to seek legal advice. In addition to the obvious criminal consequences of a conviction (fines, imprisonment, etc.), convictions of certain crimes might render someone removable from the United States or inadmissible to the United States. A student or scholar who is removable might be placed into removal (deportation) proceedings. A student or scholar who is inadmissible would likely face serious problems reentering the United States after a trip abroad or adjusting to permanent resident. Sorting out whether a conviction is one that carries immigration consequences often requires careful analysis of court records, the statute under which the person was convicted, and case law. What might not seem like a crime of moral turpitude (CIMT) to the average person or even to an attorney specializing in criminal law might in fact be considered one for immigration purposes. And what might not be a CIMT in one state may be a CIMT in another state. Even sorting out what constitutes a conviction for immigration purposes can be complicated (no, having the record expunged doesn’t mean you weren’t convicted!). Once a detrimental conviction has occurred, a careful analysis is required to determine whether any waiver or other relief is available.

Most attorneys specializing in criminal law know little about immigration and turn to immigration attorneys for information about how the client’s plea of guilty (or nolo contendere) to a criminal charge might affect the client’s immigration status. Some aren’t experienced enough with immigration issues to know that it’s essential to seek this advice, so the client must be proactive and demand that the criminal attorney consult an immigration attorney, or the client must directly consult an immigration attorney. The client must be fully informed about the immigration consequences of conviction for two reasons. First, this is often a deciding factor in determining how to proceed in a case (for instance, if a guilty plea to a lesser offense might be available and avoid immigration problems, it might be worth considering). Also, if a client might be removable or inadmissible to the United States, she/he shouldn’t first learn about this when ICE agents show up at the door or when returning from a trip abroad and undergoing inspection at the port of entry. Often an immigration attorney can provide the information needed by the criminal attorney quickly, and this means that it is often not expensive to the client. If the student or scholar cannot afford this, it certainly makes sense—as Linda suggests—to seek pro bono help, through the local bar association or from one of the excellent nonprofits that provide immigration-related legal services in many communities. Ask your colleagues for information about these.

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Failure to Enroll

An F1 student you terminated in SEVIS six months ago for reason of failure to enroll shows up in your office asking to return to classes in the next semester, which will begin in less than one month's time. What would you tell the student? What if the student was married to a U.S. permanent resident and the spouse had already filed the I-130 for the student? When would you refer them to an attorney?

Tina Tan:
If the student had already been readmitted to the school, I'd tell them they could go ahead and get registered for classes. However, the immigration status piece of it will have to be addressed. We'd have to first of all determine if the student had stayed in the United States from the time of termination or if they had exited and reentered.

Establishing what their current immigration status is right now would help determine the course of action.

If they had not left the United States from the time of termination, we'd tell the student that they appeared to be out of status, and they should either exit/reenter with new SEVIS documents and payment of a new SEVIS fee, or file for a reinstatement. We'd go over the criteria for having a reinstatement approved so the student is aware of what the parameters are for a successful application. The reinstatement is really a personal application, so we normally tell students they can either file on their own, or suggest an attorney help with the reinstatement application, particularly if it's already six months beyond the termination date.

If they had exited upon termination, and were now back in the United States in another status, then the conversation will revolve around if they can exit/reenter on a student visa or if they can do a change of status to a student status. Since a change of status is, again, really a personal application, we will mention that they can either file on their own, or have an attorney help with that application.

If the student was married to a U.S. permanent resident, and the spouse had already filed the I-130, this complicates matters quite a bit. We'd inform the student that the filing of the I-130 alone does not grant a lawful status to the student and ask if s/he had already filed an I-485.

We'd tell the student they could go ahead and register for classes for the next semester (assuming they were readmitted to school) but we'd also advise the student to talk to an attorney if they had not already done so regarding his/her legal status and their eligibility for permanent residency, especially if it appeared the student had a period of time where they were not in status.

Suzanne Seltzer:
As noted above, when it comes to student issues, particularly those that involve SEVIS, I definitely think the adviser is in a much stronger position to be of any assistance. My biggest concern when I hear that a student is married to a permanent resident, even if they have not yet filed the I-130, is travel. The visa form clearly asks if a spouse or even a fiancée is in the United States, so the student is required to disclose that information when they apply for the visa. Depending on when the marriage took place, this is potentially an issue.

If the student disclosed the relationship during the visa interview, or met the fiancée/spouse after entering the United States in F status, then the issue of whether they could be reinstated into F status is one I would refer back to the adviser.

As for the I-130, the student should be made aware that the filing of the I-130 does not give them any benefits or status in the United States, and that in order to obtain benefits, they would need to be eligible to file the adjustment. If the student is just recently married, it is unlikely that he or she would be eligible for adjustment anytime soon, since there is a five-year backlog (or more) on these types of cases. However, it may be possible to upgrade the petition if the spouse has been an LPR for five years and is eligible for naturalization. Once the spouse becomes a citizen, the student may immediately adjust.

If this is not the case, and the student is not reinstated, then most likely the student will be in limbo status until such time as the I-130 petition is current, and she is eligible to file the adjustment.

Steve Springer:
It seems to me that an adviser would never be wrong to refer a student facing a difficult reinstatement application to an attorney. Also, the effect of processing toward permanent residence on certain nonimmigrant statuses is a very murky area, and I think that an adviser would always be wise to refer students or scholars to immigration counsel to discuss these matters. Students and scholars often receive incorrect information from friends about permanent residence processes, and it can lead to dire circumstances. Particularly for those in F and J status, receiving accurate information and careful advice is crucial. The discussion is often a nuance one, sometimes involving the value of living by the requirements of the nonimmigrant status as weighed against taking advantage of certain adjustment applicant benefits that might be considered abandonment of the nonimmigrant status.

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