BIA Holds That DHS May Mail NTA to the Most Recent Address the Noncitizen Provided, Overruling Matter of G–Y–R–
In Matter of Diji, decided on September 3, 2026, the BIA overruled Matter of G–Y–R–, holding that, for purposes of an in absentia removal proceeding, written notice is sufficient if mailed to the most recent address the noncitizen provided, including an address provided before the issuance of the NTA. The BIA dismissed the respondent’s appeal, finding that the NTA was properly served by mail and that the respondent did not overcome the presumption of delivery.

