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To the Migration Court,

The appellant respectfully requests that the Migration Court overturn the decision of Migrationsverket on 2025-01-27 and grant the applicant, [Applicant Name], born on [Date], a permanent residence permit. Migrationsverket has denied her application based on her inability to meet the maintenance requirement due to a lack of steady income. This decision fails to adequately consider the applicant's long-standing and severe medical condition, which renders her permanently unable to maintain herself. I respectfully request that the court reconsider this decision in light of the evidence provided below.

### Background

[Applicant Name] has been living in Sweden since 2009. She has a long-standing history of mental health issues that have rendered her unable to work or support herself financially. Despite her efforts to integrate into Swedish society, her mental capacity has significantly hindered her ability to learn new skills or communicate effectively. She has been under medical care for years, with documented evidence of her struggles, including voice hallucinations and severe difficulties in performing daily tasks. 

In 2019, she was granted refugee status and a temporary residence permit following an appeal against the Migrationsverket's initial rejection. The court at that time acknowledged her intellectual disability and her limited ability to effectively communicate, which was also confirmed in a statement by the Migrationsverket itself. Her temporary residence permit was extended for two years in 2022, and she applied for a permanent residence permit in 2024, which has been rejected.

### Grounds for Appeal

#### 1. Legal Basis: Special Reasons Under Chapter 5, Section 3f

The Swedish Aliens Act (Utlänningslagen), under Chapter 5, Section 3f, allows exemptions from the maintenance requirement if there are *special reasons*. Proposition 2020/21:191 clarifies that such exemptions may apply when an individual cannot meet the requirement due to disability, illness, or other restrictions. It explicitly states:

> "The Government considers that there should be a valve that provides an opportunity to grant a permanent residence permit even to a person who cannot support themselves in some cases... The Committee mentions cases where a person has significant difficulties in fulfilling the set requirement due to disability, illness or other restrictions... A person who has a more long-term reduction in work capacity due to illness or other reduction of physical or mental performance may... have difficulty meeting the supply requirement."

[Applicant Name]'s case falls squarely within these "special reasons." Her lifelong mental health condition and inability to work, compounded by her age (58 years old), present significant barriers to entering the labor market. The law's intent is clear: individuals facing such obstacles due to health or age should not be excluded from obtaining permanent residence.

#### 2. Lifelong Medical Condition and Inability to Work

[Applicant Name] has a well-documented history of severe mental health conditions that have persisted throughout her life. Her medical journal contains diagnoses dating back to at least 2015, including "recurrent depression," "severe depressive episode with psychotic symptoms," "unspecified non-organic psychosis," "chronic delusional disorder," "auditory hallucinations," and "suspected cognitive impairment." These conditions are supported by her ongoing treatment with Olanzapine, a neuroleptic medication used for schizophrenia and bipolar disorders.

She has been taking Olanzapine since 2010 when she was hospitalized for over a year due to these symptoms. Her medical records prior to 2015 have already been provided to the Migration Agency in her previous case (case no. ###), further establishing the long-term nature of her condition. Her inability to work is not temporary but rather a permanent consequence of these challenges.

#### 3. Permanent Inability to Meet Maintenance Requirements

Multiple evaluations by government agencies confirm that [Applicant Name] is unable to work due to her mental health condition:

- A **2022 evaluation by an Occupational Therapist at the Swedish Public Employment Service**, conducted over four weeks, conclusively demonstrated [Applicant Name]'s inability to learn and retain new information or skills. The evaluation tested her ability to perform simple tasks such as cleaning windows, loading a dishwasher, watering plants, or making a ball out of strips of cloth. The results were striking:
  - She struggled to remember the sequence of steps after just 10 minutes.
  - On one occasion, she forgot the instruction immediately after being told and cleaned a table instead of window sills.
  - Even when she managed to follow an instruction, she would forget it by the next day.
  - The only tasks she could perform were those that required no specific instructions and were already familiar to her.

This evaluation critically demonstrates her profound inability to learn new tasks or retain information, severely limiting her employability.

- [Applicant Name] attended a **public adult language school provided by the municipality for newcomers**. Despite her willingness and effort, she was unable to learn Swedish due to cognitive limitations. The school determined that she did not meet the prerequisites for continuing in the language program because of her inability to retain new information or progress in learning.

- A **2024 evaluation by the Psychiatric Assistance department of Social Services** approved her need for assistance with daily life and companionship. She was assigned a social worker who visits several times a week to help with daily tasks.

These professional evaluations underscore that [Applicant Name] is not only unable to work but also incapable of acquiring skills necessary for employment or independent living.

#### 4. Doctor's Evaluation Regarding Employability

The evaluation by Dr. [Name] on [Date] should be considered as supporting evidence for exemption from the maintenance requirement rather than as evidence against it. While the doctor expresses uncertainty about long-term improvement, several key points support the applicant's case:

- **Ongoing mental health issues:** The evaluation confirms a diagnosis of "unspecified non-organic psychosis" and mentions hallucinations, feelings of unreality, forgetfulness, and isolation.
- **Dependency on medication:** The applicant requires ongoing neuroleptic medication (Olanzapine) to manage symptoms, indicating chronic illness.
- **Limited functional capacity:** The doctor notes that she "cannot manage on their own" and depends heavily on support from her son.
- **Language and educational barriers:** The applicant cannot speak Swedish nor read or write in her mother tongue, severely limiting employment prospects.
- **Current inability to work:** The doctor states it is "difficult at present" regarding work capacity due to intellectual limitations.
- **Uncertain timeline for improvement:** While optimistic about potential improvement with continued medication and support, the doctor emphasizes that any future occupation would need significant adaptation.

The Migration Agency's reliance on this evaluation as evidence against exemption is overly restrictive and ignores its broader context. The cautious optimism expressed by the doctor does not negate the current reality: [Applicant Name] is presently unable to work.

#### 5. Unrealistic Expectation of Employment

At 58 years old, [Applicant Name] faces insurmountable barriers to employment. Even if she were physically healthy, she would be nearing retirement age in five years. Combined with her severe mental health issues, diabetes, inability to speak Swedish, lack of education or job skills, and dependence on others for basic tasks, it is unrealistic and unreasonable to expect her ever to secure steady employment or become self-sufficient.

The evaluation by the Swedish Public Employment Service clearly demonstrates her inability to learn or retain new information, even for simple tasks. This, coupled with her doctor's assessment of her current inability to work and the need for significant adaptations for any future employment, makes the prospect of her finding and maintaining employment virtually impossible.

Furthermore, Migrationsverket's argument that her ability to work has the potential to improve in the long term is fundamentally flawed. It disregards her age, her lifelong struggle with mental health issues, and the fact that she has never been employed. The expectation that she could suddenly overcome these barriers and enter the workforce at this stage of her life is not only unrealistic but also contradicts the professional assessments provided.

#### 6. Consistency with Past Court Rulings

The previous court ruling granting [Applicant Name] temporary residence permit acknowledged her unstable mental state and limited ability to communicate effectively. Importantly, Migrationsverket itself confirmed her intellectual disability in this ruling. While this ruling did not directly address employability, it underscores the recognition of severe mental health issues affecting even basic communication and cognitive functions.

#### 7. Migrationsverket's Errors in Decision-Making

The decision letter from Migrationsverket contains several errors that suggest a hasty and inadequate review of [Applicant Name]'s case:

1. In granting a refugee travel document, they incorrectly named an irrelevant country as the one she cannot travel to, instead of her actual country of citizenship.
2. They specified an expiry date for her new refugee travel document that extends beyond her residence permit validity, which appears to be another administrative error.

These mistakes indicate a lack of thorough consideration of [Applicant Name]'s specific circumstances and raise concerns about the overall quality of the decision-making process.

### Conclusion

The totality of evidence—including legal provisions under Chapter 5, Section 3f; extensive medical records; professional evaluations; and past court rulings—demonstrates that [Applicant Name] meets all criteria for exemption from the maintenance requirement due to *special reasons*. Her lifelong mental health condition renders her permanently unable to meet this requirement through no fault of her own.

### Requested Action

I respectfully urge the Migration Court to overturn Migrationsverket's decision and grant [Applicant Name] permanent residency based on *special reasons* as outlined under Chapter 5, Section 3f of the Swedish Aliens Act (Utlänningslagen). Denying permanent residency would disregard both legal exemptions provided by law and humanitarian principles underlying Sweden's immigration system.

Sincerely,
[Your Full Name]
[Your Contact Information]