Interim Decision #3196 

MATTER OF FLORIDA RURAL LEGAL SERVICES, 

INC. 

Application for Accreditation 

Decided by Board February 22, 1993 

An organization requesting recognition or accreditation of its representatives, which 

has physically separate offices, must demonstrate by individual application that each 

office independently has at its disposal adequate knowledge, information, and experience in immigration law and procedure and that it makes only nominal charges and 

assesses no excessive membership dues for persons given assistance. 

BY: Milhollan, Chairman; Dunne, Morris, Vacca, and Heilman, Board Members 

An application was submitted by Florida Rural Legal Services, Inc., 

an organization recognized by the Board of Immigration Appeals 

under 8 C.F.R. § 292.2(a) (1992), requesting the accreditation of 

Jackson M. Francois, Federico Hernandez, Maria D. Herrera, Luc 

Charles Lully, Ernesto Urbina, Jr., Angie Vega, and Jean B. Volcy as 

its representatives under 8 C.F.R. § 292.2(d) (1992). The application 

will be disapproved. 

An orpnization recognized by the Board under 8 C.F.R. § 292.2(a) 

(1992) may apply for accreditation of persons of good moral character 

as its representatives. An organization may apply to have a representative accredited to practice solely before the Immigration and Naturalization Service, or before the Immigration and Naturalization Service 

and the Board of Immigration Appeals (which includes practice before 

the immigration judges). An application for accreditation must fully 

set forth the nature and extent of the proposed representative's 

experience and knowledge of immigration and naturalization law and 

procedure and the category of accreditation sought. 

Florida Rural Legal Services, Inc., hereafter referred to as the 

"applicant," has requested the renewal of the full accreditation of Mr. 

Hernandez and Mr. Urbina and partial accreditation of Mr. Francois. 

The applicant requests full accreditation of Mr. Lully, Ms. Volcy, and 

Ms. Vega who were previously granted partial accreditation. In 

addition, the applicant requests partial accreditation of Ms. Herrera. 

In letters dated March 3, 1992, the district director recommends 

disapproval of the applications for accreditation of all the proposed 

representatives. 

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Interim Decision #3196 

First, we note, as pointed out by the district director in his letters 

dated March 3, 1992, that the request for renewal of the accreditation 

of six of the proposed representatives is untimely. The 3-year full 

accreditation of Mr. Hernandez and Mr. Urbina and the 3-year partial 

accreditation of Mr. Francois, Mr. Lully, Ms. Vega, and Ms. Volcy 

lapsed on October 18, 1991. The request for renewal of their 

accreditation was not filed with the Board until March 2, 1992. See 8 

C.F.R. § 292.2(d) (1992)_ 

The applicant's organization located at Lakeland, Florida, is 

recognized by the Board under 8 C.F.R. § 292.2(a) (1992). The 

applicant's submissions reflect that it has six branch offices located 

throughout Florida. None of these branch offices is recognized by the 

Board. The applicant's application for accreditation does not specify at 

which offices the proposed representatives will be working. The 

resumes for these proposed representatives indicate that they live 

throughout Florida. 

An organization that has physically separate offices must submit an 

application for recognition for each office, even if the organization is 

recognized at one of its offices. Such an application for recognition 

must show that the office at the other location independently has at its 

disposal adequate knowledge, information, and experience in immigration law and procedure, and that it makes only nominal charges and 

assesses no excessive membership dues for persons given assistance. 

See Matter of Lutheran Ministries of Florida, 20 I&N Dec. 185 (BIA 

1990). The applicant's organization, at each office, must be familiar 

with all aspects of immigration law and procedure, including the visa 

petition process, exclusion, and deportation. Also, an application for 

recognition should disclose the relationship between the branch and 

parent offices. We emphasize that the purpose of requiring that each 

office independently establish its qualification for recognition is to 

assure that the interests of aliens are safeguarded and that there is 

adequate representation of persons given assistance. We further note 

that recognition of any organization is not intended as a means for a 

private attorney or law firm to employ immigration counselors as an 

extension of the attorney's or law firm's services. 

Inasmuch as the applicant's six branch offices are not recognized by 

the Board and the application for accreditation does not clearly reflect 

at which offices the proposed representatives will be working, we are 

not able to consider the application for accreditation at this time. 

Consequently, the application for accreditation of the proposed 

representatives will be disapproved. This denial is without prejudice to 

the snhmission of a new accreditation application in conjunction with 

or following the application or applications for recognition. 

ORDER: The application is disapproved. 

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