Interim Decision #3132 

MATTER OF LUTHERAN MINISTRIES OF FLORIDA 

Request for Recognition 

Decided by Board February 27, 1990 

The application of a nonprofit organization seeking recognition under 8 C.F.R. 

§ 292.2(a) (1989) should include detailed information as to how the organization will 

operate and by whom it will be staffed, as well as other evidence regarding the 

organization's qualifications such as resumes for the staff members and information as 

to the availability of legal resource materials, training programs in immigration law and 

procedure, and supervised employment for the staff. 

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

Brown, Temporary Board Member 

An application, on Form G-27 (Request for Recognition as a NonProfit Religious, Charitable, Social Service, or Similar Organization 

Established in the United States under 8 CFR 292.2), was submitted 

by the Lutheran Ministries of Florida, requesting recognition under 8 

§ 292.2(a) (1989). In conjunction with the application for 

recognition, this organization also seeks accreditation of Danielle E. 

Kearney as its accredited representative. The application for recognition will be disapproved. 

Pursuant to 8 C.F.R. § 292.2(a) (1989), a nonprofit religious, 

charitable, social service, or similar organization established in the 

United States may be recognized by the Board of Immigration 

Appeals. Such an organization must establish to the satisfaction of the 

Board that it makes only nominal charges, assesses no excessive 

membership dues for persons given assistance, and has at its disposal 

adequate knowledge, information, and experience in immigration law 

and procedure. 

According to 8 C.F.R. § 292.2(b) (1989), an organization seeking 

recognition must file an application with the Board, along with proof 

of service of a copy of the application on the appropriate district 

director) The district director has 30 days to submit a recommendation to the Board, or to request a specified period of time in which to 

conduct an investigation or otherwise obtain relevant information 

1 In the instant case, the application for recognition was served on the district director 

rather than with the Board as required by 8 C.F.R. § 292.2(b) (1989). 

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regarding the applicant. In the instant case, the Immigration and 

Naturalization Service does not oppose the application for recognition. 

Lutheran Ministries of Florida, hereafter referred to as the "applicant," has submitted in support of its Form G-27 its amended articles 

of incorporation, proof of its tax exempt status, and a listing of legal 

resource materials available to the organization. The applicant also 

submitted a resume for Danielle E. Kearney and two reference letters 

for Ms. Kearney. 

Based upon our review of the applicant's submissions, we find the 

applicant has not demonstrated that it has at its disposal adequate 

knowledge, information, and experience in all aspects of immigration 

law and procedure, including the visa petition process, exclusion, and 

deportation. The general information provided by the applicant does 

not sufficiently apprise us of how the organization will operate and by 

whom it will be staffed. The information furnished by the applicant 

indicates that the proposed representative's training and the organization's experience have focused primarily on the Immigration Reform 

and Control Act of 1986, Pub. L. No. 99-603, 100 Stat. 3359. Even 

though the applicant has indicated the availability of some legal 

resource materials and training programs in immigration law and 

procedure, none of the training programs has been specifically 

identified. Also, it is not shown that the applicant's staff has ready 

access to the Immigration and Nationality Act, Title 8 of the United 

States Code, Title 8 of the Code of Federal Regulations, and the 

Administrative Decisions Under the Immigration and Nationality 

Laws of the United States. Furthermore, there is no indicatimi that 

there is supervised employment for its staff members. The applicant 

has not provided resumes for any of its staff other than for the 

proposed representative. The applicant should provide more detailed 

information as to how its organization will operate and whether it will 

be staffed only by the proposed representative. Further, the applicant 

must demonstrate that it makes only nominal charges and assesses no 

excessive membership dues for the persons given assistance. See 

Matter of American Paralegal Academy, Inc., 19 I&N Dec. 386 (BIA 

1986). 

Also, we must paint out that recognition of an organization does not 

authorize the applicant's representatives to practice before the Board 

or the Service. Pursuant to 8 C.F.R. § 292.2(d) (1989), an organization 

recognized under S C.F.R. § 292.2(a) (1989) may apply for accreditation of persons of good moral character to act as its representatives. 

Any such application should be filed with the Board, along with proof 

of service of a copy of the application on the appropriate district 

director. 

Accordingly, the application for recognition will be disapproved. 

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This denial is without prejudice to the submission of a new recognition 

application with additional information. As the application for 

recognition is disapproved, we need not consider the qualifications of 

the individual for whom accreditation is requested. 

ORDER: The application for recognition is disapproved. 

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