San Diego Law Review

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This Comment examines the development of the "extreme hardship" standard in congressional legislation and judicial developments, with specific emphasis on the Supreme Court's decision in INS v. Wang. The author suggests that the "extreme hardship" standard poses too high a hurdle for many aliens who wish to remain in the United States. The author argues that, in interpreting the "extreme hardship" standard, the Court has raised more questions than it answered, and that it effectively will have a chilling effect on the expansion of suspension relief. The author concludes that any changes to the "extreme hardship" standard must come from Congress, and proposes several recommendations for amendments to the existing suspension of deportation statute.

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