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Victor X. Cerda Acting Director SUBJECT: Interim Guidance Regarding Post-Order Custody Reviews (POCR) After the Supreme Court Decision in Clark v. Martinez On January 12, 2005, the Supreme Court issued a decision in Clark v. Martinez, 543 U.S. (2005), holding that the custody provisions of Zadvydas v. Davis, 533 U.S. 678 (2001), extend to inadmissible and excludable aliens. This memorandum sets forth interim guidance to comply with this decision until new regulations are promulgated. Thi.

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