A plain-language timeline of how Congress built and widened the green-card-from-inside-the-U.S. process — put together to make sense of the new USCIS memo.
On May 21, 2026, USCIS put out a policy memo, PM-602-0199. Plainly put: when someone applies for a green card from inside the U.S. instead of going back to their home country to do it, the memo tells officers to treat that choice as a point against them — something they now have to make up for with unusually strong circumstances.
Immigration attorneys have two main problems with this. First, calling adjustment "extraordinary" doesn't match what the law actually says or how it grew over time. Second, the memo appears to cherry-pick old court cases — using ones that help its argument and skipping ones that don't.
Every entry gives you a verified fact and a quick note on why it pushes back against the memo. Read straight down, the message is simple: for about seventy years, Congress kept making adjustment easier and open to more people — which is the opposite of treating it as something rare.
A lot of this fight is about old Board of Immigration Appeals decisions. The worry: the memo points to a case about fraud to make ordinary green-card applications look "extraordinary," while quietly skipping cases that favor applicants.
The history part of this page (the timeline) is well-backed by USCIS and Congressional Research Service sources. The memo itself is now linked above, and its title and its use of the Blas case are confirmed straight from the memo. One thing worth knowing: the harshest "only in extraordinary circumstances" wording actually came from USCIS's press release, not the memo's actual instructions — so it's worth reading the real memo, not just the news about it. The descriptions of Arai, Cavazos, and Ibrahim still come from how other attorneys summarized them, so check those cases yourself before using them in a filing. And remember: the older cases come from a time when the law worked differently (that older system ended on 1/1/1977), so they may not fully apply today.