Interim Decision Number 1459 MATTER OF SANTILLANO. In Section 212(e) Proceedings. A-13184458Board of Immigration Appeals Executive Office for Immigration Review U.S. Department of Justice Decided by District Director March 10, 1965 Since compliance with the 2-year-foreign-residence requirement of section 212(e), Immigration and Nationality Act, as amended, would result in exceptional hardship to his United States […]