Importantly, all hardship factors should be considered in the aggregate to determine whether the qualifying relative (i.e., the U.S. citizen or lawful permanent spouse, parent, or child of the respondent) will suffer hardship that is “exceptional and extremely unusual.”178 Applying the aggregated hardship analysis in the case of stateless persons, the hardships resulting from an individual’s lack of nationality in the country designated for removal may well rise to the level of both “exceptional and extreme.”179 Practice Point When addressing the hardship requirement for a stateless person, in addition to the information listed above, consider including: * General information about statelessness in the United States, including lack of alternative forms of relief for this individual and likelihood of continued reporting requirements and other hardships; * The inability of a stateless person to return to visit with their family and community abroad; and * The treatment of stateless persons in the country to which this individual has been ordered removed. Resources EOIR, IMMIGRATION JUDGE BENCH BOOK – ASYLUM, WITHHOLDING OF REMOVAL, CAT, available at https://www.justice.gov/eoir/immigration-judge-benchbook-section-241b. EOIR, IMMIGRATION JUDGE BENCH BOOK – CANCELLATION OF REMOVAL UNDER INA SECTION 204A(B)(1), available at https://www.justice.gov/eoir/immigration-judge-benchbook-240ab1-standard Id. at 64; see also Matter of Recinas, 23 I&N Dec. 467, 472 (BIA 2002) (finding that the “exceptional and extreme hardship” standard had been met in the case of a respondent based on the aggregate of her and her family’s circumstances). 179 In the context of adjustment of status, either before USCIS or the immigration court, immigration law provides an inadmissibility waiver for extreme hardship under INA §212(h) (addressing inadmissibility for a single simple possession of less than 30g of marijuana) and under INA §212(i) (addressing inadmissibility for fraud or willful misrepresentation of fact). While not fully explored in this manual, these instances could benefit from similar analysis. 178 39