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The federal government provides a protected status, Special Immigrant Juvenile Status (“SIJS”), to immigrant youth that cannot be reunited with one or both of their parents due to abuse, neglect, abandonment, or another similar basis under state law. In order for Tatiana to be eligible for SIJS, federal law requires that a “juvenile court” issue a special finings order, an order that states the necessary factual findings that are a perquisite to petition United States Citizenship and Immigration Services (“USCIS”) for SIJS.
New York Family Court is a “juvenile court” under the meaning of federal law, as it is “a court located in the United States having jurisdiction under State law to make judicial determinations about the custody and care of juveniles.” See 8 C.F.R. § 204.11(a).
New York Family Courts’ power to issue special findings orders is widely recognized. The Appellate Division, Second Department, confirmed this Court’s power to make special findings orders when it reversed a Family Court’s denial to issue such an order in an appropriate case. See Trudy-Ann W. v. Joan W., 2010 NY Slip Op 03946 (May 4, 2010); see also In re Antowa McD., 50 A.D.3d 507 (1st Dep’t 2008). Additionally, in 2008, the Chief Administrative Judge of the United Court System of New York issued a memorandum that emphasized the appropriateness of the Family Court to make special findings orders in any proceeding that falls within the jurisdiction of the Family Court. See Memorandum from the Honorable Ann Pfau, Chief Administrative Judge, to Judges and Clerks of the Family Court (October 8, 2008) (“Juveniles may be eligible to apply to federal immigration authorities for SIJS where, in any category of court proceeding, a State court has determined that...

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... would not be in Tatiana’s best interest to return to Honduras. She would be in a country where there is no one willing to provide her with adequate support and care. Tatiana’s father is deceased and refused to acknowledge his paternity of Tatiana while he was living. See Affidavit A, B. Also, in Honduras, Tatiana’s extended family has proved inadequate and abusive in their care of Tatiana. See Affidavit A, B. In contrast to what awaits Tatiana back in Honduras, Tatiana’s mother and Mr. Mendoza are willing and able to provide Tatiana with the support and care she needs to flourish as an adolescent and into adulthood.
Tatiana has a happy and secure home with her mother and Mr. Mendoza in the United States. No such happiness or security exists for her in Honduras. Therefore, this Court should find that it is not in Tatiana’s best interest to be returned to Honduras.

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