Immigration · Primary-source case analysis

Barton v. Barr: An Inadmissibility Offense Can Trigger the Stop-Time Rule

By Aneeta Mishra and Timothy Chan

Published April 24, 2026

Decision: Barton v. Barr, 590 U.S. 222 (2020).

Barton interprets the stop-time rule governing continuous residence for lawful-permanent-resident cancellation of removal.

A longtime resident sought cancellation

Andre Barton had been admitted as a lawful permanent resident and later sustained several convictions. He conceded removability but sought cancellation, which required seven years of continuous residence after admission.

The stop-time inquiry is distinct from the charge of removal

The statute stops accrual when a noncitizen commits an offense referred to in the inadmissibility grounds that renders the person inadmissible, or an offense under the deportability grounds that renders the person removable. The Court treated this as a separate eligibility rule.

An admitted resident can be rendered inadmissible for this purpose

The Court rejected the argument that inadmissibility provisions apply only to people seeking admission. A post-admission offense listed in section 1182(a)(2) can trigger stop time even if the removal charge proceeds under a different statutory ground.

Disposition

The Court affirmed the denial of cancellation eligibility because Barton committed a qualifying offense before completing seven years of continuous residence. The ruling did not create a new ground of removal.

Key takeaways

• Build a residence timeline from the date of admission.
• Match each offense to both inadmissibility and deportability provisions.
• Separate removability from eligibility for cancellation.
• Determine the offense date rather than relying only on the conviction date.