In this recent unpublished decision, the BIA remanded for further consideration of the respondent’s argument that she is entitled to equitable tolling of the TPS registration deadline due to mental incompetence and physical illness. Attorneys can cite this decision to argue in favor of equitable tolling for other deadlines as well.
Gladys Margarita Hernandez, A095 080 333 (BIA Aug. 23, 2013) by Immigrant & Refugee Appellate Center