For the reader curious why the woman in [0] didn't get permanent residency via marriage: > Milne was divorced from the nonimmigrant student she married prior t

For the reader curious why the woman in [0] didn't get permanent residency via marriage: > Milne was divorced from the nonimmigrant student she married prior to 1983. She then married a U.S. citizen but we found, in our above-said unpublished opinion, that she had admitted that it was a marriage of convenience. After another divorce, she married her current husband, a marriage that is uncontested as "bona fide." Her request for legal permanent resident status based on this marriage was denied under INA § 204(c) which precludes approval based on even an admittedly good-faith union if the petitioner had previously contracted an improper marriage.