Can I stay over night in Puerto Rico with a C1 visa?
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A C1 transit visa is for "immediate and continuous transit" through the US. From your itinerary it sounds like you qualify. It is normal for transit passengers to stay overnight when they arrive at night and leave the next morning. You are not staying longer than reasonable. You can stay in the airport or stay in a hotel room; both of those are reasonable for overnight transit. What you cannot do is use your transit status to do other things like visit friends or do sightseeing during your stay. Make sure you have enough time between your flights in New York because that is where you will go through immigration and customs.
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Source: stackoverflow.com
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